LEAN Comments on Sasol North America, Inc. Lake Charles Chemical Complex

On behalf of Louisiana Environmental Action Network and LEAN members living in the Calcasieu Parish area, the following comments are submitted.

Re:   Sasol  North America, Inc. Lake Charles Chemical Complex

14 Part 70 Air Operating Permits

2 PSD Permits

1 Water Discharge Permit

Environmental Assessment Statement

AI Number 3271

GTL and LCCP Air Permit Numbers and Activity Numbers PER 20130016 through PER20130031

Water Permit Number LA 0003336 and Activity Number PER20130015

Date:  March 25, 2014

     On behalf of Louisiana Environmental Action Network and LEAN members living in the Calcasieu Parish area, the following comments are submitted.

      The new proposed Sasol North America projects to be constructed in Mossville consist of a Gas to Liquid Project and a Ethane Cracker Project.  The application consist of 14 Part 70 Air Operating Permits, two PSD permits and a water discharge permit.  The foot print of the two projects is proposed to be located in part of the Mossville Community.

Environmental Justice Analysis

     Executive Order 12898 requires a government entity making permit decisions to determine if the proposed project will cause any significant adverse health/environmental impact on a minority or low-income population as compared to the general population.  On the determination of the presence of minority or low income populations, Sasol set forth the criteria of greater than 39.7 percent minority and greater than 18.1 percent low income (below the poverty level) populations in the state of Louisiana.

     The minority populations in the area of the proposed Sasol Gas to Liquid and Ethane Cracker projects consisted of 39.6 percent  minority population within four to five miles of the proposed projects. This is one tenth below  the Louisiana minority population figure of 39.7 percent.  However, the Calcasieu Parish minority population figure is 30.6 percent.  The minority population around the proposed projects exceeds the Calcasieu Parish minority population within one mile (31.9 %) and four  to five miles (39.6 %) of the proposed projects.

     The low income populations in the area of the proposed projects consist of 19.3 percent low income within one mile of the facility  projects, which exceeds the 18.1 percent state criteria level.  In addition, the Calcasieu Parish low income poverty level consist of 16.2 percent of the population.  The low income populations exceed the 16.2 percent Calcasieu Parish population level within one mile (19.3 %) and four to five miles (18.0 %) of the projects.

     Thus the minority populations exceed the Calcasieu Parish minority population level within one  mile and between four  and five miles of the proposed projects and the low income populations exceed the state low income population  within one mile and the Calcasieu Parish low income population within one mile  and between four and five miles of the proposed projects.

     Based on the demographics , Sasol should have moved to the next level of evaluations to determine if the minority and low income populations in the area of the projects would  be subject to adverse health/environmental impacts. Instead, Sasol concluded that the projects will not result in any significant adverse environmental impact and that there is no disparate adverse impact on a minority or economically underprivileged community.  Sasol thus determined no further analysis was required.

     Within one mile of Sasol there are 1,716 minority individuals, 1,438 African American individuals and  898 Individuals below the poverty level.        

     Sasol determined and presented in the Environmental Justice Analysis that:

-There are pockets of high-percentage minority census blocks around the proposed project site

-A high level of poverty surrounds the site, especially to the West.

     These are the populations that will be negatively impacted by the proposed Sasol Projects.

      The  La DEQ should require Sasol to move to the next  level of evaluations to determine if the minority and low income populations in the area of the projects would be subject to adverse health/environmental impacts. 

Community Outreach

     The Department of Environmental Quality permitting process is required to be open, fair and the information accessible to potentially impacted parties.  In the list of activities associated with interaction with the community, Sasol only listed a single meeting with Mossville Environmental Action Now (MEAN) on March 1, 2013.  That meeting was only a brief meeting with MEAN Board members and myself and additional meeting dates were established and cancelled by Sasol.  Even though a number of meeting were held between Sasol and MEAN  after that initial meeting,  the meetings were concerned  with relocation issues and not proposed project information.

Sasol’s Community Advisory Panel  (CAP)

     According to the information submitted by Sasol, the Community Advisory Panel meets bi-monthly with plant management.  The CAP provides a forum for Sasol to provide information to the community and for the community to share issues and concerns with Sasol management.

Issues raised at CAP meetings are taken seriously by Sasol.  Sasol is in the process of meeting with its CAP and members of the local community  to ensure that they are aware of Sasol’s interest in building the Gas to Liquid and Ethane  Cracker  projects. 

     After reviewing the most recent  list of CAP members with community members in Mossville, it was determined that two members of the CAP are from Mossville. The MEAN members and other Mossville community members were unaware that the two individuals were on the Sasol CAP.  The individuals who reviewed the list of CAP members were never involved in the process of these CAP members interacting with the community to provide information or collection of information and community concerns.  Thus the majority of Mossville  community members are not directly or indirectly involved in the issues of the Sasol  CAP.

