At the heart of the tank farm issue is the reality that a new tank, like the one operated by Chevron that was installed in 2007, emits half the deadly pollution than an older storage tank does, according to permit writer George Yun. The idea that some tanks are "grandfathered" in with allowable excess emissions rates makes no sense when regulating something as deadly as benzene emissions. Reasonable people would assume that there would be time limits explicitly stated for how long they may continue to operate with outdated dangerous technology. “Grandfathering” by its nature should guarantee that an end is imminent, it should not be a state of perpetual life support for old and deadly operations.
Thanks to the research of Cascadia Times' Paul Koberstein, we know the Northwest Industrial Sanctuary is home to 536 petroleum storage tanks with a 300+ million gallon capacity, and combined are responsible for spewing 1,392 tons of Volatile Organic Compounds (VOCs) into our air shed. The majority of the tanks are old, between 40 and 100-yrs old. Due to the high public health threat of emissions associated with petro chemicals, including benzene a toxicant linked to leukemia, which has been identified at levels above health benchmarks across the entire Portland metro air shed, all storage tanks with the potential to emit this know carcinogen should be held to the strictest emissions standards, regardless of age of facility. While I appreciate that this move would be a financial burden to the companies operating these tanks, I also believe it is unconscionable that they are allowed to co-opt public health by spewing 100s of tons of deadly emissions into our air shed.
The public is currently being invited to comment on the proposed renewal of Air Quality Permits for Chevron, Kinder Morgan, and Shell (Equilon) petroleum storage facilities in NW Portland. If you have not submitted comments, or did not provide testimony at the public hearing last week, please consider doing so before the deadline: 5pm, Tuesday, May 25th to Catherine Blaine.Click here for the DEQ notice.
Some recommended "asks" from comments already submitted:
1. Continual ambient air monitoring at the tanks. 2. On-site, continuous, monitoring of wind speed and direction at each facility conducted by independent contractors. 3. Recording/reporting of all "unburned fuel" and "gasoline" odors to all facilities, and attribution applied to tank farms in aggregate, without the requirement of citizens to name an individual source. 4. Time frame to phase out all older tanks and/or require all tanks to adhere to the stricter emission standards achievable by newer tanks. 5. Clarification of why some companies, including Kinder Morgan, are classified as something other than a storage facility, despite the near identical operations to the other 6 companies operating in the tank farm who are. Citizens know that this allows them to skirt federal reporting requirements designed to safeguard public health such as the federal Toxic Release Inventory (TRI) database. TRI was established under the federal Emergency Planning Citizen Right-to-know Act, that helps protect communities in case of a disaster, by informing them of the nature and volume of volatile toxic chemicals that are stored, processed, and otherwise might create a public health threat in the event of a catastrophic emergency. The tank farms in the NW Industrial Sanctuary are situated on a known earthquake fault line and in a flood zone.
One neighbor summed it up best, when she asked the final question during the pre-hearing Q&A period: "Since the Town Hall Meeting a year ago at Chapman Elementary School, has the agency done any tests to better understand the problem or taken steps to fix it?"
Gregg Lande, Oregon DEQ's Senior Air Quality Analyst and the person responsible for the state's air monitoring program and the air toxics benchmarks, responded: "No."
And there is the sum of the meeting on the Air Toxics Benchmark Hearing, with particular regards to the new manganese benchmark. Manganese is the toxic that many in the room last night had first learned about last year, when also learning that their neighborhood schools ranked among the worst in the nation due to the presence of manganese and other toxic industrial emissions. The 40+ neighbors, parents and otherwise concerned citizens that attended the benchmark hearing learned that this rulemaking will have no effect on the problem identified by the study published by USA Today in November 2008.
No positive effect that is.
The more insidious threat is that under a veil of "science," the rulemaking on manganese, lead, ethyl benzene and mercury can and will be used by the polluters that put these toxins in our environment as continued protection of the status quo, and fodder for the sources to claim "they do no harm."
Let me do a quick recap of the status quo: 65 Portland area schools (117 statewide) rank in the worst 10% of schools across the nation with the most dangerous air quality due to proximity to industrial sources of pollution. The federal government's most recent National-scale Air Toxics Assessment (NATA) report, released in July 2009, showed Oregon to have the 3rd largest population at risk of excess cancer due to toxic air pollution. Finally, according to the National Cancer Institute, Multnomah County, which ranked among the worst counties in the nation in that same NATA report, also leads the state, and the nation, in rates of breast, lung, pancreas and brain cancers.
What was confirmed at the hearing is the DEQ has no measurement, or specific program in place to measure and address the short-term exposures that our children risk living in the many identified toxic hot spots across the city. These benchmarks are annualized averages and meant to address a lifetime of exposure. Risk is assessed by modeling and very limited monitoring data from the one monitoring station situated in North Portland. As Dr. Lambert, a toxicologist from OHSU, who sits on the ODEQ's Science Advisory Committee who makes these rulemaking recommendations, said the state does consider "these benchmarks to represent an acceptable level of risk."
Fortunately the public had some important advocates to put our concerns on record. Among them:
1. Dr. Matthew Brodsky, a neurologist at OHSU, who has done specific research on the effects of manganese. He testified to studies that show short term acute exposures to cause irreparable damages in the brain. In written testimony he notes: "It is astounding to me how this can be allowed to continue in such a densely populated neighborhood, and in such proximity to an elementary school full of children with rapidly developing little brains that are at the greatest risk of long-term neurologic damage."
