2.3700e-
003
6.4000e-
004
1.0000e-
005
1.5000e-
004
0.0000 1.6000e-
004
4.0000e-
005
0.0000 5.0000e-
005
0.0000 0.5916 0.5916 4.0000e-
005
0.0000 0.5925
Worker 4.1000e-
004
3.2000e-
004
3.6300e-
003
1.0000e-
005
1.0500e-
003
1.0000e-
005
1.0600e-
003
2.8000e-
004
1.0000e-
005
2.9000e-
004
0.0000 0.9494 0.9494 3.0000e-
005
0.0000 0.9501
Total 4.8000e-
004
2.6900e-
003
4.2700e-
003
2.0000e-
005
1.2000e-
003
1.0000e-
005
1.2200e-
003
3.2000e-
004
1.0000e-
005
3.4000e-
004
0.0000 1.5410 1.5410 7.0000e-
005
0.0000 1.5426
Mitigated Construction Off-Site
CalEEMod Version: CalEEMod.2016.3.2 Date: 6/22/2020 11:03 AM World Oil Tanks Installation - Los Angeles-South Coast County, Annual A-24
APPX_000370
World Oil Tank Installation Project
Construction - Architectural Coating VOC Emissions
Assumptions:
1) The coating types and VOC contents, coating thicknesses, area coated, coating volumes, thinners used, and work schedules are provided by the applicant 2) The interior of the tank is coated on the floor and up the sides 48 inches (4 feet) 3) The floating roof is not coated onsite.
4) The entire tank exterior, except the floating roof, is coated. 5) Each coating type is applied sequentially, so total schedule for coating task is 24 days.
VOC Emissions Estimate
Exterior Coating Product Sq.Ft./Tank Thickness Gallons Lb/Gal Total Lb's X 2 Tanks Days Avg/Lb/Day Field Primer Sherwin Williams 646-100 (3-5 mils) 2000 3-5 Mils 10 0.83 8.3 16.6 4.0 4.2 Intermediate Coat Sherwin Williams 646-100(4-6 mils) 13800 4-6 Mils 80 0.83 66.4 132.8 8.0 16.6 Finish Coat Sherloxane 800 (no thinner required) 13800 4 mils 40 0.77 30.8 61.6 8.0 7.7 Total (lbs) 211.0 20.0
Interior Coating Product Sq.Ft./Tank Thickness Gallons Lb/Gal Total Lb's X 2 Tanks Days Avg/Lb/Day Coating Duraplate UHS 4200 20-30 mils 85 0.83 70.6 141.1 4.0 35.3 Exempt Solvents Emissions Estimate
Exterior Coating Solvents Gals By Weight Density Lb/Gal Emissions Lbs 10 40% 8.8 35.0
60% 8.8 52.5
Gals By Weight Density Lb/Gal Emissions Lbs
20 100% 6.5 130.9
Components
Acetone
p-Chlorobenzotrifluoride
Acetone
R7K111 Thinner (for SW 646-100)
Cleaning Solvent
Components
Interior Coating Solvents
A-25
APPX_000371
World Oil Tank Installation Project
Operations Criteria Air Pollutant Emissions Summary
Proposed Project Emissions Increase NOx PM10 PM2.5 ROG CO SOx Onroad Emissions 1.21 0.09 0.03 0.04 0.18 0.00
New Tanks Fugitive Emissions1 -- -- -- 9.70 -- --
Loading Rack/Vapor Control 0.20 0.01 0.01 0.09 0.16 0.00 Total 1.41 0.10 0.04 9.83 0.34 0.00
1 - New tank emissions from SCAQMD permit engineering analysis.
Operations GHG Emissions Summary
Proposed Project Emissions Increase CO2e MT
Onroad Emissions 60.5
Loading Rack/Vapor Control 32.5
Indirect Electricity Emissions 5.9
Total 98.9
Annualized Emissions Increase CO2e MT
Construction Emissions From CalEEMod 270.5
Amortized Construction Emissions (30-years) 9.0
Incremental Operations Emissions Increase 98.9
Total Increase 108.0
Daily Emissions lbs/day
A-26
APPX_000372
World Oil Tank Installation Project
Operation - On-Road Emissions Increase
Assumptions
1) Emissions factors developed from CARB EMFAC2017 output. Paved road dust included using AP-42 and CalEEMod input defaults. 2) Heavy Duty Truck is the diesel fueled HHDT vehicle type meeting POLA/POLB's Clean Trucks Program designated as T7 POLA in EMFAC2017. 3) The additional maximum daily truck round trips caused by the project is 3 trips per day, a 10 percent increase from baseline per World Oil. 5) The distance for each additional round trip is 30 miles per World Oil. A single average trip distance is 15 miles. 6) There are no additional passenger or delivery class vehicle trips above baseline for the proposed Project.
NOx PM10 PM2.5 ROG CO SOx CO2e
Heavy Duty Truck 1.34E-02 9.66E-04 3.26E-04 4.83E-04 2.05E-03 3.68E-05 4.06 Vehicle Type NOx PM10 PM2.5 ROG CO SOx
Heavy Truck 90 1.209 0.087 0.029 0.043 0.184 0.003 60.5 4) While World Oil does not anticipate a long term increase in fuel trucking, it is conservatively assumed that the maximum daily increase in trucking occurs daily.
Incremental Increase
Emissions Factors lbs/mile
Daily VMT
Daily Emissions - Lbs GHG
MTCO2e/Yr
A-27
APPX_000373
World Oil Tank Installation Project
Operation - Loading Rack/Vapor Control Emissions
Assumptions
1) Emissions are a 10 percent increase from 2019 baseline for loading rack thermal oxidizer use and fugitive ROG 2) Baseline emissions are from the 2019 emissions inventory submitted to SCAQMD. 3) Annual thermal oxidizer natural gas fuel use is 6.0 million standard cubic feet (assume 1,020 Btu/scf to convert to MMBtu). 4) CO2e emissions factor for natural gas is from the Climate Registry is 53.17 Kg CO2e/MMBtu (includes CH4 and N2O). 5) To adjust annual emissions, operations are 7 days per week year-round.
Thermal Oxidizer Emissions
NOx PM10 PM2.5 ROG CO SOx
745.920 45.000 45.000 42.000 573.190 3.600 325
Project Increase Annual 74.59 4.50 4.50 4.20 57.32 0.36 32.54 Daily Increase 0.20 0.01 0.01 0.01 0.16 0.00
Fuel Oil Loading Rack Fugitive Emissions
ROG
277.540
Project Increase Annual 27.75
Daily Increase 0.08
2019 Baseline Annual
Daily Emissions - Lbs GHG
MTCO2e/Yr
2019 Baseline Annual
A-28
APPX_000374
APPX_000375
Appendix
B (Confidential)
Cultural Resources Records Search Report
APPX_000376
APPX_000377
Appendix C
Noise Calculations
APPX_000378
APPX_000379
APPENDIX C. World Oil Tank Installation Project Noise Calculations Construction Equipment
Lmax Ref
dBA
Useage Per
Hour Along Levee
Distance to
Resident
Equip
Leq(h)
Foundation Installation @ 50 ft (%) quantity feet dBA
Pile Driver (vibro pier mounted impact hammer/hoe ram) 90 20 1 2610 48.7 Crane 81 16 1 2610 38.7
Bobcat (backhoe) 78 40 1 2610 39.7
Total Quantity of Equipment: 3
Peak Unmitigated Composite Leq(h): 49.5
Line-of-Site/Intervening Structures Reduction (10dB): 39.5 Threshold:
LBMC District 1 50 dBA daytime - 5 (for tonal)=45 dBA OR increase by 5 dB to encompass ambient - 5 (for tonal) Project equipment per Application Item 21. Assume maximum of 3 pieces of equipment; worst-case vibro pier installation using mounted impact hammer/hoe ram.
Source:
Federal Transit Administration (FTA). 2006. Transit Noise and Vibration Impact Assessment. Final Report, May. [Online]:
http://www.fta.dot.gov/documents/FTA_Noise_and_Vibration_Manual.pdf. Accessed March 2012.
Assumptions: Containment structure, which breaks the line of site, would provide at least 5 dBA reduction in noise levels from the project site, plus additional 5 dB reduction from topography and intervening structures (tanks).
App C-Noise calcs-World Oil 051820.xls Page 1 of 1
APPX_000380
BEFORE THE LONG BEACH CITY COUNCIL
APPEAL OF LONG BEACH BOARD OF HARBOR
COMMISSIONER’S APPROVAL OF WORLD OIL TANK
INSTALLATION PROJECT (HD-21-537)
APPENDICES IN SUPPORT OF APPEAL
VOLUME 3 OF 3
Bates Nos. APPX_000381–APPX_000569
i
INDEX OF APPENDICES
Appx
No.
Description Vol No. Bates Nos.
1 Comments from Earthjustice, Center for Community
Action and Environmental Justice, San Pedro & Peninsula Homeowners Coalition, and Sierra Club – Angeles Chapter on World Oil Tank Installation Project
(October 27, 2021)
1 of 3 APPX_000001–
APPX_000005
2-1 Port of Long Beach Final Negative Declaration/Application Summary Report on World Oil Tank Installation
(September 2021), Part 1 of 2
1 of 3 APPX_000006–
APPX_000230
2-2 Port of Long Beach Final Negative Declaration/Application Summary Report on World Oil Tank Installation
(September 2021), Part 2 of 2
2 of 3 APPX_000231–
APPX_000380
3 Comments from Earthjustice, Communities for a Better
Environment, East Yard Communities for Environmental
Justice, Center for Biological Diversity, and Coalition for Clean Air on the Draft Initial Study and Negative
Declaration for the World Oil Tank Installation Project (November 11, 2020)
3 of 3 APPX_000381–
APPX_000567
4 Comments from California Coastal Commission on World Oil Tank Installation Project Final IS/ND
(October 26, 2021)
3 of 3 APPX_000568–
APPX_000569
APPENDIX 3
Comments on Draft IS/ND for World Oil Tank Installation Project November 11, 2020
1 VIA: ELECTRONIC MAIL ONLY ([email protected])
November 20, 2020
Matthew Arms
Director of Environmental Planning
Port of Long Beach
415 W. Ocean Blvd
Long Beach, California 90802
RE: Comments on the Draft Initial Study and Negative Declaration for the World Oil Tank Installation Project (SCH#2020100119)
Dear Mr. Arms:
The undersigned organizations provide comments on the Initial Study and proposed Negative Declaration (“IS/ND”) for the World Oil Tank Installation Project (“the Project”). Adequate review of the Project under the California Environmental Quality Act (“CEQA”) is crucial to understanding the environmental impacts this Project will have on local communities and climate change. The IS/ND prepared by the Port of Long Beach (“the Port”), however, fails to account for substantial evidence indicating the Project may have significant environmental effects. The IS/ND also reveals multiple significant procedural defects that violate established guidelines for CEQA review. For these reasons, in order to fulfill CEQA’s mandates and to permit a meaningful public review, the Port must prepare an Environmental Impact Report (“EIR”) for the Project.
The potential environmental impacts of the Project must be considered in the context of existing environmental burdens in the region. The adjacent Ports of Los Angeles and Long Beach are the largest fixed sources of pollution in the Greater Los Angeles region.
1 The communities surrounding the Port experience disproportionate
1 Taylor Thomas, Port of Long Beach Grant Program – A Lesson in Improving Funding for EJ Projects, in Environmental Justice Working Group Case Studies: Appendix To The Recommendations For The California State Lands Commission Environmental Justice Policy Update 9 (2018), https://www.slc.ca.gov/wp-content/uploads/2018/07/EJWG-Case-Studies-FINAL.pdf. (hereinafter “Appendix I”).
APPX_000381
2 exposure to pollution and severe cumulative health impacts.2 The welfare of these communities has historically been deprioritized in development projects at both ports.3 In this context, adequate CEQA review is critical to mitigate all foreseeable significant environmental impacts from the Project. We have attached substantial technical analysis and other evidence demonstrating that issuance of a negative declaration for the Project would be scientifically unsupported and in violation of CEQA.4 The Port must consider the evidence presented and respond to issues raised in this comment letter, including expert comments in Appendix A. We appreciate your consideration of these concerns.
I. THE IS/ND VIOLATES CEQA’S TIMING, CONSULTATION, AND
NOTIFICATION REQUIREMENTS
A. The Port Improperly Relies upon Permits to Construct Granted by SCAQMD Prior to the CEQA Review of the Project.
The Project’s IS/ND violates CEQA’s procedural requirements because it was prepared months after the Project received permits to construct from the Southcoast Air Quality Management District (“SCAQMD”), and it improperly relied upon those permits in its analysis of air quality impacts. The Port is required to follow all CEQA procedures, which courts will “scrupulously enforce” to ensure adequate environmental review.
5 Under CEQA, “every lead agency or responsible agency” must consider an EIR or negative declaration “[b]efore granting any approval of a project subject to CEQA.”6 As a responsible agency for this Project, SCAQMD did not wait for the Port to complete and adopt the IS/ND before providing its “approval” and issuing permits to construct for each of the Project’s tanks.7 The SCAQMD’s failure to comply with this procedural requirement constrained the Port’s environmental review, which undermines CEQA’s “basic purpose” to “[p]revent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures” that are feasible.8 Indeed, the “policy of
2 Id.
3 Id.
4 See generally Julia May, Communities for a Better Environment, Comments on the Draft Negative Declaration, World Oil Tank Installation Project (Nov. 20, 2020) (hereinafter “Appendix A”). 5 Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova, 40 Cal. 4th 412, 435 (2007), as modified (Apr. 18, 2007).
6 414 Cal. Code Regs. § 15004(a) [hereinafter CEQA Guidelines] (emphasis added). 7 CEQA Guidelines § 15381. (The term “responsible agency” includes “all public agencies other than the lead agency which have discretionary approval power over the project.”); CEQA Guidelines § 15352(b) (For “private projects, approval occurs upon the earliest commitment to issue… by the public agency of a… permit, license, certificate, or other entitlement for use of the project.”) (emphasis added).
8 CEQA Guidelines § 15063(a)(3).
APPX_000382
3 environmental review of feasible alternatives and mitigation measures makes practical sense only if that review occurs before an agency approves a project.”9 The SCAQMD issued permits to construct for the Project’s tanks on January 2, 2020.10 The Port, however, did not release the IS/ND for the Project for public review until October 7, 2020.11 Delays in conducting CEQA review allow for “more bureaucratic and financial momentum . . . behind a proposed project, thus providing a strong incentive to ignore environmental concerns that could be dealt with more easily at an early stage of the project.”12 CEQA review cannot take the form of “post hoc rationalizations to support action already taken.”13 Accordingly, the Port should have conducted its CEQA review “as early as feasible in the planning process to enable environmental considerations to influence project program and design and yet late enough to provide meaningful information for environmental assessment.”14 The SCAQMD should have then followed with its approval of permits to construct.
15 Premature approval and issuance of permits for a project by a responsible agency before CEQA review creates a strong incentive for a lead agency to dismiss key environmental concerns.
16 By issuing its permits before the Port completed the first stages of CEQA review, SCAQMD created an improper impetus for the Port to avoid any conclusions that would invalidate those permits. In fact, the Port relied upon SCAQMD’s pre-existing permits when evaluating the significance of the Project’s air quality impacts: “[T]he two new tanks would create additional fugitive VOC emissions from tank operations. The new tank VOC emissions were estimated by the Applicant… and
have been approved by the SCAQMD during their tank
permitting process (SCAQMD, 2019b).”17
CEQA review involves consideration of numerous potential impacts beyond air quality, and mitigation of those impacts may require project design changes not
9 POET, LLC v. State Air Res. Bd., 218 Cal. App. 4th 681, 717 (2013), as modified on denial of reh'g (Aug. 8, 2013) (emphasis added).
10 SCAQMD, Permit to Construct, Application No. 614274 at 1 (Jan. 2, 2020) (hereinafter “Appendix B”); SCAQMD Permit to Construct, Application No. 614275, at 1 (Jan.2, 2020) (hereinafter “Appendix C”.
11 IS/ND at 3.
12 Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal. 3d 376, 395 (1988), as modified on denial of reh'g (Jan. 26, 1989).
13 Save Tara v. City of W. Hollywood, 45 Cal. 4th 116, 130 (2008), as modified (Dec. 10, 2008). 14 CEQA Guidelines § 15004(b).
15 CEQA Guidelines § 15004(a) (“Before granting any approval of a project subject to CEQA, every lead agency or responsible agency shall consider a final EIR or negative declaration or another document authorized by these guidelines to be used in the place of an EIR or negative declaration.”). 16 Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal. 3d 376, 395 (1988), as modified on denial of reh'g (Jan. 26, 1989).