Air Emissions

Air Emissions to be Released  From the Proposed Gas to Liquid and Ethane Cracker Projects

The release of Volatile Organic Compounds will  be greater than 3,000 tons per year, and green house gases greater than 10 million tons per year.   

Significant Increase in Net Emissions

     The Gas to Liquid and Ethane Cracker Projects will result in a significant net increase in emissions of :

Volatile Organic Compounds

Particulate Matter PM 10 and PM 2.5

Sulfur Dioxide (SO2)

Nitrogen Oxides (NOX)

Carbon Monoxide (CO)

Green House Gases (CO2E)

Exceeds the Prevention of Significant Deterioration Thresholds

     The Gas to Liquid and Ethane Cracker Projects will exceed the  prevention of significant deterioration thresholds for:

Volatile Organic Compounds

Particulate Matter PM 10 and PM 2.5

Sulfur Dioxide (SO2)

Nitrogen Oxides (NOX)

Carbon Monoxide (CO)

Dispersion Modeling

     The Sasol Gas to Liquid Project and the Ethane Cracker Project emissions will exceed the Prevention of Significant Deterioration (PSD) major modifications threshold levels.

     The exceedence of the PSD thresholds required Sasol to perform dispersion modeling to demonstrate that the projects will not cause or contribute to a violation of the National Ambient Air Quality Standards (NAAQS) or exceed the PSD increments.

     The preliminary screening modeling indicated the increases in emissions  of PM 10, PM 2.5, SO2, NOX, and CO exceeded the respective significant impact  levels.  As a result, refined modeling was required.

     The refined modeling demonstrated compliance with PM 10, PM 2.5, SO2, and CO NAAQS.  The ambient impact analysis for ozone was conducted based on the concentrations of NOX and VOCs in the emissions exceeding100 tons per year.  The peak impact of the combined emissions from the Sasol Project was predicted to be 0.4 ppb of ozone at the Carlyss monitor and a maximum of 0.6 ppb in the areas away from the monitor. These concentrations are within acceptable levels.

     Secondary PM 2.5 is formed primarily from reaction of sulfur dioxide emissions to form particulate sulfate and nitrogen oxide emissions to form particulate nitrates.  The NOX emissions dominate the emissions at a level of 1,595 tons per year while the sulfur dioxide emissions are 121 tons per year. 

     The combined primary and secondary PM 2.5 emissions do not cause or contribute to violations of the NAAQS or incremental PM 2.5 standard.

Summary of the Dispersion Modeling

     Based on the dispersion modeling, emissions from the proposed Sasol projects will not violate National Ambient Air Quality Standards for criteria pollutants and Louisiana Ambient Air Standards for Toxic Air Pollutants.

     The modeling of emissions from the new proposed Sasol projects, the existing Sasol facility units and the existing industrial sources in Lake Charles indicated the  new Sasol projects with the existing facilities will not violate NAAQS or the PSD increments.

     The modeling was performed on a chemical specific basis, the  cumulative impacts of all of the chemicals including a large number of Volatile Organic Compounds were not evaluated.

Facility Air Impacts

     Toxic chemicals are currently being detected in the ambient monitoring  stations in Westlake and Mossville and are associated with the health impacts experienced by community members.  Community members continue to suffer severe heath impacts as demonstrated by the heath survey and report  I prepared on the health conditions in the Mossville  community.  A copy of the health report is attached.  These chemicals currently detected in the ambient air, are some of the many chemicals that will be released into the air by the two proposed Sasol projects.  It is very difficult to comprehend how the additional  burden of the large quantity of emissions from this very large development by Sasol can be calculated to demonstrate the lack of impacts over acceptable levels.   

     The very large increase in air emissions from the new Sasol facility will have a negative impact on community members remaining in the area.  Even though Sasol has made attempts to offer relocation to community members closest to the proposed facility, there will be individuals remaining in the area of impact.

Best  Available Control  Technology (BACT)

     A Best Available Control Technology (BACT) analysis  is required to control regulated pollutants emitted from a new or modified major stationary source in excess of significant emission rates.  The Sasol projects emissions exceeded PM10, PM 2.5, SO2, NOX, CO, VOC and CO2e Green House Gases PSD Significant thresholds.

     BACT selection for the control of PM 10, PM 2.5, SO2, CO and  VOCs consisted of the use of gaseous fuels and good combustion practices.  NOX  BACT controls consisted of Ultra Low NOX Burners.