2. Maye Thompson, RN, PhD, Environmental Health Program Director, Oregon Physicians for Social Responsibility, who noted: "We are accruing evidence that air pollution affects the brain and neurological development. For instance, children from highly polluted Mexico City, compared with matched controls from a low-pollution city, showed a high incidence of cognitive deficits on psychometric testing, and brain abnormalities in the prefrontal region on MRI. These findings suggest that brain inflammation linked with air pollution begins at an early age and is associated with early cognitive impairment."
3. Sharon Genasci, Northwest District Association Health & Environment Chair, offered a great chronicle of neighbors' efforts to monitor the air shed themselves and the history of recording high levels of manganese and lead in dust samples taken off porches near, and downwind of, one of the city's largest steel foundries. She also noted her committee addressing the issue of conflict of interest of members of the science advisory committee as far back as 2004. Genasci suggested that the conflict of interest was severe enough to put a shadow over any of the benchmarks set during that period.
4. Finally, testimony was provided by Sattie Clark, parent, local manufacturing business owner, and founder of a sustainable business alliance. Clark described her personal experience of behavioral and other health issues with her son and the subsequent discovery that he had high, chronic, levels of arsenic. When she consulted the USA Today study on schools and industrial pollution, she found that the neighborhood school near her family's house was situated near an industrial source of arsenic, and arsenic was a pollutant of concern in the profile of the school's air quality problem.
Where are we now? Scientific research supports that there are no known safe levels of exposure to neurotoxins such as manganese yet DEQ's proposed air toxic benchmarks for emissions do not guarantee *reductions* in the current levels of manganese emissions around Portland and the state. We have until June 30 to let DEQ know their proposed benchmarks do not adequately protect public health.
Nicholas Kristof of the New York TImes wrote an editorial yesterday about an about to be released report from the Federal Cancer Panel, entitled: New Alarm Bells about Chemicals and Cancer. Read it here. This is on the heels of a report released earlier this year, and reported on by Blake Morrison for USA Today. In this study the General Accounting Office, chastised the EPA for its failure to protect children from toxic chemicals. Read Blake's article here.
This is all the more reason for us to question the decade old Air Toxics Benchmark program in Oregon. We need to press the state to ensure that the best new science is taken into consideration when new air toxics benchmarks are adopted. The problem with these benchmarks, if they stand on their own, is the false pretense they provide for polluters. These allow company's to assert, like ESCO did in a letter to the NW Examiner in December last year, that the toxic releases that have put 35 of Portland schools in the top 5% of schools across the nation with the worst air due to the aggregate load of toxic industrial air pollution, are "doing no harm."
Please help us send a strong message to the DEQ and the EQC - the rule making body for that agency - that we expect the state to adopt air toxic standards that are protective of public health, particularly children and other vulnerable populations, who live in urban areas with high industrial air toxics. Sign the petition here.
And attend the hearing on May 18th: Public Hearing on Air Toxics Benchmark Rulemaking
For months, we have been asking people to care about the Air Toxics Benchmarks, specifically the new stricter standard being proposed for manganese. It would be pretty easy to accept that the state is addressing our concerns about industrial Air Toxics as they consider lowering the manganese benchmark to match the current California standard. Since last year when I stumbled on the report that showed 35 Portland schools, including my daughters', to be in some of the worst industrial toxic hot spots in the nation, I have been routinely directed to the Department of Environmental Quality's program: Portland Air Toxics Solutions (PATS). Last summer I became one of the over 30 members of the PATS Advisory Committee. It has been through this process, the first meeting in August 2009, and the 2nd just held in April 2010, that I have come to better understand the importance of the Air Toxics Benchmarks. And to realize it is incredibly important that citizens pay attention, especially those of us who are concerned about the high levels of these specific pollutants, like manganese, which we discovered through USA Today's national report on industrial pollution.
The Air Toxics Benchmarks will be the metric that the state agency uses to measure reductions in toxic air pollution.
The problem is, that these benchmarks are measured in terms of the annualized averages of the ambient levels detected (or most likely modeled) over the tri-county area.
And this new stricter manganese benchmark will not require any emissions reduction efforts for those facilities emitting the neurotoxin in the toxic hot spots in the city, Northwest and North Portland, where, according to DEQ data, manganese was both modeled and monitored at the highest levels in the tri-county area. And, most notably, 2008 fenceline monitoring data of the ESCO facility revealed that the manganese levels in the air emissions from the NW steel refinery were sometimes 300 times the benchmarks. At least that is what I infer from the comments by DEQ and ESCO staff who both assert that "we are already in attainment" of this new stricter benchmark.
That is why I drove the nearly 450 mile round trip to deliver the message to the Environmental Quality Commission in person at their meeting last week in Coos Bay. I showed up to address Agenda Item M, on the Air Toxics Benchmark Rulemaking, which was thankfully removed by DEQ Director Dick Pedersen to allow for more public input. Because, we need to insist that the EQC consider adopting dual standards to address not only the long term health risks, but the short term risks of high exposures experienced in the toxic hot spots, as well as the more protective levels that are needed to safeguard the most vulnerable to these high spikes, like our children. My concern is, without the qualification that these current ABC's do not address the risk of the most vulnerable to short term exposures, these benchmarks will be used as a false pretense of public health safety by the sources of these air toxics. In other words, major sources of manganese, lead and other types of toxic air pollution will go back to saying "we are doing no harm," even if the science says that there are no safe levels for children.
I urge everyone to sign the petition to ask the EQC to ensure that the Air Toxic Health Benchmarks protect children from short term and long term exposure to toxic pollutants present in the environment where they live, play and go to school. Click here to sign online. Let's deliver the message at the May 18th public hearing, or before the June 30th public comment period closes.