Sierra Club Delta Chapter Comments, SASOL Industrial Complex
Sierra Club Delta Chapter
P.O. Box 52503
Lafayette, Louisiana 70505
March 27, 2014
LDEQ Public Participation Group
P.O. Box 4313
Baton Rouge, LA 70821-4313
Re: AI Number 3271, Permit Number GTL and LCCP, Activity Number PER20130016 through PER20130031, and Water Permit Number LA 0003336 and Activity Number PER20130015
Sierra Club Delta Chapter submits the following comments regarding proposed air and water discharge permits for the SASOL North America Inc. Lake Charles Chemical Complex
Public Information Process
The public process is a sham. No real effort is being made to involve or inform the public as to the health, environmental or social consequences of the emplacement of such a huge industrial complex in the community. Only one public meeting is provided and no question and answer is allowed. The public is not allowed to ask questions of the permitting agency during the public hearing, but the permittee has unlimited access to Q&A with LDEQ throughout the permit application process.
The public is left to get their information from a long list of documents without clear instructions on how to access or interpret them. For example the public notice states physical locations for review of the documents and then states “The available information can also be accessed electronically on the Electronic Document Management System (EDMS) on the DEQ public website at www.deq.louisiana.gov.” The problem is that no reference numbers for the relevant documents are provided that correspond to search fields on the EDMS page.
Further down the public notice states “All correspondence should specify AI Number 3271, Permit Number GTL and LCCP, and Activity Number PER20130016 through PER20130031, and Water Permit Number LA0003336 and Activity Number PER20130015.” Here there is only one reference, the AI number that would help one to use available search fields in EDMS but the AI number accesses hundreds of documents, not selecting for the current proposed permit action.
The only effective way to search for relevant documents is through the DEQ public notice page that is listed further down in the information. Even for that option, no search criteria to the relevant documents are provided that match available search fields. This method of document search should be elevated to prominent status on the page with suggested search criteria included. All suggestions for use of EDMS should be removed from the public notice unless adequate information is provided to search within EDMS for documents relevant to the proposed permit.
More importantly, and especially for such a large permitting action, LDEQ should conduct a full public information and involvement process with meetings in both Baton Rouge and the affected communities. Information on the proposed permit action should be presented in graphical and understandable form, comparing proposed discharges with others in the state, region, and in other states. This so that persons of different education backgrounds can better understand how the project compares with other industrial installations and how it will affect them. Proposed air and water monitoring programs and public safety programs could be presented within the context of these meetings. It is apparent from the comments at the March 25 public meeting in Mossville that there is significant lack of trust in the permitting process. LDEQ should be proactive in attempting to gain public confidence.
Local area air Monitoring
LDEQ should conduct full time fenceline and community location air monitoring for PM10, PM2.5, SO2, NOx, CO, VOC and CO2e. LDEQ should be charging permit initiation and maintenance fees of the permittee that are sufficient to fund full time monitoring for these parameters with real time reporting to the public. Permittee and LDEQ reporting of other Toxic Air Pollutants listed in the public notice should be made available to the community on monthly basis. (as per comments by Dr. Wilma Subra, 3-25-2014).
Sufficient LDEQ staff should be maintained in the Lake Charles office to conduct frequent inspections of site operations and process monitoring equipment, and to respond to alerts from monitoring equipment or emergency situations. Fees from industrial permits should fund LDEQ expanded inspection and monitoring programs while allowing the programs complete discretion and independence from industry influence.
The proposed dumping of 10.66 million tons per year of Greenhouse Gases to the atmosphere is a huge addition to the rate of Louisiana’s GHG production. Most recently available data from USEPA (http://epa.gov/statelocalclimate/documents/pdf/CO2FFC_2011.pdf) shows 114.72 Million Metric Tons CO2 (MMTCO2)CO2 Emissions from Fossil Fuel Combustion in Louisiana’s industrial sector. Converting all tons to metric tons the proposed discharge represents an 8.4 percent increase from just one industrial location. The economics of the proposed installation are of a scale that SASOL should be required to reduce, eliminate or mitigate the discharge.
Language in the public notice after the TAP chart states “GTL and LCCP will result in significant net air emissions increases of the following pollutants: PM/PM10/PM2.5, SO2, NOx, CO, VOC, and greenhouse gases (GHG) regulated as carbon dioxide equivalents, or CO2e).” Yet LDEQ states “Neither the projects nor the general commercial, residential, industrial, or other growth associated with them is expected to have a significant adverse impact on soils, vegetation, visibility, or air quality in the vicinity of the facility or in any Class 1 area.”
Likewise, despite 16.84 million gallons per day proposed discharge of polluted wastewater LDEQ states “During preparation of this permit, it has been determined that the discharge will have no adverse impact on the existing uses of the receiving waterbody.
These statements are apparent contradictions that should be addressed by an analysis of aggregate effects of these very large proposed discharges (ie combined with existing air and water pollutants) on public health and the environment.
Sierra Club Delta Chapter is in support of, and acknowledges reference to, verbal and written technical comments presented by Dr. Wilma Subra representing LEAN, and verbal and written comments submitted by Michael Tritico, representing RESTORE at the March 25, 2014 public hearing.
We thank LDEQ for the opportunity to comment.
Haywood Martin, Chair
Sierra Club Delta Chapter