17 IS/ND at 4-9 (emphasis added). (The IS/ND also notes that “the new tank emission were required to be offset,” and that “SCAQMD has approved the transfer” of VOC credits for the Project.) APPX_000383
4 contemplated during SCAQMD’s permitting process.18 By producing the IS/ND months after SCAQMD’s permits were issued, and by relying on those pre-existing permits to evaluate the Project’s air impacts, the Port violated CEQA’s procedural requirements. Though the Port cannot require SCAQMD to withdraw improperly granted permits, the Port’s CEQA analysis should not draw upon premature approval of the Project by a responsible agency.
B. The IS/ND Fails to Establish whether the Port Consulted with all Responsible and Trustee Agencies Prior to Producing the IS/ND.
CEQA requires that “[p]rior to determining whether a negative declaration or environmental impact report is required for a project, the lead agency shall consult with all responsible agencies and trustee agencies” regarding the project.19 The consultation may be conducted “informally,” but must occur “[a]s soon as a lead agency has determined that an initial study will be required for the project.”20 The purpose of the consultation is to “obtain the recommendations of those agencies as to whether an EIR or a negative declaration should be prepared.”21 SCAQMD is a “responsible agency” for this Project under CEQA, because it has “approval power over the project.”22 The IS/ND provides no indication that the Port consulted with SCAQMD prior to determining a negative declaration is appropriate for the Project.23 Although the IS/ND cites to permits to construct issued by SCAQMD for the Project tanks, the permits themselves do not constitute “recommendations” by SCAQMD regarding “whether an EIR or negative declaration should be prepared” for the purposes of CEQA.24 Therefore, the IS/ND’s omission of any consultation with responsible agencies indicates the Port failed to consult with SCAQMD and seek its recommendations as required by CEQA.
Initial CEQA review of the Project also required the Port to consult with relevant trustee agencies. A “trustee agency” is “a state agency having jurisdiction by law over natural resources affected by a project which are held in trust for the
people of the State of California.”25 The California Department of Fish and Wildlife
18 Specifically, if the Port’s CEQA review required project changes to mitigate impacts, SCAQMD may be forced to re-evaluate the project design and determine again whether to approve construction permits for the tanks. See Residents Against Specific Plan 380 v. Cty. of Riverside, 9 Cal. App. 5th 941, 959 (2017) (It is a basic purpose of CEQA to “prevent significant, avoidable damage to the environment by requiring changes in projects through the use of alternatives or mitigation measures when the governmental agency finds the changes to be feasible.”). 19 Cal. Pub. Res. Code § 21080.3(a).
20 CEQA Guidelines § 15063(g).
21 Id.
22 CEQA Guidelines § 15381.
23 See, e.g., IS/ND at 6-1 (Summarizing parties involved and consulted in the preparation of the negative declaration and omitting responsible and trustee agency contacts from list). 24 CEQA Guidelines § 15063(g).
25 CEQA Guidelines § 15386.
APPX_000384
5 (“CDFW,” formerly the Department of Fish and Game), is specifically listed as one such trustee agency in CEQA Guidelines.26 CDFW is a trustee agency “with regard to the fish and wildlife or the state.”27 The Port was required to consult with CDFW, because the Project would affect the fish and wildlife of the State in several ways.
The IS/ND notes that “[t]he open water areas of the Port provide important nursery and foraging habitat for coastal marine fish and nesting and foraging habitat for many resident and migratory birds. The waterways in and around the Port also provide habitat for marine mammals, which are protected under the Marine Mammal Protection Act.”
28 The IS/ND also notes that “[s]pills of hazardous
materials could occur due to improper handling and/or storage practices during construction or operation activities could potentially cause soil or groundwater contamination, or contamination of the adjacent Channel 2.” 29 The Project would
also involve “[a]pproximately 50,000 bbl of water . . . used for the [facility’s] hydrotest,” which would be “discharge[d] into the harbor” after testing and dichlorination.
30 The IS/ND indicates potential Project impacts on birds, providing several measures to “prevent taking active bird nests during the nesting season.”31 The IS/ND claims that the Project will not have significant effects on wildlife resources. However, for the purposes of CEQA’s consultation requirement, “natural resources can be ‘affected by’ a project, and hence the lead agency may have duties toward ‘trustee agencies,’ even if the lead agency believes the project will have no significant effect on the environment.”
32 Because the Port admits a risk of
hazardous waste spills that could cause contamination to Port waters that provide “important nursery and foraging habitat” for fish and wildlife, and that measures may be needed to avoid the taking of bird nests, the Port was required to consult with CDFW.33 Specifically, CEQA Guidelines require the Port consult with CDFW and receive its recommendations before issuing a negative declaration or preparing an EIR.34
26 CEQA Guidelines § 15386(a).
27 Id.
28 IS/ND at 4-16.
29 Id. at 4-30, 4-31.
30 Id. at 4-34.
31 Id. at 5-5.
32 Gentry v. City of Murrieta, 36 Cal. App. 4th 1359, 1387 (1995), as modified on denial of reh'g (Aug. 17, 1995).
33 IS/ND at 4-30, 4-31, 5-5.
34 CEQA Guidelines § 15063(g).
APPX_000385
6 C. The IS/ND Fails to Establish that the Port Sent the Notice of Intent to Adopt to all Responsible and Trustee Agencies.
CEQA requires that the lead agency provide a notice of intent to adopt a negative declaration to all responsible agencies and trustee agencies “sufficiently prior to adoption” of the negative declaration with “the review period provided under Section 15015.”35 As noted in Section I.B., it is unclear whether the Port properly identified and consulted with all responsible and trustee agencies regarding the Project. The notice of intent to adopt and other documents provided to the public do not list the SCAQMD and CDFW, or any other responsible and trustee agencies, for service. Based on the information available, it appears these agencies did not receive legally sufficient notice of the Project’s IS/ND as required by CEQA.
As such, the Port must provide information confirming that all required agencies received adequate notice, and were granted sufficient opportunity to provide comments on the IS/ND.
II. THE IS/ND FAILS TO ANALYZE PROPERLY THE PROJECT’S AIR QUALITY
IMPACTS
A. The Estimates of Benzene and Other VOC Emissions in the IS/ND are Unreliable and do not Fully Reflect Potential Significant Air Emissions.
The IS/ND fails to fully account for Project VOC emissions because it uses the U.S. EPA TANKS model,36 which is known to grossly underestimate VOC emissions from storage tanks. According to a 2017 SCAQMD-sponsored study (the “FluxSense study”) on air emissions from petroleum refineries in the South Coast Air Basin, that model consistently underestimates VOC emissions from storage tanks at startling levels.
37 Excluding a partially shut-down refinery, the average VOC emissions were 8.6 times greater than estimated using the U.S. EPA TANKS model.38 The attached technical comments applied the findings of the FluxSense study, concluding that the Project’s VOC emissions are estimated at “83.4 lbs/day (9.7 x 8.6), which exceeds the District’s 75 lb./day threshold of significance, but which has the potential to go much higher.”39 Further, based on the greatest
35 CEQA Guidelines § 15072(a); CEQA Guidelines § 15105(b) (“The public review period for a proposed negative declaration or mitigated negative declaration shall be not less than 20 days. When a proposed negative declaration or mitigated negative declaration is submitted to the State Clearinghouse for review by state agencies, the public review period shall not be less than 30 days, unless a shorter period, not less than 20 days, is approved by the State Clearinghouse.”). 36 IS/ND at 4-9.
37 Johan Mellqvist, et al., FluxSense Inc., Emission Measurements of VOCs, NO2 and SO2 from the Refineries in the South Coast Air Basin Using Solar Occultation Flux and Other Optical Remote Sensing Methods 3 (Final Report Apr. 11, 2017), https://earthjustice.sharefile.com/d- s5312b425ff2c44f2a0c0415cd0f45d4a (hereinafter “Appendix E”). 38 Id.
39 Appendix A, Section II.D.
APPX_000386
7 underestimation observed in the FluxSense study, the Project’s “VOC emissions would be 116.4 lbs/day (9.7 x 12).”40 The Fluxsense study also found that cancer- inducing benzene emissions in particular are underestimated at extremely high rates: observed emissions were, on average, 34 times higher than estimates, and excluding the partially shut-down refinery, 71 times higher.41 Beyond the FluxSense study, “[s]ystematic underestimation of VOC emissions from the petroleum industry, such as large refineries, has been observed in various areas of the US and around the world during multiple measurement surveys.”42 For instance, a 2015 study from the Journal of Air & Waste Management found that underestimation levels could be even higher than reported in the FluxSense study, “up to 448 times greater than estimated at a floating roof tanks.”43 The proposed Project would also use floating roof tanks.44 There is substantial evidence from other recent studies and multiple experts demonstrating that the IS/ND’s methodology significantly underestimates the Project’s VOC emissions.45 On the basis of this evidence and the specific details of the Project, Communities for a Better Environment Senior Scientist Julia May concludes “[t]he Project clearly has the potential for significant VOC emissions.”46 The IS/ND relies upon flawed methodology for its assessment of VOC emissions, and is otherwise not “supported by substantial evidence in the record” as required by CEQA.47
B. The Analysis of Localized VOC Impacts is Flawed and Incomplete.
The IS/ND did not address properly the Project’s potentially significant impacts from VOC emissions on sensitive receptors near the Project site. The Port noted that there are no SCAQMD localized significance thresholds for VOC emissions, so the Port instead based its analysis on the SCAQMD daily VOC emissions threshold and SCAQMD’s “cancer health risk assessment.” 48 On the basis
of that threshold, the Port concluded that “operation emissions would not expose sensitive receptors to substantial pollutant concentrations.”49 The Port’s analysis of localized VOC risks is flawed for several reasons. First, a general, daily emissions threshold cannot substitute a localized emissions
40 Id.
41 Appendix A, Section II.A.
42 Appendix E at 3.
43 Appendix A, Section II.C.iv.
44 IS/ND at 4-7.
45 Appendix A, Section II.
46 Appendix A at 3.
47 CEQA Guidelines § 15091(b).
48 IS/ND at 4-12.
49 Id.
APPX_000387
8 threshold when evaluating localized impacts on nearby sensitive receptors; this is especially true in the context of multiple nearby sensitive receptors, including several elementary schools and parks located approximately half a mile of the Project site.50 Furthermore, SCAQMD’s cancer health risk assessment does not address any of the other significant health risks posed by VOC emissions, including through the formation of ground-level ozone.51 Finally, the Port’s estimates of the Project’s VOC emissions are based on an unreliable methodology, as discussed in Section II.A. These issues together create an unjustifiable risk that the Project’s VOC impacts on nearby sensitive receptors, including children at elementary schools, were not meaningfully addressed in the IS/ND.
C. The IS/ND Fails to Analyze Potentially Significant Impacts from Hydrogen Sulfide Emissions that are Cumulatively Significant in the Area.
The IS/ND completely fails to analyze Hydrogen Sulfide (“H2S”) emissions from the Project’s tanks, which have potentially significant environmental impacts.52 While the odor of H2S is “extremely strong and foul,” it can also cause adverse health effects, including headaches, nausea, vomiting, and eye irritation.53 SCAQMD has specifically identified H2S emissions as causing substantial impacts in the Port area.54 The IS/ND failed to provide any analysis of these impacts, despite key studies showing cumulative impacts of H2S in communities near refineries and other facilities.55 By ignoring the potential impacts of H2S emissions, the IS/ND fails to meet CEQA’s requirement to provide a “comprehensive cumulative impacts evaluation.”56
D. The IS/ND Fails to Account for the Full Increase of Foreseeable Truck Trips Required to Service the New Tanks and for Crude Balancing.
The IS/ND estimates that the Project will cause terminal truck trips to increase by 10 percent “to accommodate vendors not connected to the pipeline.”57 However, the IS/ND also states that “[p]eriodically, crude oil may be returned to the tanks by daily truck trips for refinery crude balancing.”58 Furthermore, the IS/ND
50 IS/ND at 4-43.
51 Junfeng (Jim) Zhang et al., Ozone Pollution: A Major Health Hazard Worldwide, Frontiers in Immunology, Oct. 31, 2019, at 1, https://doi.org/10.3389/fimmu.2019.02518 (VOCs react with nitrogen oxides “leading to ozone formation in the troposphere. . . Emerging evidence has shown that both short-term and long-term exposures to ozone, at concentrations below the current regulatory standards, were associated with increased mortality due to respiratory and cardiovascular diseases.”).
52 Appendix A, Section III.
53 CARB, Hydrogen Sulfide & Health, https://tinyurl.com/y4nlq8lh. 54 Appendix A, Section III.
55 Id.
56 Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184, 1214 (2004). 57 IS/ND at 2-8.
58 Id.
APPX_000388
9 does not account for truck trips to transport maintenance materials required by the Project’s tanks, and the waste materials those tanks would generate. It is unclear whether the Port considered all additional truck trips in its estimation of truck trip increases, and the IS/ND does not estimate how often trips for crude balancing would occur. Trucks serving the Port “often travel near and through local neighborhoods to reach their destinations” and “expos[e] residents to harmful air pollutants.”
59 Given the existing impacts of truck traffic in the region, the Port must consider the full foreseeable increase of truck trips the Project would cause.
E. The IS/ND Fails to Consider that Exposure to Air Pollution Increases Vulnerability to COVID-19.
The IS-ND completely fails to consider the link between air pollution from the Project’s construction and operation, including associated lifecycle emissions, and COVID-19. Studies published since the onset of the COVID-19 pandemic have found that exposure to higher amounts of air pollution also increases a population’s vulnerability to this coronavirus. A major study of air pollution and COVID-19 mortality in the U.S., for example, found that exposure to even a small increase in fine particulate matter (“PM2.5”) was linked to an 8% greater chance of dying from COVID-19.60
A second study in Europe found that populations exposed to higher levels of nitrogen dioxide experienced higher rates of mortality during the COVID-19 pandemic and concluded “long-term exposure to this pollutant may be one of the most important contributors to fatality caused by the COVID-19 virus in these regions and maybe across the whole world.”61
Additionally, a study in England found that higher levels of ozone, nitrogen oxide, and nitrogen dioxide are significantly associated with COVID-19 deaths.62 Similarly, a study in Italy concluded that air pollution should be considered an additional co-factor in the high level of COVID-19 mortality in Northern Italy, noting that people living in areas with high pollution levels are
59 SCAQMD, AB 617 Community Emissions Reduction Plan for Wilmington, Carson, West Long Beach 5d-1 (Final Draft, Sept. 2019), http://www.aqmd.gov/docs/default-source/Agendas/Governing- Board/2019/2019-sep6-025c.pdf?sfvrsn=6.
60 Xiao Wu et al., Exposure to air pollution and COVID-19 mortality in the United States, medRxiv (Apr. 5, 2020), https://doi.org/10.1101/2020.04.05.20054502; see also Lisa Friedman, New Research Links Air Pollution to Higher Coronavirus Death Rates, N.Y.Times (Apr. 17, 2020), https://www.nytimes.com/2020/04/07/climate/air-pollution-coronavirus-covid.html. 61 Yaron Ogen, Assessing Nitrogen Dioxide (NO2) Levels as a Contributing Factor to Coronavirus (COVID-19) Fatality, 726 Science of the Total Environment 138605 (July 15, 2020), https://doi.org/10.1016/j.scitotenv.2020.138605.
62 Marco Travaglio et al., Links Between Air Pollution and COVID-19 in England, medRxiv (Jun. 6, 2020), https://doi.org/10.1101/2020.04.16.20067405.
APPX_000389
10 more likely to develop chronic respiratory conditions and are more vulnerable to infective agents.63 Finally, two studies from China found that short-term exposure to higher concentrations of air pollutants—including particulate matter, nitrogen dioxide, carbon monoxide, and ozone—is associated with an increased risk of COVID-19 infection.
64 The Port must consider these recent studies that that present significant new information link COVID-19 to pollution sources common throughout all stages of oil and gas development and processing.
F. The IS/ND Fails to Consider Potentially Significant Emissions from Equipment and Processes to be Used in the Project’s Operation.
The IS/ND does not properly account for the Project’s emissions from pipeline pumps, pipeline cleaning, tank water draw, and tank flashing.
The IS/ND states that “a 25-horsepower pump would be installed for each tank to pump crude oil from existing lines to and from the new tanks,” but then fails to analyze the emission impacts from the operation of those pumps.65 The Port also acknowledges that the Project’s implementation would lead to pumping fuel oils at the terminal, which would generate a “minor amount of increased indirect GHG emissions.”66 Instead of evaluating these emission increases, the Port states “the amount of these increased emissions cannot be estimated as the future use of these two existing tanks is not known.”