     The control of the more than 10 million tons per year of Green House Gases consisted of the use of natural gas as feedstock  and good combustion practices.  Sasol states that very few Green House Gas technologies have actually been demonstrated in practice and many are not commercially available.   So the use of good combustion practices is proposed to be used as the only method of controlling  Green House Gas emissions.  The use of natural gas as feed stock is not  a control technology for Green House Gases, it is the feed stock on which the Gas to Liquid Project is based. The LA DEQ needs to require as a part of the permit conditions, a clause that if technology is developed for the control of Green House Gases, the technology will be evaluated and required to be implemented by Sasol to reduce emissions of Green House Gases.

Ambient Air Modeling

     Currently there are two ambient air monitoring stations in the area of the proposed Sasol expansion projects.  These monitors consist of the Westlake monitor on John Stine Road which is operated by LA DEQ and the Mossville monitoring station on Old Spanish Trail operated by the Lake Area Industrial Alliance.  Sasol has  purchased the property on which the Mossville monitoring station is  located.  It is critical that the Mossville monitoring station continue to be operated at its present location and the data from the monitoring location be publicly available.

     These monitors are critical to tracking the quality of the air off site from the Sasol existing facility and proposed projects.  Sasol has stated that the wind blows from the south towards the Westlake monitoring  station two  times more frequently than it blows towards the Mossville monitoring station. 

     This evaluation of wind direction indicates that the Westlake community will be the most vulnerable and at risk to emissions from the new Sasol projects.  However, the Mossville community members who remain in the community will also be vulnerable and  at risk.

     Even with the Sasol Voluntary Property Purchase Program, Westlake, Mossville and Maplewood will remain in the vulnerable area of impact surrounding the  proposed Sasol projects.  There is a desperate need for the Louisiana Department of Environmental Quality to require as a  part of the permit conditions, the establishment and operation of a continuous air monitoring network around the entire Sasol complex.  The continuous monitoring network must be placed around the fence line of the entire facility to detect chemicals leaving the Sasol facility and within the communities of Westlake, Mossville and Maplewood to determine chemicals in the air of these communities.

     The continuous monitors in Mossville should be located in the area where the most individuals and the most vulnerable individuals continue to live in Mossville.

     The continuous monitor network must monitor for the criteria pollutants Sulfur Dioxide, Nitrogen Oxides, Carbon Monoxide,  PM 2.5 and  PM 10, and Green House Gases as well as speciated Volatile Organic Compounds.  In  addition the PM 2.5 and PM 10 particles must be required to be speciated for heavy metals and organic compounds.

     The continuous monitoring network  must be established to provide the communities with immediate alerts and notification when the concentrations of monitored chemicals reach levels of concern.  The trigger levels must consider the impacts on the most vulnerable populations.

     The continuous monitoring data must be publicly available in real time on a site that is easily accessible by community members and easy to interpret for the lay person.

     Once a month, Sasol should be required to issue, in electronic and hard copy format, a report on the monitoring results.  This monthly report must be required to be distributed to all individuals living, working and attending school within a three mile radius  of the expanded Sasol facility.

Accidental Releases and Upset Conditions

     When Sasol has an accidental release or upset condition, notification should be provided to the community and workers within a three mile radius at the same time notification is made to the Calcasieu  Parish Emergency Response Agency.  Follow up reports must also be provided to the community and workers in a three mile radius at the same time such reports are submitted to the Emergency Response Agency.

Particulate Matter

     A total of 611.12 tons per year of PM 10 and 740.33 tons per year of PM 2.5 will be released into the environment on an annual basis by the two Sasol projects.  The LA DEQ should require as a part of the permits conditions, a requirement that Sasol speciate the heavy metals and organic chemicals in the PM 2.5 and PM 10 particles released by each of the units releasing particulate matter from the new and modified units.   

     The chemical concentrations in the particulate matter are important because of the impacts to at risk populations with pre existing heart and lung disease and those of low social/economic status.

     The information from the analytical testing must be required to be made publicly available.

Toxicology Health Clinic

     Sasol presented information on  their ad valorem (property) taxes paid and the Calcasieu Parish entities that will benefit from the new ad valorem taxes they will pay on the two new  projects. One of 21 entities they listed in Calcasieu Parish as receiving resources from the ad valorem taxes was health clinics.  The community of Mossville has been desperate for  a toxicology health clinic to address their health impacts associated with their exposure to chemicals released by the industrial facilities in Calcasieu Parish.

     Sasol should consider providing financial contributions to facilitate the establishment of a toxicology health clinic to serve the citizens of the Mossville area who will continue to live in Mossville as well as those who locate out of the immediate area of the proposed Sasol Projects. 

LEAN appreciated the opportunity to comment on the proposed Sasol  Projects.  LEAN would like to request to be notified of the final decisions on the permits.

Wilma Subra

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