67 The Port’s contradictory statements are
misleading—it cannot simultaneously assess that these emission increases are insignificant, while also stating the amount cannot be estimated. Even assuming the future activity of the Project’s existing tanks is unknown, fuel pump emissions are assumedly bound to some range according to factors, such as their energy efficiency, pipeline capacity, and the permit limits. The Port must provide an estimate of the emissions increase from the Project’s pipeline fuel pumps before attempting to characterize the Project’s air impacts as insignificant.
Additionally, the IS/ND does not consider emissions from cleaning the added terminal pipeline the Project would bring to the terminal. The tanks would each
63 Edoardo Conticini et al., Can Atmospheric Pollution Be Considered a Co-factor in Extremely High Level of SARS-CoV-2 Lethality in Northern Italy?, 261 Environmental Pollution 114465 (June 2020), https://doi.org/10.1016/j.envpol.2020.114465.
64 Huaiyu Tian et al., Risk of COVID-19 is Associated with Long-term Exposure to Air Pollution, medRxiv (Aug. 23, 2020) (unpublished), https://doi.org/10.1101/2020.04.21.20073700; Yongjian Zhu et al., Association Between Short-Term Exposure to Air Pollution and COVID-19 Infection: Evidence from China, 727 Science of the Total Environment (July 20, 2020), https://doi.org/10.1016/j.scitotenv.2020.138704.
65 IS/ND at 2-4.
66 Id. at 4-26.
67 Id.
APPX_000390
11 require approximately 40 linear feet of pipeline to connect them to existing pipelines at the terminal.68 Such pipelines are typically cleaned using a “pig,” a physical device that facilitates transferring and separating products across pipelines.
69 Cleaning pipelines with a “pig” can cause significant air emissions, especially of VOCs.70 The IS/ND fails to disclose or analyze whether the Project will use a “pig” or similar devices to maintain the additional pipelines, and whether significant emissions may be associated with those cleaning procedures.
Finally, the IS/ND does not address the VOC emissions associated with the necessary treatment of wastewater from dewatering the Project’s tanks. The Project would generate wastewater that would be “treated at the onsite wastewater treatment plant.”
71 Treating wastewater from a crude oil storage tank is a process that emits VOCs.72 The Port must account for those emissions and include them in consideration of the Project’s total emissions.
III. ANALYSIS OF THE PROJECT’S CUMULATIVE IMPACTS IS INCOMPLETE
AND INADEQUATE
A. The IS/ND’s Analysis of the Project’s Cumulative Impacts is Improper and Incomplete.
CEQA requires the lead agency to consider whether a project would have significant environmental effects based on its cumulative impacts.73 The analysis of cumulative impacts must consider the “incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.”74 CEQA stresses the importance of cumulative impacts in recognition that “the full environmental impact of a proposed project cannot be gauged in a vacuum.”75 Failure to properly address cumulative impacts would “effectively defeat CEQA’s mandate to review the actual effect of the projects upon the environment.”76
68 IS/ND at 2-6.
69 Phyllis Fox, Report on Bakersfield Crude Terminal Permits to Operate (Dec. 24, 2014) at 9-10 (hereinafter “Appendix F”).
70 Id. (“As the pig travels through the pipeline, residual vapors are pushed through the line. If the vapors are not routed to a control device, typically a flare or incinerator, they escape through openings on devices such as hatches, doors, or vents. Emissions can be significant, depending on the amount and vapor pressure of the product. Depending on the gas used to push the pig, the bleed-off step can also emit significant amounts of VOC.”).
71 IS/ND at 4-30.
72 Appendix F at 9-10.
73 CEQA Guidelines § 15064(h).
74 CEQA Guidelines § 15355(b).
75 Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184, 1215 (2004). 76 Id.
APPX_000391
12 The IS/ND states the Project’s impacts are not cumulatively considerable due to its “relatively nominal level and area of impact” and “temporary nature.”77 However, it is unclear how the Project’s impact could be accurately described as “nominal” or “temporary.” The Project involves not simply the construction of the storage tanks, but also includes their operation over many decades. The cumulative impacts analysis fails to consider the storage tanks’ estimated operation lifespan of “greater than 50 years.”78 Moreover, the Project’s tanks are expected to collectively generate approximately 15,000 barrels of tank sludge (a form of “hazardous waste”) and over 170,000 pounds of VOCs over their operational lifetime of 50 years or longer.
79 In light of these and other expected lifetime impacts, the Port cannot plausibly conclude that the Project’s impacts are too “nominal” or “temporary” to be cumulatively considerable.80
The Port also claims that the Project’s cumulative impacts are insignificant due to the Project’s “highly developed industrial surroundings.”81 This statement appears to imply that increased air, water, and other types of pollution, among other environmental impacts, are less harmful when pre-existing pollution levels are already high in the area. This approach contradicts the analysis required by CEQA Guidelines: the Port must consider the “incremental impact of the project when added to other closely related past, present, and reasonably foreseeable probable future projects.”82 In spite of that requirement, the IS/ND concludes that cumulative impacts of the Project and “other current projects in the region” would be “limited and minimized” because each of those individual projects are expected to comply with SCAQMD standards.83 CEQA Guidelines, however, explicitly envision that impacts may be “individually limited, but cumulatively considerable.”84 Indeed, “[o]ne of the most important environmental lessons that has been learned is that environmental damage often occurs incrementally from a variety of small sources.”
85 By failing to apply the relevant CEQA standards for assessing the Project’s cumulative impacts, the IS/ND failed to provide “a comprehensive cumulative impacts evaluation” as required by CEQA.
86 77 IS/ND at 4-65.
78 Id. at 2-9.
79 Id. at 2-9, 4-10, 4-61 (The IS/ND estimates that the Project’s would generate 1,500 barrels of sludge from cleaning each tank every 10 years and 9.81 pounds of VOC emissions each day. Each tanks’ lifespan is estimated to be greater than 50 years.). 80 Id. at 4-65.
81 Id.
82 CEQA Guidelines § 15355(b).
83 IS/ND at 4-65.
84 CEQA Guidelines § 15064(h)(1) (emphasis added).
85 Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184, 1214 (2004). 86 Id.
APPX_000392
13 B. The IS/ND Fails to Consider the Project’s Cumulative Impacts in the Context of World Oil Terminal Operations.
The Port is required to assess the Project’s cumulative impacts in the context of the “closely related past, present, and reasonably foreseeable probable future projects,” including the existing facilities at the World Oil Terminal.87 Whether projects are “closely related” depends on the similarity of the projects’ function and type of impact.88 The World Oil Terminal presently “contains seven existing petroleum tanks… [with] a total storage capacity of 502,000 bbl.”89 Four of those tanks are “leased to Marathon Petroleum and Glencore.”90 The Project proposes two additional tanks to be built at the World Oil Terminal, immediately adjacent to existing tanks, connected to the same pipelines as existing tanks, and providing additional “storage of crude oil and leasing of the existing tanks to third-party vendors.”
91 These vendors are Marathon Petroleum and Glencore – the entities already leasing storage at the World Oil Terminal.92 Viewing the terminal as a whole, the Port claims “the two new tanks would blend in with the existing seven tanks on-site.”93 The Port also describes operation of the Project’s tanks as “similar to existing operations.”94 As the Project tanks would simply add to the type of petroleum storage infrastructure that exists at the terminal, and these new tanks would serve a similar function to existing tanks, the Project is closely related to the operations of the terminal as a whole. The Port is therefore required under CEQA to consider the Project’s cumulative impacts in the context of existing terminal operations.
95 The IS/ND fails to consider adequately the “incremental impact of the project when added to” the closely related operations at World Oil Terminal.96 Although the Port claims that “[o]perational activities would not substantially change,” the IS/ND does not actually describe key impacts from operation of the terminal, which already provides 502,000 barrels of storage capacity.
97 For example, the cumulative
impacts analysis does not consider the terminal’s current hazardous waste generation, GHG emissions, or fugitive VOC emissions. Instead, the Port speculates
87 CEQA Guidelines § 15355(b).
88 Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184, 1215 (2004). (Finding that two shopping centers were closely related projects, because the shopping centers covered the same “shopper catchment area,” they provided similar services within a few miles of each other, and they created similar adverse environmental effects.). 89 IS/ND at 1.
90 Id. at 2-3.
91 Id. at 2-8.
92 Id. at 2-8.
93 Id. at 4-2.
94 Id. at 4-60.
95 CEQA Guidelines § 15355(b).
96 Id.
97 IS/ND at 2-3.
APPX_000393
14 that air quality impacts from “all current projects in the region” would be “limited” or “minimized” by virtue of complying with SCAQMD standards, but fails to provide any evidence or analysis relating to the terminal’s existing operations. 98 As noted in
Section III.A., CEQA Guidelines explicitly conceive that impacts may be “individually limited, but cumulatively considerable.”99 The IS/ND lacks key evidence and analysis of the Project’s cumulative impacts “when added to” operations at the World Oil Terminal, and the Port’s finding of no significant cumulative impact violates CEQA’s requirement that such findings “shall be supported by substantial evidence in the record.”
100
C. The IS/ND Fails to Consider Cumulative Impacts of Closely Related Refining Operations in the Region.
The Port is required to consider the Project’s cumulative impacts in the context of closely related projects, including “reasonably foreseeable probable future projects.”101 World Oil’s plan to lease the additional storage space created by proposed tanks is a fundamental goal of the Project as a whole. The tanks are explicitly planned to allow World Oil to lease additional terminal storage to specific “third party vendors” – the Marathon Petroleum Carson Refinery and the Glencore Long Beach and Carson Marine Terminals.102 The new tanks are also planned to “provide crude oil to the World Oil Refinery in South Gate.”103 As the Project is specifically intended to enable particular oil refining activities at these named facilities, those refining activities are “reasonably foreseeable” and “closely related” to the Project.104 Therefore, the refining activities specifically facilitated by the Project must be considered in the Port’s cumulative impacts analysis.
The IS/ND’s cumulative impact analysis does not consider any of the Project’s potential cumulative impacts in the context of closely related refining activities. Oil refineries generate multiple pollutants including numerous air emissions such as VOCs, particulate matter (“PM10” and “PM2.5”), nitrogen oxides, and sulfur oxides.105 Oil refineries are substantial contributors to the high air pollution burden in the region, and the impacts of closely related refineries should not be omitted from the “comprehensive cumulative impacts evaluation” that CEQA requires. 106
98 IS/ND at 4-65.
99 CEQA Guidelines § 15064(h)(1).
100 CEQA Guidelines § 15091(b).
101 CEQA Guidelines § 15355(b).
102 IS/ND at 2-1, 2-8.
103 Id. at 2-1.
104 CEQA Guidelines § 15355(b).
105 CalEPA & Office of EnvHealth Hazard Assessment, Analysis of Refinery Chemical Emissions and Health Effects 34 (Mar. 2019),
https://oehha.ca.gov/media/downloads/faqs/refinerychemicalsreport032019.pdf. 106 Bakersfield Citizens for Local Control v. City of Bakersfield, 124 Cal. App. 4th 1184, 1214 (2004).
APPX_000394
15 The IS/ND claims impacts from “all other current projects in the region” would be “limited and minimized,” but it is unclear whether “current projects” refers only to other storage tanks, or also includes petroleum refinery operations. The IS/ND’s conclusory and vague cumulative impacts analysis fails to inform the public and decisionmakers about impacts from closely related refinery activities and does not meet CEQA’s requirement to consider cumulative impacts “in connection with the effects of . . . probable future projects.”107
D. The IS/ND Fails to Consider the Cumulative Impacts from Hundreds of Other Similar Storage Tanks Projects Recently Approved in the Region.
The adjacent Ports of Los Angeles and Long Beach “are the single-largest fixed sources of pollution in the Greater Los Angeles region.”108 The ports are located in the community of Wilmington, Carson, and West Long Beach (collectively referred to as “WCWLB”).109 SCAQMD’s Community Steering Committee for WCWLB identified “emissions and leaks from refining process equipment and storage tanks” as one of “three main air quality priorities” that must be addressed to protect that community from harmful air pollution.110 The Committee also “identified the Ports [of Los Angeles and Long Beach] as an air quality priority.”111 Despite the severe environmental burden created by regional fossil fuel infrastructure, SCAQMD has permitted over 850 storage tanks in the last 10 years for oil refinery operations and related infrastructure.112 Over half of these storage tanks are for petrochemicals, and 86 tanks are specifically for crude oil storage.113 The Project’s proposed crude oil tanks would be an addition to the wave of recently- approved storage tanks in and adjacent to the Port, and is “closely related” to these other tank projects under CEQA.114
107 CEQA Guidelines § 15064(h)(1).
108 Appendix I at 9.
109 SCAQMD, AB 617 Community Emissions Reduction Plan for Wilmington, Carson, West Long Beach 5d-1 (Final Draft, Sept. 2019), http://www.aqmd.gov/docs/default-source/Agendas/Governing- Board/2019/2019-sep6-025c.pdf?sfvrsn=6.
110 Id. at 5b-3.
111 Id. at 5c-1.
112 Earthjustice, Spreadsheet Summary of SCAQMD-approved Storage Tanks (hereinafter “Appendix G”).
113 Id.
114 CEQA Guidelines § 15355(b).
APPX_000395
16 Figure A: Concentration of Storage Tanks around the Los Angeles/Long Beach Port Complex in the Los Angeles Basin115
The Port acknowledges the Project is located among “highly developed industrial surroundings,” but does not meaningfully consider cumulative impacts of other oil storage tank projects recently approved in the region.116 As stated in Section III.A., the Port’s mere insistence that all “current projects in the region” would “comply with applicable SCAQMD standards” falls short of the comprehensive cumulative impacts analysis required by CEQA. 117 In order to meet
CEQA’s requirements, the Port must consider the Project’s cumulative impacts in the context of the closely related storage tanks recently permitted in the same region.
IV. THE IS/ND’S ANALYSIS IGNORES THE PROJECT’S SIGNIFICANT
FORESEEABLE IMPACTS
A. The Project Description Fails to Include Foreseeable Oil Refining Operations.
The IS/ND fails to define properly the Project as required by CEQA, by excluding foreseeable impacts that contribute substantially to the scope and ultimate significance of the Project’s environmental harms. CEQA defines a “project” to include “the whole of an action, which has a potential for resulting in
115 Appendix E at 30.
116 IS/ND at 4-65.
117 Id.
APPX_000396
17 either a direct physical change in the environment, or a reasonably foreseeable indirect physical change in the environment.”118 CEQA defines “project” “extremely broadly.”119 This broad interpretation aims to “maximize protection of the environment.”120 A “curtailed or distorted project description may stultify the objectives of the reporting process.”121 CEQA analysis of a project must include any “future action” that is “a reasonably foreseeable consequence of the initial project… [and which] will be significant in that it will likely change the scope or nature of the initial project or its environmental effects.”
122 For an action to be “reasonably
foreseeable,” it is not necessary that a project applicant “formally decide[] precisely how they will use [the facility in question.]”123 Rather, it is sufficient that applicant “intend[s]” a future action and that action is described in CEQA review documents.
124
The IS/ND’s analysis of the Project’s impacts did not account for the impacts of oil refining activities that would occur as reasonably foreseeable consequences of the Project. The IS/ND states that the Project would provide “additional storage capacity of petroleum products for refining and distribution.”125 These tanks would increase the storage capacity at the World Oil terminal by 50,000 barrels – a 10 percent increase in the terminal’s already-substantial total capacity.126 This additional capacity is explicitly planned to allow World Oil to lease existing tanks at the terminal to several other refineries, including Marathon Petroleum Carson Refinery and the Glencore Long Beach Marine Terminal.
127 World Oil’s
unambiguous intention to lease the Project’s storage tanks to specific refineries demonstrates that refining activities are reasonably foreseeable future consequences that must be weighed in the Port’s CEQA analysis.128 The Project would allow existing tanks at the terminal to “ship and receive fuel oils” serving Marathon and Glencore facilities, and the new tanks are planned
118 CEQA Guidelines § 15378(a); see also id. at § 15003(h); Pub.Res. Code § 21065. 119 Pub. Res. Code § 21065; CEQA Guidelines § 15002(d); Azusa Land Reclamation Co. v. Main San Gabriel Basin Watermaster, 52 Cal. App. 4th 1165, 1188 (1997). 120 McQueen v. Board of Directors, 202 Cal.App.3d 1136, 1143 (1988). 121 Berkeley Keep Jets Over the Bay Comm. v. Bd. of Port Comm'rs, 91 Cal. App. 4th 1344, 1358 (2001), as modified on denial of reh'g (Sept. 26, 2001). 122 Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal. 3d 376, 396, as modified on denial of reh'g (Jan. 26, 1989) (The Court established this rule when reviewing the sufficiency of an EIR, but its decision was based on CEQA’s definition of ‘project’ given in CEQA Guidelines § 15378(a), which also applies to an Initial Study or Negative Declaration.). 123 Id. at 397 (Emphasis in original.).
124 Id.
125 IS/ND at 1-1.
126 Id. at 2-4.
127 Id. at 2-8.
128 Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal. 3d 376, 397, as modified on denial of reh'g (Jan. 26, 1989).
APPX_000397
18 to “provide crude oil to the World Oil Refinery in South Gate.”129 The IS/ND does not fully address impacts from “anticipated increase” in fuel oil throughput.130 The IS/ND states that the Project would simply “provide for more efficient terminal operations,” but fails to account properly for the fact that the Project would “increase fuel oil throughput” at the terminal.131 This increase in throughput would cause loading rack truck trips to “increase 10 percent during proposed project operations.”132 Given that World Oil explicitly plans to use the Project’s tanks to facilitate increased terminal fuel oil transport, the resulting refinery activities are reasonably foreseeable as a consequence of the Project. By failing to analyze the impacts of those reasonably foreseeable refining operations, the IS/ND violates CEQA’s requirement to provide a complete and accurate view of the whole project.
Moreover, the IS/ND repeatedly asserts without evidence that the Project would not “allow greater actual crude oil throughput.”133 The Port’s claim that the Project would not increase crude oil throughput appears to be contradicted by SCAQMD permits granted to the Project’s tanks. As noted, the Port claims that increased terminal capacity would not result in greater crude oil throughput “beyond the permitted limits.”134 However, it is unclear whether the Port is referring to currently permitted limits for World Oil’s existing facilities, or referring to the limits the terminal would have after construction of the new tanks. The SCAQMD permits for the Project’s new tanks specifically provide a maximum throughput of 75,000 barrels per month to each tank.135 Those permits suggest that the terminal’s total permitted throughput would increase substantially with the construction of the new tanks. The Port claims that the Project would not allow “allow greater actual crude oil throughput,” but the Project’s SCAQMD permits allow storage of “crude oil or non-gasoline petroleum products having a Reid vapor pressure not to exceed 10.0 pounds per square inch.”136 Thus, there is substantial evidence that the terminal’s permitted throughout would increase; if the Port asserts otherwise it must affirmatively show how, despite additional permitted capacity, the terminals’ permitted throughput would remain unchanged.
129 IS/ND at 2-1, 2-8.
130 Id. at 4-19.
131 Id. at 2-1, 4-9.
132 Id. at 2-8.
133 Id. at 4-26.
134 Id.
135 Appendix B at 1; Appendix C at 1.
136 IS/ND at 4-26 (emphasis added); SCAQMD Permits at 1 (emphasis added).
APPX_000398
19 B. The IS/ND Fails to Include Foreseeable Combustion of Distributed Oil Products.
CEQA requires the Port to assess the Project’s impacts under a broad enough scope “in order to maximize protection of the environment.”137 The IS/ND entirely fails to consider the environmental impacts of increased fossil fuel combustion that would result from this Project. The Project would allow World Oil to construct and lease additional crude oil storage “for refining and distribution” and would enable an increase in “fuel oil” transported to nearby refineries.138 The use of fuel oil or bunker fuel – one of the dirtiest fossil fuels – generates sulfur oxides and particulate matter that contribute to respiratory harm, heart problems, and premature deaths.139 By enabling increased distribution of fuel oils from the World Oil terminal, the burning of fuel oils is a “reasonably foreseeable consequence” of the Project that must be considered in the Port’s CEQA analysis.140 As described in Section V, the combustion of fossil fuels also necessarily contributes to the climate change crisis, and must fully considered by the Port.
V. THE IS/ND ANALYSIS OF GREENHOUSE GAS EMISSIONS IS
INADEQUATE AND INCOMPLETE
A. The IS/ND Fails to Consider Greenhouse Gas Emissions in the Context of California’s Emission Reduction Goals and the Crisis of Climate Change.
The IS/ND concludes that the Project would “conform to state and local GHG emissions/climate change regulations, policies, and strategies.”141 However, at a time when California policies reflect a need to urgently reduce greenhouse emissions, approving the Project would lead the Port in exactly the wrong direction by increasing greenhouse gas emissions (“GHGs”). As such, the Project directly conflicts with State and local efforts to reduce GHG emissions.
The need for deep and rapid greenhouse emission reductions grows more urgent with each passing day. The world faces a climate emergency with widespread and escalating harms, driven by fossil fuel production and use.142 The
137 McQueen v. Board of Directors, 202 Cal.App.3d 1136, 1143 (1988). 138 IS/ND at 1-1, 4-19.
139 Maria Gallucci, At Last, the Shipping Industry Begins Cleaning Up Its Dirty Fuels, YaleEnvironment360 (June 28, 2018), https://e360.yale.edu/features/at-last-the-shipping-industry- begins-cleaning-up-its-dirty-fuels.
140 Laurel Heights Improvement Assn. v. Regents of Univ. of California, 47 Cal. 3d 376, 396, as modified on denial of reh'g (Jan. 26, 1989).
141 IS/ND at 4-28.
142 Intergovernmental Panel on Climate Change, Climate Change 2014: Synthesis Report.
Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (Rajendra K. Pachauri & Leo Meyer, eds., 2015), https://www.ipcc.ch/report/ar5/syr/; U.S. Global Change Research Program, Climate Science Special Report: Fourth National Climate Assessment, Vol. I (2017), https://science2017.globalchange.gov/ ;
APPX_000399
20 landmark 2018 IPCC Special Report on Global Warming of 1.5°C provided overwhelming scientific evidence for the necessity of immediate, deep GHG reductions across all sectors and underscored the high costs of inaction or delays, particularly in the next crucial decade, in making these cuts. The IPCC emphasized that limiting warming to 1.5°C requires “rapid and far-reaching transitions” across all sectors, including energy.
143 At the global level, 1.5°C pathways require global
CO2 emissions to be cut by half by 2030 and to reach near zero by 2050,144 with steeper emissions reductions required in wealthier countries. The latest United Nations Emissions Gap report similarly found that global GHG emissions must drop by at least 7.6 percent per year through 2030, for a total reduction of 55% between 2020 and 2030, to keep warming below 1.5°C.
145
As the world’s fifth largest economy, California has both the ability and responsibility not just to meet but to exceed the average reductions necessary to respond to the climate emergency. To that end, California has strict mandates to rapidly reduce emissions. The Governor’s Executive Order B-30-15 and Assembly Bill 32 establish a GHG emissions reduction target for California of 40 percent below 1990 levels by 2030.
146 Executive Order S-3-05 calls for the State to reduce emissions levels by 80 percent below 1990 levels by 2050.147 Executive Order B-55- 18 calls for the State to achieve carbon neutrality by 2045.148 The IS-ND fails to contextualize the impact of the Project within the State regulatory landscape.
U.S. Global Change Research Program, Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment, Vol. II (2018), https://nca2018.globalchange.gov/. 143 IPCC, 2018: Summary for Policymakers, in Global Warming of 1.5°C. An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty 15 (Valérie Masson-Delmotte, et al., eds., 2018), https://www.ipcc.ch/sr15/.
144 Joeri Rogelj et al., 2018: Mitigation Pathways Compatible with 1.5°C in the Context of Sustainable Development, in Global Warming of 1.5°C, supra, 95, Figure 2.5, Figure 2.6 (2018), also at 2018: Summary for Policymakers, supra, at 12-14.
145 United Nations Environment Programme, Emissions Gap Report 2019, XV, XX, 26 (2019), https://www.unenvironment.org/resources/emissions-gap-report-2019. 146 Cal. Exec. Order No. B-30-15 (Apr. 29, 2015),
https://www.library.ca.gov/Content/pdf/GovernmentPublications/executive-order-proclamation/39-B- 30-15.pdf; Press Release, Office of Governor Edmund G. Brown, Governor Brown Establishes Most Ambitious Greenhouse Gas Reduction Target in North America (Apr. 29, 2015), https://www.ca.gov/archive/gov39/2015/04/29/news18938/index.html; Assem.Bill 32, 2005-2006 Reg.
Sess. (Cal. 2006),https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=200520060AB32. 147 Cal. Exec. Order No. S-3-05 (June 1, 2005),
https://www.library.ca.gov/Content/pdf/GovernmentPublications/executive-order-proclamation/5129- 5130.pdf.
148 Cal. Exec. Order No. B-55-18 (Sept. 10, 2018), https://www.ca.gov/archive/gov39/wp- content/uploads/2018/09/9.10.18-Executive-Order.pdf.
APPX_000400
21 Fossil fuels account for three quarters of all GHG pollution, and the world faces a tremendous over-production problem: producers currently plan to extract far more fossil fuels than the world can afford to burn.149 There is enough oil and gas in already developed fields and mines globally―that is, places where the infrastructure is built and the capital is invested―to far exceed the pollution budget for 1.5°C if these reserves were all produced and burned, even assuming no further fossil fuel extraction.150 This means that meeting global climate goals will require an immediate halt to the approval of new fossil fuel production and infrastructure and a phase-out of existing oil and gas fields before the reserves in existing fields are fully depleted.151 Importantly here, ending the approval of new fossil fuel infrastructure projects is critical for preventing “carbon lock-in,” where approvals and investments made now can lock in decades-worth of fossil fuel production and associated emissions that we cannot afford.152 The Project is therefore flatly inconsistent with meeting our climate goals or preserving a livable planet.
The IS/ND states that the Project will generate direct GHG emissions from construction and indirect GHG emissions during operation from electricity used to power the pipeline pumps.153 However, as noted in Section III.C., the IS/ND fails to analyze the potentially significant impacts of GHGs during all stages of oil development, including lifecycle and cumulative impacts.
The IS/ND failed to provide relevant information or context for the discussion of GHGs and the climate crisis, let alone adequately assess the extent to which the incremental GHG impacts of the Project are inconsistent with State climate change efforts. In particular, the IS/ND failed to show with substantial evidence that operational GHG emissions from the Project are consistent with AB 32 and other statewide GHG emissions reduction plans.
154 The Port has failed to meaningfully
149 Stockholm Environmental Institute et al., The Production Gap: The Discrepancy Between Countries’ Planned Fossil Fuel Production and Global Production Levels Consistent with Limiting Warming to 1.5°C or 2°C (2019), http://productiongap.org/2019report/.
150 Kelly Trout & Lorne Stockman, Oil Change International, Drilling Towards Disaster: Why U.S. Oil and Gas Expansion Is Incompatible with Climate Limits, Section I (Jan. 2019), http://priceofoil.org/2019/01/16/report-drilling-towards-disaster/ .
151 Id.; Christopher J. Smith et al., Current fossil fuel infrastructure does not yet commit us to 1.5°C warming, 10 Nature Communications 101, https://doi.org/10.1038/s41467-018-07999-w (2019); Dan Tong et al., Committed emissions from existing energy infrastructure jeopardize 1.5°C climate target, 572 Nature 373 (2019), https://doi.org/10.1038/s41586-019-1364-3.
152 Fergus Green & Richard Denniss, Cutting with both arms of the scissors: the economic and political case for restrictive supply-side climate policies, 150 Climatic Change 73, 78 (2018), https://doi.org/10.1007/s10584-018-2162-x.
153 IS/ND at 4-26.
154 Id.
APPX_000401
22 contextualize the Project’s operating emissions within the larger landscape of California’s GHG emissions reductions targets, in violation of CEQA.155 As discussed above, there is substantial evidence that the GHG impacts from the Project are significant in the context of statewide emissions goals.
B. The IS/ND Improperly Relies on SCAQMD’s Outdated Interim GHG Threshold for Significance.
A threshold of significance “does not relieve a lead agency of the obligation to consider substantial evidence indicating that the project’s environmental effects may still be significant.”156 When determining the significance of GHG emissions, “[t]he agency’s analysis also must reasonably reflect evolving scientific knowledge and state regulatory schemes.”157
That the Project’s annual operating GHG emissions fall under the SCAQMD’s significance thresholds does not obviate the need to assess the cumulative impacts of these emissions as compared to California’s climate goals.
The agency is required to consider, among other factors, “[t]he extent to which the project may increase or reduce greenhouse gas emissions as compared to the existing environmental setting.”
158 SCAQMD’s CEQA GHG Significance
Thresholds is outdated: the threshold was determined in 2008—over a decade ago.159 Since then, science has progressed—and determined that more emissions cuts than previously thought are needed to avert the worst climate catastrophes. As discussed above, the State has acted accordingly, enacting more stringent emissions targets.
That SCAQMD’s 2008 draft significance thresholds were ostensibly met does not obviate the Port’s duty to “independently review and analyze” the Project’s GHG impacts.160 The Port must exercise its independent judgment to determine whether the GHG impacts of the Project are significant. The agency cannot “simply rely on its settled . . . factors of significance in the face of substantial evidence [that] the
155 See, e.g., Golden Door Props., LLC v. Cty. Of San Diego, (2018) 27 Cal. App. 5th 892, 904 (The court found that the fact that a project would reduce GHG emissions by a greater percentage than required by the scoping plan in place at the time (31% to 29%) was insufficient evidence to show that the project was in fact compatible with statewide GHG emissions reductions plans. In that case, the agency’s failure to identify and implement any cognizable relationship between county- and state- wide reductions fell short of the substantial evidence standard required by CEQA.) 156 CEQA Guidelines § 15064(b)(2).
157 CEQA Guidelines § 15064.4(b).
158 CEQA Guidelines § 15064.4(b)(1).
159 SCAQMD, Interim CEQA GHG Significance Threshold for Stationary Sources, Rules, and Plans (2008) http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa- significance-thresholds/ghgboardsynopsis.pdf?sfvrsn=2.
160 Cal Pub Resources Code § 21082.1(c); see also CEQA Guidelines § 15074(b).
APPX_000402
23 project might have a significant impact on the environment.”161 Here, the Port impermissibly accepted at face value that operating GHG emissions that fall under SCAQMD’s significance thresholds will have no impact,162 despite substantial evidence to the contrary.163 Rather than accept outdated metrics that have been contradicted by substantial evidence, the Port must, “to the extent possible,” base its significance determination on “scientific and factual data.”164 Since 2008, California has adopted numerous GHG emissions reductions targets.165 The IS/ND must take into account this new information. The lead agency cannot adopt the quantitative threshold of another regulatory body without first “ensur[ing] that the quantitative project-level threshold [is] properly correlated to statewide targets.” 166
The Port has failed to do so here.
VI. THE IS/ND IMPROPERLY UNDERESTIMATES EARTHQUAKE AND
TSUNAMI RISK
A. The IS/ND’s Earthquake Risk Analysis is Inadequate and Improperly Postpones Full Evaluation of Earthquake Risks.
The IS/ND failed to provide substantial evidence that earthquakes would not pose a risk of significant environmental impact. The IS/ND admits that “the site is likely to experience strong to very strong ground shaking within its lifetime.”167 However, the Port asserts that “the final project design would be reviewed” in order to implement recommendations from a geotechnical investigation.168 However, future implementation of unspecified geotechnical recommendations does not constitute “substantial evidence in the record.”169 The IS/ND cannot rely upon a future geotechnical evaluation to presently conclude that no significant environmental impact may occur.170
161 John R. Lawson Rock & Oil, Inc. v. State Air Res. Bd., 20 Cal. App. 5th 77, 110 (2018). 162 IS/ND at 4-27.
163 See supra pp.19-21.
164 Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts, 3 Cal. 5th 497, 515 (2017) (citing 14 Cal. Code Regs. § 15064(b)) (finding that the Executive Order No. S-3-05’s 2050 goal of reducing California’s GHG emissions by 80 percent below 1990 levels provided important scientific and policy information regarding the pace and magnitude of GHG emissions reductions efforts that must be considered by the agency in determining the significance of GHG emissions). 165 See supra p.20.
166 Governor’s Office of Planning and Research, Discussion Draft: CEQA and Climate Change Advisory (Dec. 2018), https://opr.ca.gov/docs/20181228- Discussion_Draft_Climate_Change_Adivsory.pdf.
167 IS/ND at 4-22.
168 Id. (emphasis added).
169 CEQA Guidelines § 15091(b).
170 IS/ND at 5-5.
APPX_000403
24 Substantial evidence demonstrates that the Project’s storage tanks would be vulnerable to earthquakes, risking dangerous fires, spills, and explosions.171 The IS/ND improperly dismisses risks the Project would pose to people and the environment in the event of an earthquake. For example, the IS/ND fails to consider that “heavy black smoke [from a storage tank fire] can spread over residential areas for many miles,” or that a fire at the Project could spread and threaten areas “well beyond the Project location.”172 Appendix A provides numerous detailed examples of earthquake impacts to storage tanks, and notes the particularly earthquake heightened risk at the Project site created by the San Andreas fault.173 B. The IS/ND Fails to Properly Assess Potentially Significant Risks from Tsunamis.
The Port’s analysis of tsunami risks improperly relies on studies that were not adequately cited or included in the record and does not account for substantial evidence showing risks of significant environmental impacts from a tsunami.174 The IS/ND notes that “[d]ue to the project’s location adjacent to the ocean, the project site is vulnerable to tsunamis generated off the coast of California.” 175 Despite
recognizing this vulnerability, the Port’s analysis ignores key expert reports that find tsunamis pose considerable danger specifically to the Ports of Los Angeles and Long Beach.176 Recent expert studies find that the risk that tsunamis pose “considerably more danger to the ports . . . than previously thought.”177 The Port’s underestimation of risks posed by tsunamis resulted from a failure to consider substantial evidence demonstrating significant risks. The Port’s CEQA analysis and findings must adequately reflect those risks.
VII. THE PORT MUST PRODUCE AN ENVIRONMENTAL IMPACT REPORT
FOR THIS PROJECT TO COMPLY WITH CEQA
A lead agency can only issue a negative declaration if there is not even a “fair argument that the project will have a significant environmental effect.”178 An EIR is required if a project “may” have a significant effect on the environment “in light of the whole record before” the lead agency.
179 This standard applies “even though [the
lead agency] may also be presented with other substantial evidence that the project will not have a significant effect.”180 CEQA requires its provisions “to be read so as
171 Appendix A, Section V.B.
172 Id.
173 Id.
174 Appendix A, Section V.A.
175 IS/ND at 4-36.
176 Appendix A, Section V.A.
177 Id.
178 CEQA Guidelines § 15064(f)(1); No Oil, Inc. v. City of Los Angeles, 13 Cal.3d 68, 75 (1974). 179 CEQA Guidelines § 15064(a)(1) (emphasis added).
180 Id.
APPX_000404
25 to afford the fullest possible protection to the environment within the reasonable scope of the statutory language.”181 Further, CEQA Guidelines provide that “[i]f there is disagreement among expert opinion supported by facts over the significance of an effect on the environment, the Lead Agency shall treat the effect as significant and shall prepare an EIR.”182 Any doubts are resolved in favor of environmental review.”183
As detailed in these comments and based on the referenced substantial evidence, a “fair argument” can be made that the Project is likely to have a significant adverse effect on the environment. The Port’s finding of no possible significant impact from the Project ignores crucial, substantial evidence. Moreover, the Port committed serious procedural errors in violation of CEQA’s requirements that undermine meaningful public participation and informed decision-making. The Port must produce an EIR for the Project to comply with CEQA and to properly serve the Act’s fundamental purpose of ensuring adequate environmental assessment of projects with potentially significant environmental impacts. * * *
Sincerely,
Kartik Raj
Oscar Espino-Padron
Lisa Fuhrmann
Adrian Martinez
Earthjustice
Jennifer Ganata
Communities for a Better Environment
Lauren Packard
Center for Biological Diversity
Taylor Thomas
East Yard Communities for
Environmental Justice
Chris Chavez
Coalition for Clean Air
181 No Oil, Inc. v. City of Los Angeles, 13 Cal.3d 68, 83 (1974). 182 CEQA Guidelines § 15064(g) (emphasis added).
183 Pocket Protectors v. City of Sacramento, 124 Cal.App.4th 903, 928 (2004).
APPX_000405
26 APPENDIX
A. Julia May, Communities for a Better Environment, Comments on the Draft Negative Declaration, World Oil Tank Installation Project (Nov. 20, 2020) B. SCAQMD, Permit to Construct, Application No. 614274 (Jan. 2, 2020) C. SCAQMD, Permit to Construct, Application No. 614275 (Jan. 2, 2020) D. SCAQMD, Facility Permit to Operate, Facility ID No. 800080, Lunday-Thagard CO. DBA (World Oil Refinery) (Revision No. 87, Sept. 11, 2020) (Title V Permit), https://earthjustice.sharefile.com/d-s5312b425ff2c44f2a0c0415cd0f45d4a.
E. Johan Mellqvist, et al., FluxSense Inc., Emission Measurements of VOCs, NO2 and SO2 from the Refineries in the South Coast Air Basin Using Solar Occultation Flux and Other Optical Remote Sensing Methods 3 (Final Report
Apr. 11, 2017), https://earthjustice.sharefile.com/d-
s5312b425ff2c44f2a0c0415cd0f45d4a
F. Phyllis Fox, Report on Bakersfield Crude Terminal Permits to Operate (Dec. 24, 2014)
G. Earthjustice, Spreadsheet Summary of SCAQMD-approved Storage Tanks H. Bahram Fazeli, Communities for a Better Environment, Cumulative Impacts:
Changing Regulatory Culture to Address Environmental Injustice & Environmental Racism (Oct. 2009)
I. Taylor Thomas,
Port of Long Beach Grant Program – A Lesson in Improving Funding for EJ Projects, in Environmental Justice Working Group Case Studies:
Appendix To The Recommendations For The California State Lands Commission Environmental Justice Policy Update 9 (2018)
APPX_000406
APP
ENDIX A
APPX_000407
Appe
ndix A
C
omments of Julia May,
S
enior Scientist, CBE
On
the Dr
aft Negative Declaration,
W
orld Oil Tank Installation Project,
P
ort of Long Beach,
11/20/2020
C
ommunities for a Better Environment (
CBE)
He
adquarters, 6325 Pacific Blvd., Suite 300,
Huntingt
on Park, CA, 90255
jul
[email protected] -- ww
w.cbecal.org
APPX_000408
2 I. Introduction
and Summary
I
reviewed the Draft Ne
gative Declaration / Application Summary Report f
or the W
orld Oil Tank
I
nstallation Project, P
ort of Long Beach,1 [
the “World Oil Tank P
roject”
, “Nega
tive De
clar
ation”, “
ND”,
or
“the Project”]. I ha
ve a
lso reviewed the South Coast Air Quality M
anagement District’
s (AQMD’s)
Applica
tion Engineering Evaluation and Pe
rmit-to-C
onstruct doc
uments f
or the Pr
oject (
although the
ND
did not provide these).2
W
orld Oil proposes to construct two new 25,000 b
arrel (bbl) s
torage tanks f
or crude oil and other
“
non-ga
soline” petroleum products a
t the existing World Oil Terminal located at 1405 Pier C Street in L
ong Beach, California.3 I
concluded there are deficiencies in the Ne
gative Declaration, r
equiring
de
tailed e
nvironmental analysis
. In
summary, I c
oncluded:
• T
he Negative Declaration makes unsupported conclusions,
fails to include basic information
ne
cessary for public review, and leaves mitigation for later. • T
he Project has c
lear p
otential to cause significantly
increased h
azards, air an
d water
p
ollution,
and cu
mulative im
pacts.
o S
ignificant Air Impacts: P
roject ongoing
air e
missions a
re gr
eatly unde
restimated a
nd
ha
ve the potential to cause significantly increased Vola
tile Organic Compounds (VO
Cs),
be
nzene,
and other c
ontaminants. T
his was de
monstrated by multiple studies and many
e
xperts:
– T
he South Coast 2017 Fluxsense study directly measured VOCs (attributed t
o storage tanks) at
e
very r
efinery,
and found each refinery’s emissions
s
ubstantially underestimated, up t
o 12 times h
igher than t
he AQM
D e
mission
in
ventory. On
average thi
s was 8
.6 times higher (a
fter e
xcluding the low-end a
t a
pa
rtially shut down r
efinery)
. E
very single refinery including
tank farms wa
s
mea
sured at greatly higher emissions than the emission inventory. It found be
nzene up to 202 times higher, on average 71 times higher (a gain, e
xcluding the
pa
rtially shut refinery). (E
ven including the low outl
ier, VOCs on average were
6. 2 times higher and benzene 34 times higher.)
– T
he Fluxsense authors found that standard emission inventory factors (
inherent in t
he E
PA Tanks model) do n
ot ac
count for equipment
d
egradation over time. Us
ing the a
verage unde
restimation value of
8.6, P
roject
s
torage tank VO
C e
missions would be 83.
4 lbs/day. Using the highest
unde
restimation, they would be 116.4 lbs
/day.
The Project clearly has the
potential
for significant VOC emissions. Othe
r studies show emissions could be
f
ar higher
(448 times the calculated values). W
ith benzene 71 times higher, the
c
ancer risk is likely to be significant (although the ND fails to provide inf
ormation about what portion of the risk is attributable to benzene). S ince it
is
li
kely that be
nzene is
the largest part of the c
ancer risk a
nd since the
overall risk
1 P
repared for the Port of Long Beach, October 2020, available under Environmental Documents as World Oil Tank Ins
tallation at: ht
tps://www.polb.com/documents/#ceqa-ne
pa
2 S
CAQMD, Engineering a
nd Permitting Division, Application Evaluation and Calculations, Permit to Construct Evaluation, 8/
5/2019; and SCAQMD, Permit to Construct, Ribost Terminal LLC, DBA World Oil Terminals, Granted 1/2/2020 3 W
orld Oil Neg. Decl. p. 2-4
, available at: ht
tps://www.polb.com/documents/#ceqa-ne
pa
APPX_000409
3 would
only have to be 5.4 times higher to exceed 1 in a million, at 71 times higher
be
nzene, cancer risk likely exceeds this threshold, requiring additional risk a
ssessment according to
Rule 1401.
– Anot
her study in Texas similarly found 5-15
times the VOCs,
confirming t
he
ge
neral range of underestimation in
the South Coast. T
hat study found the
r
esults indicated these emissions s
ystematically and substantially unde
restimated
V
OC emissions.
– M
any experts have submitted comments or performed studies demonstrating t
he overarching large
u
nderestimation of petroleum storage tank VOC
e
missions
, including
Dr. Phyllis Fox (
environmental engineering
expert), D
r.
R
anajit (
Ron) S
ahu (e
nvironmental and energy e
xpert),
Dr. Jay Olaguer, Director
of
Air Quality Science at the Houston Advanced Research Center, a nd academics
Dr
. Da
niel Hoyt & Dr
. L
oren H. Raun publi
shing i
n the Journal of Air & Waste
M
anagement.
– T
he ND shou
ld have included an evaluation of cancer risk from diesel e
missions due to portable equipment s
uch as that used at the C
arson E
quilon
tank
farm, whic
h was determined to cause significant cancer risk.
This equipment
wa
s used dur
ing tank maintena
nce ope
rations a
nd described in
the recent AB2588
He
alth Risk Assessment.
o S
ignificant Air
Impacts,
and Hazards of Hydrogen Sulfide (H2S): T
he ND leaves out
ke
y H2S da
ta,
is inconsistent, a
nd make
s unsupported conclusions. I
t also r
epeats a
n e
rror
pr
eviously identif
ied by AQMD in othe
r tank pe
rmits. W
hen available s
tudies and data
a
re c
onsidered, a
nd because of the ubiquit
y of H2S pr
esence in crude oil and common
oc
currences of H2S r
eleases, the
Project ha
s the
potential for significant H2S
im
pacts a
t
mi
nimum causing nuisance odors,
and potentially causing health harms.
– AQM
D found H2S the most corrosive and toxic compound in crude oil. H2S is
very irritating at low levels, harmful to health at medium levels, causes death at high
levels, and is highly corrosive to equipment.
– AQM
D id
entified th
e Ports area as
the source of ongoing H2S odors f
rom
c
rude oil tankers (
which are basically floatin
g storage tanks),
but it
t
ook
ye
ars f
or AQMD t
o locate.
This demonstrates t
he difficulty of enforcing t
he
low H2S
i
mpact assumptions. T
here are no permit conditions identified for the
W
orld Oil Project to ensure adequate, or any monitoring of H2S to catch odor nuis
ances. T
he World Oil tanks
int
roduce new sources of H2S s
torage, a
dding to
potential odors
by itself, and to the cumulative ris
k.
– T
he ND p
rovides no information on H2S concentrations in
t
he tanks,
and
c
oncludes t
hat as
sociated releases an
d im
pacts would be in
significant,
r
epeating a previous permitting and environmental review error. S imilarly,
whe
n Tesoro crude oil s
torage tanks
were permitted by AQMD, in the absence of
H2S
data from Tesoro, AQ
MD at first a
ssumed H2
S in crude oil would be at a
low leve
l (5 ppm). When T
esoro’s da
ta became available ye
ars later, H2
S was
f
ound nine-ti
mes higher (45 ppm), requiring new permitting and environmental a
nalysis. Now
the
W
orld Oil ND
has taken this error one step further, by
not
APPX_000410
4 pr
oviding any a
ssumption about H2S c
oncentration a
t all, but still a
ssuming no
im
pacts. There
are no permit conditions set to limit H2S concentrations in the s
torage tanks to low level a
ssumptions. High
concentrations would be allowed
a
nd must be assumed. High H2S
content in
P
roject tanks
can be emitted to the air
dur
ing the Project life, with the
potential for significant impacts.
– T
he California Of
fice of Environmental Health Hazard Assessment
(OE
HHA), Air
Districts, a
nd Oil Industry literature id
entified crude
oil
s
torage tanks, pipelines, and transport as sources of H2S r eleases, health
im
pacts, and handling problems.
O
EHHA identified chronic he
alth ha
zards
ne
ar oil industry sources. T
he Bay Area Air Quality Management District and oil
indus
try literature identif
ied s
pecific e
mission points in f
loating
roof s
torage
tanks
. S
CAQMD identif
ied accident risks.
An oil
indus
try report found H2S
c
auses handling problems,
and the ability of H2S to flash out of liquid and
c
oncentrate at higher levels in vapor spaces, c
auses s
afety risks and corrosion.
– Hyd
rogen sulfide is well-k
nown as a corr
osion hazard, in
creasing the risk of
r
upture or leaks; a
t higher
concentrations it
was shown to r
educe s
torage tank
r
oof lifetime to a few years. M
itigation measures are available which could
r
educe H2S levels in storage tanks, significantly reducing impacts. o S
ignificant Tsunami Risks – T
here is a significant risk of increased and severe tsunami ha
zards due to the Project.
– T
he conclusion that this r
isk is les
s-than-s
ignificant (based on quoti
ng a
2007
por
ts study that was not produced) is contradicted by a 2010 ports study published by
the National Oceanic and Atmospheric Administration (NOAA), available onli
ne: “
Findings show that tsunamis generate
d along
far-fi
eld subduction zones
pos
e considerably more danger to the ports of Los Angeles and Long Beach than pr
eviously thought.”
– NO
AA found 11 different far-a
way sites can produce tsunamis traveling a long
dis
tance “s
ignificant to the ports of Los A
ngeles and Long Beach”. I
t found these
c
an trigger waves and currents exceeding 8 knots in the Ports of Long Beach and L
os Angeles, and concluded: “
Currents are particularly noteworthy since those
e
xceeding 8 knots (≈4 m/s) are known to break mooring line s and damage harbor
pier
s and other structures.”
– T
he Project location is within the Long Beach inundation zone. – T
his is sufficient to conclude there is a significant potential risk due to the Project a
s a result of tsunamis which could damage Project equipm ent. Damage can cause
oil
spills and fires, as shown in other evidence below.
o S
ignificant Earthquake Risks -- T
he Negative Declaration conclusion that hazards due
to
earthquake are less-than-s
ignificant is contradicted by many studies and is incorrect. – T
he ND is
internally inconsistent,
at one point stating uncertainly that “a
ground
impr
ovement system may r
educe the effects of
static and seismic settlements”
(e
mphasis added, p. 2-5)
. Elsewhere it states “A
lthough the site is likely to
e
xperience strong to v
ery strong ground shaking within its lifetime,
APPX_000411
5 implem
entation of the geotechnical investigation report’s recommendations in the fi
nal project design e
nsures that
impacts from ground shaking would be less than
s
ignificant.”
– T
he ND r
elies on f
uture evaluation,
but this mitigation discussed is not
id
entified as a requirement: “
The final project design would be reviewed by
A
lbus-K
eefe & Associates, as the design implements recommendations of the ge
otechnical investigation report (Matrix, 2019). .
. . M
itigation Measures: No
mi
tigation is required.” (
p. 4-22,
emphasis added)
– T
he ND in
cludes erroneous conclusions,
for example: “
The proposed project
w
ould not include habitable structures and would therefore not result in a change or
increase in the s
eismic hazard to people.” (
p. 4-22) T
his is incor
rect –
e
arthquake induce
d failures causing fires at petroleum storage tanks are a known ha
zard (and documented below). Fires can spread well beyond the Project loca
tion, and produce heavy black smoke known to have caused hazardous levels of
PM2.5 air pollution miles away, in
residential areas. (See for example Nustar
f
ire below, r
eporte
d by
public officials.)
– T
his Project significantly increases t
he potential for m
ajor h
azards due to
e
arthquake (
and due to other malfunctions), causing da
ngerous fires, explosions,
s
moke, and
spills listed below and supported by USGS and other predictions (by it
self and by further concentrating petroleum product storage and infrastructure).
M
y resume is attached, encompassing over three decades of environmental engineering assessment of
pe
tr
oleum f
acilities in
California, including
s
torage and distribution, refining, and extraction
ope
rations. This covered regulatory, permitting, CEQA, and other analysis of s ources, emissions, and
poll
ution prevention for normal operations. I ha
ve e
valuated numer
ous petroleum industry ups
ets, a
nd
major
accidents, explosions, and fires, e
xamining da
ta a
nd documents of r
egulatory a
gencies a
nd
indus
try.
I dir
ectly witnes
sed major
a
ccidents in person, and received numerous calls ove
r the years
f
rom ne
ighbors living next to such facilities,
who asked f
or he
lp a
nd information du
ring releases. I ha
ve
ope
rated sampling devices and Remote Optical Sensors during normal and upset conditions next to pe
trochemical facilities.
I
was appointed by
the LA County Board o
f S
upervisors to its Oil & Gas S
trike Team Advis
ory
C
ommittee, to advise on emissions, safety, c
hemical use, ha
zards, and mitigation options, regarding
s
ome of the
largest urban oil fields in
the
country,
serving dur
ing the las
t f
our ye
ars. The South Coast
Air
Quality Management District hired me as a technical consultant to s upport c
ommunity members
taking
part in the AQMD Refinery Pilot Project, to
provide a
technical report on oi
l r
efinery di
rect
e
missions c
ontrols a
vailable in
lieu of e
missions tr
ading in 2007.
Early in my engineering career, I was
a
n electrical engineer in Silicon Valley at National Semiconductor, before movi ng into
environmental
e
ngineering. I ha
ve a
lso pr
ovided expert testimony in qua
si-judi
cial proceedings of the California
P
ublic Utilities Commission on long
term electricity planning and z
ero emission opti
ons.
Outs
ide California I pr
ovided e
xpert tes
timony r
egarding oil refinery permitting for nationally-ba
sed
e
nvironmental organiz
ations,
including e
ngineering analysis f
or the
Natural Resources Defense Council
(
NRDC), the Environmental Integrity Project, and others, in Michigan, Illinois, Texas, Louisiana, North Da
kota (the MHA Nation), Oregon, and other parts of the country.
APPX_000412
6 II. Storage
Tank VOC, benzene,
and other emi
ssions estimates
are unreliable –
potential emissio
ns are much
higher and significant
A. C
rude Tank VOC and Benzene emission assumptions are unreliable, as demonstrated in the 2017
Fluxsense Study in
the South Coast Air District
W
orld Oil Project emi
ssions were estimated using the standard EPA Tanks Model 4.0 whic h AQMD
nor
mally uses a
s it did in
this case (ba
sed on the tank size, construction, contents, turnover rate, etc.).
Unf
ortunately, many e
xperts have concluded the model underestimates emissions substantially a nd
s
ystematically, e
specially given that equipment degrades over time. I
agree ba
sed on the multiple
s
tudies, numer
ous experts who have found the same problem,
and my personal experie
nce of petroleum
indus
try emission factor review within regulatory frameworks over decades. T he EPA Tanks modeli
ng
is
based on emissions factors which by their nature are meant to generalize emissions estimation, and whic
h are well-known
to vary in accura
cy.
T
he problem of gross underestimation of VOC and benzene emissions at refineries including the
tank
farms wa
s dir
ectly de
monstrated in the South Coast in the Fluxsense s
tudy performed by Swedish
s
cientists with AQ
MD.4 The unde
restimation was found at every single South Coast refinery. T he c
hart
be
low summarizes the underestimation, which s
howed results ranging f
rom 2.7 to 12 times higher
VO
Cs. Be
nzene r
anged f
rom 3.2 to
202 times higher. On
av
erage,
the study di
rectly mea
sured 6.2 times
the
VOCs and 34 times the benzene compared to the District inventory, f or e
very oil r
efinery in
the
S
outh Coast. Howe
ver, the
low-e
nd r
epresented unusual conditions at the T
orrance r
efinery, which h
ad
many
units closed due to an earlier explosion.5 Wit
hout these low-e
nd ou
tliers,
average VOCs would
b
e 8.6 times higher, benzene would be 71 times higher.
R
atio of measured emissions to
r
eported emissions (
p. 94)
H
ow much higher
w
ere VOCs?
H
ow much higher was
B
enzene?
R
efinery A - T
ESORO Carson
r
efinery (Tesoro LA)
6. 4 times 43
times
R
efinery B & C (Ph
illips 66 Carson
&
Wilmington r
espectively)
8. 3 to 12 times 33
to 202 times
R
efinery D – V
alero Wilmington 11
times 39
times
R
efinery E – C
hevron El Segundo 5.
4 times 38
times
R
efinery F – T
orrance Refinery 2.
7 times 3.
2 times
A
ll LA R
efineries Average 6.
2 times 34
times
(
Also note that the study did not include the Wilmington half of the Tesoro refinery.)
4 E
mission Measurements of VOCs, NO2 and SO2 from the Refineries in the South Coast Air Basin Using Solar Occultation F
lux and Other Optical Remote Sensing Methods, Fi
nal Report, FluxSense Inc, 11 April 2017, Authors: Johan Mellqvist, J
erker Samuelsson, Oscar Isoz, Samuel Brohede, Pontus Andersson, Marianne Ericsson, John Johansson 5 D
aily B
reeze, August 14, 2015, To
rrance leaders question ExxonMobil’s credibility on s
afety in wake of state accusations, [A
fter a major explosion shut
d
own the plant in Feb. 2015, the plant was partially reopened. This August 2015 article quoted AQMD: “Cu rrently, the company is producing less
t
han 20 percent of the 155,000 barrels a da
y the plant typically refined, AQMD spokesman Sam Atwood said.”] ht
tps://www.dailybreeze.com/2015/08/14/torrance-l
eaders-q
uestion-e
xxonmobils-c
redibility-on-s
afety-in-w
ake-of-s
tate-
a
ccusations/
APPX_000413
7 R
egarding these VOCs (
including be
nzene),
the study authors found:
I
n our experience, tank emissions contribute a
pproximately 2/3 of the total refinery [VOC]
e
missions (
Kihlman 2005). (at p. 94) . . .
R
efineries and tank farms are complex environments with a large number of installations and numer
ous potential emission sources (e.g. tank seals, valves, gauges, flare s, vapor recovery units,
e
tc.). M
any of these components can show degrading performance over time, and to ac
curately account for the impact of non-id
eal performance in emissions inventory
r
eporting is, we believe, an impossible task. p
. 95
.
. . In our expe
rience, the observed difference in fugitive VOC emissions between measured and inventor
y estimates is a general issue for the petroleum industry worldwide. We believe that a
p
ossible path forward could be to conduct monitoring in parallel with continued AP 42 b
ased reporting, and to use the measurements to guide and verify the efficiency of the e
mission reduction efforts at the industrial sites. p
. 96
.
. . The ORS [Optical Remote Sensing] techniques used in this study have demonstrated their a
bility to quickly
quantify and map refinery emissions and to identify potential air pollution s
ources within a facility. p. 96
I
n other words the Fluxsense s
tudy performed with AQMD found that although EPA’s AP 42 e
missions factors (inher
ent in the EPA T
ANKS m
odel) ha
ve their place, they cannot be relied on by
thems
elves,
and it
is v
ery li
kely that
emissions for pe
troleum storage tanks a
re in
general unde
restimated
by
EPA factors. T
he study found most of the VOCs come from tanks, and that t he e
missions
f
actors do not account for degradation over time. I
t a
lso f
ound a
dditional monitoring is needed to
ve
rify emissions be
yond idealized estimations f
or new tanks,
and that these are wor
ld-wide
problems.
B. A
similar study in Texas found the same results r
egarding s
ystematically and substantially
unde
restimated V
OC emissions
T
he same kind of s
tudy performed in the Houston-Ga
lveston Texas area a
nd published in
2013,6
li
kewise found greatly underestimated VOCs at petroleum r elated operations including tank farms. I
t
include
d a
dditional evaluation to determine if weather-r
elated impacts or ups
et conditions could account
f
or these higher emissions. The a
uthors c
oncluded those conditions only had a small impact on
e
missions relative to this large and across-the-boa
rd underestimation.
They f
ound that thi
s indicated
VOCs a
re systematically and s
ubstantially underestimated,
by a factor of 5 to 15:
A
mobile platform for flux measurements of VOCs (alkanes and alkenes), SO2, and
NO2 e
missions using the Solar Occultation Flux (SOF) method and mobile differential optical a
bsorption spectroscopy (DOAS) was used in four different studies to measure industrial e
missions. The studies were carried out in several large conglomerates of oil re fineries and
pe
trochemical industries in Southeast and East Texas in 2006, 2009, 2011, and 2012. . . .
The
r
esults were compared to annual inventory emissions, showing that measured VOC
6 J
ohansson, J. K. E., J. Mellqvist, J. Samuelsson, B. Offerl e, B. Lefer, B. Rappenglück, J. Flynn, and G. Yarwood (2014), E
mission measurements of alkenes, alkanes, SO2, and NO2 from stationary sources in Southeast Texas over a 5 year period us
ing SOF and mobile DOAS, J. Geophys. Res. Atmos., 119, 1973–1991 , doi:10.
1002/ 2013JD020485., available at:
ht
tps://agupubs.onlinelibrary.wiley.com/doi/full/10.1002/2013JD020485 APPX_000414
8 e
missions were typically 5–15
times higher .
. . Both meteorological
and upset effects were
s
mall compared to the factor of 5–15
, s
uggesting that VOC emissions are systematically and
s
ubstantially underestimated in current emission inventories.
C. M
any e
xperts agr
ee that oil
industry s
torage tank emissions ar
e unde
restimated in the s
tandard
E
PA TANKS modeling factor
s
i. P
hyllis Fox, Ph.D., P.E.
Dr
. Fox evaluated the significance of the FluxSense studies a nd implications for e
missions
e
stimation of pe
troleum s
torage tanks a
t other facilit
ies undergoing permitting,
including storage tanks.
He
r conclusions f
urther described thi
s VO
C unde
restimation problem in
the following example of her
wor
k (
this did not account for the closed Torrance refinery, which would make the average even higher if
excluded):7
T
he FluxSense c
omparison demonstrated that VOC emissions were underestimated by an a
verage factor of 6.2, ranging from 2.7 to 12 for the six facilities, compared to emissions r
eported to the SCAQMD. A factor of 6.2 means that the emission inventories underestimated VOC e
missions by a factor of 6.2 compared to measured VOC emissions. This is consistent with r
esults reported elsewhere for other facilities that also estimate their emissions using AP-42 and
other
similar methods. Johansson et al. (2014), for example, reporte d that, “De
spite some
s
ignificant variations from year to year and from area to area, there is a clear pattern of m
easured VOC emissions (alkanes, ethane, and propene) exceeding reported emissions wit
h almost an order of magnitude on average.”40 T
he majori
ty of the VOC emissions
or
iginate from the tanks.
ii. Dr
. Ranajit Sahu found
crude storage emissions 3-7
times higher than EPA Tank
s
e
stimates
Dr
. Sahu provided expert testimony to
the State of Washington r
egarding the proposed Tesoro
S
avage Vancouver crude oil
s
torage tanks,
which us
ed the
same EPA TANKS modeling.
He found t
his
modeling include
s errors, underestimates emissions, and that VOC estimates are problematic as a result.
He
found s
torage tank VOC s
ources are “the big ones”:8
So a
ll of these crude or crude-r
elated liquids that are produced or handled will have the c
apability to produce VOC emissions. So there are many different sources. The big ones are the tanks
, which I'm sure we'll talk about. (a
t p. 3594)
.
. . in
the air permi
tting activities, they have actually estimated some tank emissions. I take issue with
the accuracy of those estimates, and so that's an example of where they have done some c
alculations and I'm questioning the accuracy. (at p. 3596)
7 P
etition requesting that the Administrator object to the iss uance of the Proposed Title V Air Permit No. 2240-0045
2-V
0 i
ssued by the Louisiana Department of Environmental Quality to IGP Methanol, LLC for the Gulf Coast Methanol Complex i
n Plaquemines Parish, Louisiana, N
ov. 28, 2017, Sierra Club Petition including s
ummary of Dr. Fox comments,
ht
tps://www.epa.gov/sites/production/files/2018-01
/documents/sierraclubigpmethanoltitlevpetition2017.pdf
8 S
ahu Testimony, Hearing - V
ol. 15 In Re: Application 2013-01
Tesoro Savage Vancouver Energy Distribution Terminal,
BU
ELL REALTIME REPORTING, LLC 206 287 9066, excerpt i
n A
ttachment 2.
APPX_000415
9 He
estimated that stor
age tank emissions should be 3 to 7 times higher,
which is consistent with
F
luxsense results:
Q.
And what adjustments would you make, then, to the calculations for tank emissions and how would
that differ from the applicant?
A.
. . . M
y best e
ngineering estimate is it is a multiple of what they have estimated, s
omewhere around maybe three to seven times higher, based on what we know about tank e
missions and what we have learned about tank emissions in the last many years with more ac
curate inst
ruments and more accurate measurement methodologies. ( at p. 3598)
Dr
. Sahu explained pr
oblems wi
th the E
PA TANKS model, and s
tated E
PA has publicly
a
cknowledged these problems. (at pp. 3626 to 3628). The Sahu Transcript contains many pages of tes
timony de
monstrating his expert conclusion that VOC emissions are underestimated, particularly for s
torage tanks, that the EPA TANKS model is known to be unreliable, and that instead direct emissions mea
surement technologies show higher emissions. He a
lso discus
sed the
problem of underestimated
be
nzene in
VOCs (
for example at p. 3710). T
he proposed World Oil crude oil tanks represent
e
xactly the same use of EPA Tanks modeling.
iii. Dr
. Jay Olaguer, Director, A
ir Quality Science, H
ouston Advanced Research
C
enter, found e
mission factors unde
restimating oil
industry emissions is typical
Dr
Olaguer a
lso discussed the Fluxsense study, f
inding that
underestimation of emissions by the oil
indus
try was typical:9
“
That’s very typ
ical. People have done the same sort of [study] in other areas and invariably, it’s a
similar result,” said J
ay Olaguer, the director of air quality science at the Houston Advanced R
esearch Center, who was familiar with the AQMD study but not involved wit h it.
T
hat’s because currently, most refineries do not measure their emissions. Instead, they use an e
ngineering handbook to calculate what emissions from flares, tanks, pipelines, smokestacks and va
lves might be, and then report their best estimate to s tate and federal regulators.
“
It’s only somewhat better than a wild-a
ss guess, but it’s basically a wild-a
ss guess,” said
Ola
guer, who has authored a book on air emissions from the oil and gas industry. The c
alculations do not capture things like unexpecte
d days of flaring, releases of hydrocarbons or
lea
ks, he said.
i
v. Danie
l Hoyt & Loren H. Raun de
monstrated in A
ir & Waste Management J
ournal
that
me
asured floating roof tank V
OCs w
ere 448
times higher than estimated
Anothe
r study published in 2015 in the Journal of Air & Waste Management found similar results.
M
easured and estimated benzene and volatile organic carbon ( VOC) emissions at a major U.S.
9 S
outhern California Public Radio, December 29, 2016, LA-a rea refinerie
s emit up to 12 times more toxic chemicals than
r
eported, h
ttp://www.scpr.org/news/2016/12/29/67663/la-a
rea-r
efineries-e
mit-up-to-12-t
imes-m
ore-t
oxic/
APPX_000416
10 r
efinery/chemical plant: Comparison and prioritization f ound that e
missions factors provided
u
nreliable results, causing c
onsistent u
nderestimation of emissions, particularly at storage tanks:10 T
he most commonly used method, based on emission factors, result s in unreliable estimates. . .
T
o address this need, benzene and volatile organic compound (VOC) emissions within a major c
hemical plant/refinery were measured and compared with emission factor estimates. T he results
of
this study indicate estimated emi
ssions were never higher and commonly lower than the
mea
sured emissions. At one source location, VOC emissions we re found to be largely
r
epresentative of those measured (i.e., the catalytic reformer), but m ore often, emissions were
s
ignificantly underestim
ated (
e.g., up to 448 times greater than estimated at a floating roof t
ank). T
he sources with both the largest relative error between the estimate and the m
easurement and the largest magnitude of emissions in this study were a wastewater
tr
eatment process
, an aromatics concentration unit and benzene extraction unit process area, an d
t
wo sets of tanks . . .
D. Thes
e studies and evaluations are more than enough to conclude the P otential to Emit VOCs and
toxics
from P
roject tanks is
far
higher
than N
egative Declaration e
stimation, and
Significant.
Us
ing the
Fluxsense study r
esult average unde
restimation (
without the Torrance outlier data point),
the
VOC emissions from the new storage tanks wo
uld be 8.6
times higher, and the benzene emissions
would
be 71 t
imes higher than estimated – r
esulting in 83
.4 lbs
/day (9.
711 x 8
.6),
which exceeds the
Dis
trict’s 75
lb./day thr
eshold of significance,
but which has the potential to go much higher. I
f the
uppe
r end of the Fluxsense study was used (12 times higher), the Project VOC emissions would be 116.
4 lbs/day (9.7 x 12). T
here is even a far higher potential (hundreds of times higher), as shown a
bove. The assumption that the Project will start at
and continue at the EPA Tanks estimate is
de
monstrably incorrect. T
he Project requires additional analysis and mitigation to address these e
missions, including monitoring and control measures.
B
enzene emissions (which are VOCs) and other BTEX compounds ( Benzene, Toluene,
E
thylbenzene, and Xylene) would also be increased, potentially by 71 ti mes higher
compared to that
e
stimated using EPA TANKS modeling
, and should be evaluated at this higher potential to emit. T he
AQ
MD Engineering Evaluation for the Permit identifies Benzene at 34.88 lbs/year, which would rise to 2,
486 lbs/year. C
ancer risk should be re-c
alculated using health-pr
otective conservative assumptions
including
the higher
potential be
nzene emissions i
ndicated by the Fluxsense studies.
S
ince the HRA results in the AQ
MD E
ngineering Evaluation show residential risk for all toxics at
1. 85E-7 (o
r 0 .185 pe
r mi
llion, pa
ge 2), the risk would have to rise by a factor jus
t over 5
.4 to go over 1
in
a million
(0
.185 per million x 5.4 = 1 per million). The
permit identifies thi
s threshold unde
r Rule
1401
a
s requiring a
cancer risk analysis a
t p.
4).
The portion of the risk attributed to benzene is not
pr
ovided, but it probably drives the cancer risk, and at
71 times higher-leve
ls of benzene, the overall
10 Me
asured and estimated benzene and volatile organic carbon (VOC) emissions at a major U.S. refinery/che mical plant:
Com
parison and prioritization, D
aniel Hoyt & Loren H. Raun, Journal of Air & Waste Management, V olume 65, 2015
– Is
sue 8, pp. 1020-1031
, Published online: 11 Jun 2015, available at:
ht
tp://www.tandfonline.com/doi/full/10.1080/10962247.2015.1058304 11 N
egative Declaration, Table 4.3-2.
Summary of Maximum Daily Operation Emissions Increase Estimates (Pounds P er
D
ay), Fugitive VOC Emissions, at p. 4-10
APPX_000417
11 c
ancer risk is likely to go up by far more than 5.4, resulting in a significant cancer risk (over 1 in a mi
llion). The ND does not provide this kind of detail – a full analysis is necessary.
E. T
he ND should als
o evaluate known significant cancer risk due to portable diesel equipment
T
he ND should have included an evaluation of cancer risk from diesel emissions due to portable e
quipment such as that used at the Carson Equilon tank farm, which was determined to cause significant c
ancer risk in
the recent AB2588 Health Risk Assessment (HR
A).12 T
his equipment was used during
tank
maintenance operations.
The HRA found:“
Cancer risk at each of these receptors was primarily
due
to exposure to diesel particulate matter (DPM) and PAHs from contractor-ope rated portable diesel
e
ngines and to a less
er extent benzene from storage tanks and pipeline component fugitive emissions.” (
p. 5) a
nd “
In 2015, contractors operated numerous gasoline and diesel engines to assist in performing maintenanc
e tasks onsite, such as tank degassing and coating/painting of tanks and piping.”(p.
9)
III. Crude tank
H2S Project impacts
are missing and potentially
significant
A. T
he ND leaves out key H2S data,
is inconsistent, makes unsupported conclusions, and repeats an e
rror identified by AQMD in another storage tank pe
rmitting process
‣ T
he Negative Declaration n
ever mentioned on
e of the most impactful chemicals present in
c
rude oil - h
ydrogen sulfide (H2S).
This hazardous chemical is
irr
itating a
t low levels, harmf
ul
at
medium levels, c
auses d
eath a
t high levels, an
d is h
ighly c
orrosive to equipment.
T
he ND is internally inconsistent in identif
ying the potential for objectional odors, but then
f
inding
im
pacts les
s than s
ignificant. I
t mentions “ther
e is the potential for individuals to find s
uch odors as
objec
tionable” but
concludes unc
ertainly wi
thout basis “
given the distance between project emission
s
ources and the nearest sensitive receptors (i.e., approximately 800 meters), ade quate dispersion of
thes
e odorous emissions to below objectionable
levels would be an
ticipated”. (
emphasis added p. 4-13)
T
his is insufficient to conclude that there is no possibility of a significant impact. I n fact, the
identif
ication of objectional odors is by definition a public nuisance, whic h is it
self a significant impact.
I
n addition, studies and data be
low provide overwhelming evidence that H2S odor
problems a
nd dangers
ne
ar petroleum operations are c
ommon a
nd present health risks a
nd equipment hazards, in
addition to
publi
c nuis
ances. T
his P
roject incr
eases the potential for significant H2S
im
pacts de
scribed below.
F
urthermore, this Project ha
s no
pe
rmit li
mit on percentage of H2S allowed to be present within the c
rude oil.
‣ T
he ND repeats b
ut m
akes wor
se a h
istory of underestimation and missing analysis on H2S
in
crude oil storage tank p
ermitting t
hat was
al
ready identified as
problematic by AQMD.
I
n another crude oil storage tank permit process, AQ
MD s
taff r
ealized H2S concentrations in
crude
oil
could be
present at 9
times higher than pr
eviously a
ssumed for ne
w T
esoro c
rude oil storage tanks13
(
now owned by Marathon). In
the absence of c
rude oil da
ta f
rom T
esoro,
AQMD assumed H2S leve
ls
12 E
quilon E
nterprises, LLC, 2015 H
RA & A
pproval L
etter (6
/5/2020), http://www.aqmd.gov/home/rules-
c
ompliance/compliance/toxic-hot-s
pots-ab-258
8/health-r
isk-a
ssessment]
13 T
esoro Los Angeles Refinery Integration a
nd Compliance Project
APPX_000418
12 would
be low,
and included this assumption in the T
esoro E
nvironmental Impact report (
EIR). B
ut aft
er
AQ
MD r
eceived data more than two years later, th
e permit ha
d to be corrected, a
nd a
n Addendum to
the
E
IR wa
s published to
analyze impacts of increased H2S.14 T
he World
Oil Tank Project ND
is
repeating
thi
s error in
a more extreme form – not e
ven identi
fying H2S concentration in crude oil as an
e
nvironmental issue, and concluding without evidence that impacts are not significant. Now that AQ
MD
ha
s identified this problem, the World Oil Project evaluation must not repeat the error. An assessment of the
potential maximum H2S concentrations in crude
oil is
needed.
(F
urthermore, M
arathon (
previously
T
esoro),
leases tanks
at the W
orld Oil Projec
t loca
tion. (
ND, p. 2-3))
B. The
re is w
idely av
ailable data
and studies regarding the importance of H2S, storage tanks, and impac
ts, de
monstrating the
Project has
a potential for significant impacts
‣ AQM
D has found in other CEQA documents that “
Hydrogen sulfide is the most corrosive and
toxi
c c
ompound found in crude oil.” 15
H2S
is a neurotoxin, extremely odorous at low levels, and causing highly irritating episodes in c
ommunities surrounding oil refineries, crude oil storage, oil tankers, and oil drilling. H2S can cause he
adaches, nausea, eye inf
lammation, and more.16 I
t re
gularly kills workers across the country
(
including 20 deaths or severe exposures in indus
trial accidents f
rom 2016 to 2019 according to the
Oc
cupational Safety and Health Administration (OSHA)).17 The OSHA da
ta il
lustrates the seriousness
of
exposure to high
levels of H2S,
and the relatively common occurrence of accidents in the U.S. T he
S
tate of California Office of Environmental Health Hazard Assessment (OEHHA) f ound “
Hydrogen
s
ulfide is very toxic by inhalation.
Because exposure to this chemical affects most organ systems, hy
drogen sulfide is considered to be a broad spectrum toxicant and may pose a significant health risk to thos
e exposed.”18 T
his recent O
EHHA r
eport also found “
individuals living in close prox
imity to oil
r
efineries may be at risk of chronic exposure to hydrogen sulfide.”19 Although the OE
HHA r
eport
14 T
he Tesoro LARIC project crude oil tank H2S content estimate had to then be changed from 5 parts per million (ppm), to 45 ppm. Addendum to the Final Environmental Impact Report for the Tesoro Los Angeles Refinery Integration and Com
pliance Project, October 2019, p.
17, [
“In the baseline period (i.e., 2012-201
3) analytical data from crude oil suppliers
di
d not include data for H2S
in crude oil. Thus, the data used during the preparation of the May 2017 Final EIR did not pr
ovide concen
tration data for H2S
as a potential TAC in crude oil. For this reason, the May 2017 Final EIR describes the c
oncentration of H2S
in crude oil as typically less than 5 ppm (the analytical detection limit) (page G1-1186 in Appendix G1
of
the May 2017 F
inal EIR). During the preparation of the permit applications for the CCT storage tanks, analytical data be
came available that identified differences in concentrations of some TACs and included H2S concentrations for some crude
oi
ls (up to 45 ppm).”] A
vaila
ble at: http://162.80.26.25/docs/default-s
ource/ceqa/documents/permit-
proj
ects/2019/oct2019addendumtomay2017finaleirfortesorolaric.pdf?sfvrsn=6 15 T
esoro LARIC, Final EIR, V
olume V: Appendix G, May 2017, p. G1-11
86), available at:
ht
tp://www.aqmd.gov/docs/d
efault-s
ource/ceqa/documents/permit-p
rojects/2017/tesorolaric/appg1_2.pdf
16 T
oxic Substances Portal, Hydrogen Sulfide and Carbonyl Sulfide, Agency for Toxic Substances and Disease Registry (A
TSDR),
ht
tps://www.atsdr.cdc.gov/mmg/mmg.asp?id=385&tid=67#:~:text =At%20low%20levels%2C%20hydrogen%20sulfide,conv
ul
sions%2C%20coma%2C%20and%20death.
17 O
SHA online database, A
ccident Search Results, Hydrogen Sulfide,
at:
ht
tps://www.osha.gov/pls/imis/AccidentSearch.search?acc_keyword=%22Hydrogen%20Sulfide%22&keyword_list=on 18 At
page A-16
19 Ca
lifornia Office of Environmental Health Hazard Assessment (OEHHA), Analysis of Refinery Chemical Emissions and H
ealth Effects, March 2019 p. A-1
7, available at:
ht
tps://oehha.ca.gov/media/downloads/faqs/refinerychemicalsreport032019.pdf APPX_000419
13 f
ocused on oil
refineries,
it included evaluation of storage tanks, and so is relevant to oi l ter
minals
including W
orld Oil.
‣ OE
HHA, AQMD, and Oil Industry literature identified crude oil storage tanks, pipelines, an
d transport as sources of H2S corrosion, accidents and releases .
OE
HHA detected H2S at crude storage tanks and highl
ighted them as s
ources.
(p. A-16)
AQMD
identif
ied pipelines connected to storage tanks as sources of ha zardous gas r
eleases: “A
n accidental
r
elease of haz
ardous materials at a facility can occur due to natural events, such as earthquakes, and non-natur
al events, such as mechanical failure or human error. . . Risks are also associated with tr
ansportation, including truck transport, rail transport, and pipe line tr
ansport.”20 (
emphasis added)
Oil
industry literature also identified H2S
in petroleum storage tanks as commonly causing handling pr
oblems, corrosion, environmental risk, safety, and odor problems. ( See below.) An
accidental
release
f
rom storage tanks
and pipelines has the potential to r
each s
ignificant levels over the period of the
li
fespan of the W
orld Oil tanks
Project.
Although not every H2S release would be
e
xtreme,
the ubiquity
of
its presence, and OEHHA’s finding that such releases are c ommon increases the potential for a
s
ubstantial release over a period of years at World Oil. Adding new sources of H2S to the area of Long
B
each and Wilmington (which already has extremely high concentrations of crude oil transport, e
xtraction, refining, a
nd storage) also causes a significant cumulative impact. (See more in E
nvironmental Justice and Cumulative Impacts section below.) ‣ T
he Bay Area Air Quality Management District an
d oil industry literature id
entified
p
articular e
mission points from floatin
g roof storage tanks.
T
he new storage tanks are internal floating roof tanks. This design reduces emissions to atmosphere due
to wind
effects compared to an external floating roof tank without a dome, but does not eliminate
emi
ssions above the floating r
oof, into the space below the dome (or to atmosphere). F or example,
B
AAQMD found: “E
xternal and internal floating roof tanks are emission sources because of e
vaporative losses that occur during standing storage and withdrawal of liquid from the tan k.
Standi
ng storage losses are a result of evaporative losses through rim seals, deck fittings, and/or deck s
eams.”21 F
ittings on floating r
oofs tanks also deteriorate with time.
This would incr
ease e
missions into
the
space above, where H2S can concentr
ate.
‣ Oil I
ndustry li
terature f
ound H2S
i
n crude oil c
auses handling s
afety,
and odor p
roblems:
“R
efineries and storage facilities, such as tank farms, are likely to encounter problems specific to the handli
ng of crude oils, intermediates and refined products that contain or generate H2S. Heavy oils, in
cluding crude oil,
residual fuel and gas oil, tend
to have large concentrations of H2S.
This becomes
a c
oncern if these products are to be stored for an extended time or transported.”22 ( emphasis added)
T
his article also found that in tank farms, there is very little time to correct such H2S problems, and that thi
s contamination causes corrosion and odor concerns: “
In many cases, tank farm or terminal operators
hav
e very little time in which to correct H2S-r
elated problems. These could impact operations
(
personnel safety issues) or profitability (product transport/transfer issues) in a time critical manner. . .
20 T
esoro LARIC, Final EIR, V
olume I: F
EIR & Appendix A2
017, p. 1-2
0, available at: http://www.aqmd.gov/docs/default-
s
ource/ceqa/documents/permit-pr
ojects/2017/tesorolaric/tesoro_feir.pdf
21 A
ssembly Bill 617, Industrial Cap-and-T
rade Sources, Expedited BARCT Implementation Schedule, BA AQMD, Dec.
2018,
p. 2, [Hereafter - BA
AQMD Report] available at: ht
tps://www.baaqmd.gov/~/media/files/ab617-c
ommunity-
he
alth/barct/20181214_fsr_ab617_barct-pdf
.pdf?la=en
22 Ba
ker Hughes, p.
3, A
vailable a
t: ht
tps://www.worldoil.com/uploadedFiles/Media/SULFIX-H
2S-W
hite-P
aper.pdf
APPX_000420
14 A
dditional issues caused by H2S contamination include corrosion problems, odor concerns and produc t
de
gradation.”23
T
he Baker Hughes report and other articles found levels of H2S above crude oil liquid can c
oncentrate to much higher levels (in the vapor space above the crude oil (the “headspace”). B
aker
Hughe
s found storage tanks with H2S in the
crude
li
quid at c
oncentrations of 15-25
ppm c
ould r
each
much
higher concentration in the headspace (up
to 600 ppm measured H2S).
This
is due
to agitation,
higher
temperatures, or increasing the liquid in the tank so that the vapor phase is c ompressed and
c
oncentrated: “H2S
is a gas at typical storage temperatures and equilibrates between liquid and vapor phas
es. Dis
tressed cargoes containing high H2S levels can easily generate percent levels (parts per h
undred) of H2S in storage tank and tran
sport vessel headspaces. C
ertain tank conditions (increased
li
quid volume, agitation and high temperatures) cause deterioration of this already hazardous s
ituation by changing.” p.
4 ‣ Hyd
rogen sulfide is well-k
nown as a corrosion hazard, increasing the risk that a rupture or
leak c
ould occur;
higher concentrations reduced roof lifetime to a few years.
T
he H2S tank
headspace c
oncentrations up to 600 ppm in the
Baker Hughes article were f
ound to
incr
ease corrosion rates a
nd r
educe s
torage tank roof lifetime to les
s than five years. Suc
h deterioration
wa
s not considered in the Negative Declaration and mus
t be e
valuated.
Another a
rticle (on oil
and gas production – c
rude oil extraction) ide
ntified similar H2S hazards in
c
rude oil storage tanks.
It found H2S
“.
. . is also a corrosive, making it more likely that oil storage tan
ks where hydrogen sulfide is present will leak.”24 And C orrosion Journal f
ound increased sulfur
c
oncentrations in crude oil due to
c
ost-c
utti
ng towa
rd using c
heaper crude oils (c
alled “
opportunity
c
rudes”) c
ould introduce higher-H2S
crude oils in
to equipment, r
esulting in incr
eased c
orrosion. It
f
ound that worldwide, a severe c
orrosion incident occurs each week (such as sudden leakages from pipe r
uptures).25
‣ M
itigation measures could reduce H2S in storage tanks, significantly reducing impacts.
F
or example, mitigation to further reduce toxic gases using a c ombination of Domed External
F
loating Roof Tanks in addition to vapor recovery and incineration was identified by the Bay Area Air Qua
lity Management District (
BAAQMD).26 T
his Bay Area regulatory report found additional
e
missions reductions could be achieve
d by adding vapor recovery, and further reductions by also adding incine
ration to domed external floating roof tanks to reduce ROG (Reactive Organic Gases).27 I n
a
ddition to reducing R
OG (a
ka VO
Cs),
this measure would capture, remove vapors, and combust H2S
23 Ba
ker Hughes p. 12
24 H
ydrogen Sulfide In Texas Oil and Gas Production, On behalf of Abraham, Watkins, Nichols, Sorrels, Agosto & Aziz pos
ted in Oil and Gas Accidents on Thursday, December 4, 2014, at:
ht
tps://www.abrahamwatkins.com/blog/2014/12/hydrogen-s
ulfide-in-t
exas-o
il-a
nd-g
as-pro
duction.shtml
25 A
bout the Correlation Between Crude Oil Corrosiveness and Results From Corrosion Monitoring in an Oil Refinery P
hilip
p Schempp,‡, * Karsten Preuß,* and Micha Tröger* 2016, ht tps://corrosionjournal.org/doi/pdf/10.5006/1940
26 A
ssembly Bill 617, Industrial Cap-and-T
rade Sources, Expedited BARCT Implementation
Schedule, BA
AQMD, Dec.
2018,
p. 2, available at: ht
tps://www.baaqmd.gov/~/media/files/ab617-c
ommunity-he
alth/barct/20181214_fsr_ab617_b
arct-
pdf.
pdf?la=en
27 P
otential ROG emission reductions may be achieved by installing domes on external floating roof tanks, an d by capturing
ve
nted emissions from internal floating roof or coned roof tanks and removing ROG emissions through a vapor r
ecove
ry unit (VRU) flowing back to the tank(s) or to a thermal incinerator. ( emphasis added) BA
AQMD Report
l
abeled p.3, 30th p
age of pdf.
APPX_000421
15 va
pors. T
his mitigation could reduce H2S tank concentrations and reduce these gases available to be r
eleased during accidents. The BAAQMD Report showed these additions on a domed floating roof ta nk
c
utting ROG an additional 25 tpy (tons per year) through added vapor recovery, plus another 25 tpy by a
lso adding incineration -- be
yond the 75 tpy cuts achieved by the domed roof on the external floating r
oof tank. (T
his example, p.
4,
assumes emission
s without controls o
f 400
tons per year.) Anothe
r
doc
ument identified H2S
scavengers to remove H2S,
because of the dangers of H2S leve
ls in
c
rude oils,
whic
h it finds a
re incr
easing on
average.28 F
urther, an
article in C
hemical Engineering Online, R
emoving
H2S
from Crude Petroleum On-Sit
e, identif
ied a system used at extraction sites to remove H2S before tr
ansport to refineries, which strips H2S using an inert gas.29 Anothe r mitigation option could be
a
greements for World
Oil to contract with crude suppliers to require that H2S be removed upstream, be
fore shipping to the ter
minal.
‣ Th
e Ports area r
equired years of AQM
D in
vestigation and resources before identification of
t
he source of o
ngoing o
dors, in
cluding H2S f
rom crude oil tankers.
T
he Los Angeles Times reported in November of 2018 that inspectors identified fugitive emissions f
rom an oil tanker as the source of pe
riodic pungent odors that took years to identify.30
AQ
MD a
lso publi
shed it
s own Ne
ws Release in
2018, describing its ye
ars of
work a
nd extensive
r
esources necessary to identify these odors,
and the association violations.31
“F
or the past two years we h
ave devoted extensive resources to finding the sources of p
eriodic foul odors in Long Beach, Seal Beach and Huntington Beach,” s aid Wayne Nastri,
S
CAQMD’s executive officer. “Using a combination of dedicated field staff, advanced e
missions imaging technology,
atmospheric modeling and in-hous
e laboratory analysis, now for
the
first time we have confirmed one potential source of these odors.” . . .
C
rude oil contains dissolved hydrocarbon and sulfur gases that can be released to the atmosphere if
not pr
operly contained in the vessel’s storage tanks.
Ga
ses detected include
d H2S (
one of the most odorous sulfur compounds), a
nd hyd
rocarbons.32
IV. Hazards of fires,
explosions, or spills due
to tsunami or earthquake are
significant
T
he Negative Declaration s
tates ther
e are less-than-s
ignificant risks of
impacts f
rom ts
unamis a
nd
e
arthquakes. T
his is not only
illogical at face value since the Project is in a tsunami inunda tion zone and
a
region at high earthquake risk, but the specific studies and facts below demonstrate that there is a
28 Ba
ker Hughes, H
ydrogen Sulfide Management Mitigation options in petroleum refining, storage and transportation, ht
tps://www.worldoil.com/uploadedFiles/Media/SULFIX-H
2S-W
hite-P
aper.pdf
29 M
ay 1, 2018, h
ttps://www.chemengonline.com/removing-h2
s-c
rude-pe
troleum-s
ite/
30 ‘
Fugitive emissions’ from oil tanker identified as a source of foul mystery odors in local cities, L A Times, Nov. 12,
2018,
[“Ins
pectors say they have identified “fugitive emissions” from a 2-m illion-bar
rel crude oil tanker as a culprit in periodic
punge
nt odors that have offended coastal residents and whose source has e luded detection for years.”] a
vailable at:
h
ttps://www.latimes.com/socal/daily -pi
lot/news/tn -dp
t-me-c
oastal-o
dor-20
181112-
s
tory.html#:~ :
text=Inspectors%20say%20they%20have%20identified,has%20eluded%20detection%20for%20years. 31 SC
AQMD Issues Violation to Oil Tanker Ship for Fugitive Emissions, N ov. 9, 2018, http://www.aqmd.gov/docs/default-
s
ource/news-a
rchive/2018/violation-to-oi
l-t
anker-s
hip-nov9-2018.
pdf?sfvrsn=8
32 L
A Times 11/12/18 article above, [“The agency partnered with the fire departments in those cities to train their personnel t
o collect air samples when residents report odors. Analysis of those samples showed higher levels of c hemical compounds
i
ndicative of an odor from crude oil or unprocessed natural gas, the agency said. The compounds included several hydroc
arbons and h
ydrogen sulfide,
the agency said.” (emphasis added)]
APPX_000422
16 s
ignificant risk of impacts due to the Project because fires, explosions, spills, and other impacts c an
r
esult from earthquakes
and ts
una
mis
(a
nd from general malfunctions which can also cause fires in this
kind
of project,
which were not evaluated).
A. T
sunami risk is
significant at
the Project location,
increasing haz
ards due
to new tanks
T
he Negative Declaration conclusion that ha
zards due to tsunami are less-than-s
ignificant (based on
r
eference to a 2007 ports study that was not produced) is contradicted by a 2010 ports study published by
the National Oceanic and Atmospheric Administration (NOAA) a nd other information a
vailable
onli
ne. T
he 2010 study for example provides clear evidence that there is a significant risk of damage dur
ing tsunami to the Project area. Such damage has the potential to cause oil s
pills and potentially
other
hazards whic
h must be fully evaluated.
T
he Nega
tive Declaration found the
risk of damage from a tsunami would be less than significant.
B
ut it also contradicts itself by acknowledging that “
Due to the project’s location adjacent to the ocean,
the
project site is vulnerable to tsunamis ge
nerated off the coast of California.” (
Negative Declaration at
4-36) I
t a
lso identi
fied a
2007 report which i
t s
tates s
hows a
tsunami would only oc
cur at this location
e
very 10,000 years. (
Moffatt & Nichol, 2007). T
his report was not provided. I
t is not
possible to
de
termine which c
onclusions in
the Negative Declaration c
ame from the
2007 study r
eport, a
nd which
we
re other
wise a
ssumed or c
oncluded by the Negative Declaration authors.
E
ither way, other
e
xpert reports whic
h s
tudied ts
unami im
pacts in the
Ports of Long Beach and LA
(publi
shed late
r a
nd a
vailable to
the public online) c
ontradict the
Negative Declaration’s c
onclusion.
T
hese show that there is a potential of significant impacts at the Project location in the Ports of Long B
each a
nd Los Angeles.
F
or example, a 2010
S
pecial Report on Tsunami Hazard Assessment of the National Oceanic and Atmos
pheric Administration (NOAA) – Dis
tant tsunami threats to the ports of Los Angeles and Long B
each, California33 – f
ound tsunami risks f
rom 11 different far-a
way sites can produce tsunamis
tr
aveling a long distance that
are “
significant to the ports of Los Angeles and Long Beach”.34
I
t specifically f
ound s
uch ts
unamis can trigger waves and currents exceeding 8 knots (≈4 m/s) in the P
orts of LA and Long Beach, and concludes that “Curr
ents are particularly noteworthy since those
e
xceeding 8 knots (≈4 m/s) are known to break mooring lines and damage harbor piers and other s
tructures.” (
pp. ix-x) T
he only wa
y to interpret t
he s
tatement a
bove and the following conclusion of
the r
eport,
is that
tsunamis pose a significant,
and “
considerable” danger in the Po
rts of
Long Beach and
L
os Angeles
. The conclusion goes on to state:
Fin
dings show that tsunamis generat
ed along far-f
ield subduction zones pose considerably more
d
anger to the ports of Los Angeles and Long Beach than previously thought . . . D
ue to their
i
mportance to United States commerce, the hazard posed by tsunamis is of great concern because the
33 Bur
ak Uslu, et al, Joint Institute for the Study of
the Atmosphere and Ocean (JISAO), University of Washington, Seattle, W
A, NOAA/Pacific Marine Environmental Laboratory (PMEL), Seattle, WA, May 2010, available at:
ht
tps://nctr.pmel.noaa.gov/hazard_assessment_reports/02_LA_LB_CA_3532_web.pdf 34 “
Of these 322 scenarios [investigated], tsunamis from 11 source regions in Alaska, Chile, Philippines, Manus, New Z
ealand, and Vanuatu are identified as having the potential to generate a tsunami significant to the ports of Los Angeles and L
ong Beach, so t
hese are investigated in detail.” at pp. ix-x
APPX_000423
17 pote
ntial devastation and impact would likely interrupt commerce, marine, and tourism activities. Tourist a
ttractions, including the Maritime Museum, Aquarium of the Pacific, and Queen Mary (Figure 1.1), a
long with the large number of tourists who visit them da ily, are potentially at risk. (
p. 30)
The im
plication is clear that the
2010 r
eport’s authors do not interpret this risk as e
xtremely rare (
such as
e
very 10,000 years,
which the Negative Declaration concluded).
The C
alfornia Department of Conservation publ
ishes de
tailed tsunami maps, including the L
ong
B
each Tsunami Inundation Area map be
low.
It s
hows the World Oil P
roject s
ite c
learly include
d in t
he
inundation z
one (with
the
blue a
rrow I a
dded to
highlight World Oil).35
B. E
arthquake risk is high at the
P
roject location
, which adds
s
ignificant ne
w hazards
As
in the case for tsunamis, the Negative Declaration acknowledges that the region can experience s
trong earthquakes, but it then
c
oncludes that
risk is less-than-s
ignificant. It also describes plans to la
ter
e
valuate the Pr
oject design and c
oncludes later recommendations will ensure impacts are not significant.
I
t even states No Mitigation is Necessary. (Neg. Dec. p. 4-22)
T
he final project design would be reviewed by Albus-Ke
efe & Associates, as the design implements
r
ecommendations of the geotechnical investigation report (Matrix, 2019). Although the site is likely to
experience strong to very strong ground shaking within its lifetime, implementation of the ge
otechnical investigation report’s recommendations in the fina l project design ensures that impacts
f
rom ground shaking would be less than significant.
M
itigation Measures: No
mitigation is required.
35 Ca
lifornia Dept. of Conservation, Los Angeles County Tsunami Inundation Maps, Long Beach Quad, at ht
tps://www.conservation.ca.gov/cgs/Documents/Publications/Tsunami- M
aps/Tsunami_Inundation_LongBeach_Quad_LosAngeles.
pdf
APPX_000424
18 I
t is not possible to rely on future evaluations, not e
ven r
equire them as mitigation, and then
c
onclude these will e
nsure Project mi
tigation
of “
very strong ground shaking within its lifetime”. This
a
lso goes against known s
evere impacts at storage tanks due to earthquake, including examples below.
I
n addition, in other places, the Negative Declaration it self identi
fies uncertainty regarding the
e
ffectiveness of future improvements in reducing effects of seismic and other ground-s ettlement:
B
ecause the site is underlain by compressible earth materials that are susceptible to liquefaction, im
plementation of a
groun
d improvement system may r
educe the effects of static and
s
eismic settlements. C
onstruction of the ground improvement system would consist of vibratory s
tone column Geopiers, also known as vibro pie
rs, or equivalent rammed aggregate piers
(
RAPs). (
emphasis added, p. 2-5)
T
he Negative Declaration also states that because people would not live at the project sites, ther
efore, it cannot result in an increase in seismic hazards to people.
T
he propos
ed project would not include habitable structures and would therefore not result in a c
hange or increase in the seismic hazard to people. (
p. 4-22)
T
his is also erroneous. For example, earthquake induced failures causing fires at petroleum storage tanks
are a known hazard (also documented below). Such fires can spread well beyond the Project loca
tion, and even if they don’t, produce heavy black smoke that can spread over residential areas for many
miles. (See for example Nustar fire below.) This Projec t does significantly increase the potential
f
ire hazard with associated significant impacts listed below.
T
hese uncertainties, inconsistencies, and incor
rect information r
egarding effectiveness of future
mi
tigation,
as well as great underestimation of potential impacts, c annot form a basis to conclude tha
t
ther
e is no potential for a significant impact from earthquakes due to the Project. Furthermore, common s
ense, the information below, and other widely available inf ormation means there is certainly a potential
f
or significant impacts due to earthquakes.
I
n 2015, USGS predicted that within the next 30 years, the LA Region has a greater than 60% c
hance of an earthquake of magnitude 6.7,36 a
nd a 31% chance of a magnitude 7.5 (Richter Scale). In 2016,
T
homas Jordan, director of the Southern California Earthquake Centre stated at a conference in L
ong Beach that t
he San Andreas f
ault i
n Southern California is
“Locked, Loaded, and Ready to
Roll.
” T
he Nature Science Alert publishing this w
arning a
lso f
ound: “C
alifornia's San Andreas fault
has
been quiet for far too long and is overdue for a major earthquake. The state was warned to prepare for
a potential earthquake as strong as magnitude
8.0.” 37 C
onsequently the
re is more than a passing
c
hance of major seismic shaking in
this location soon,
and certainly during the P
roject e
quipment life.
T
he pr
oposed World Oil tanks
are floating roof tanks, which have s
eismic vulnerabilities s
uch as
da
mage caused by sloshing, s
inking roofs and many f
ailure modes dur
ing earthquakes. These can cause,
36 ht
tps://www.usgs.gov/faqs/what-prob
ability-e
arthquake-w
ill-oc
cur-l
os-a
ngeles-a
rea-s
an-fr
ancisco-b
ay-a
rea?qt-
ne
ws_science_products=0#qt-n
ews_science_products,
and ht
tps://pubs.usgs.gov/fs/2015/3009/pdf/fs2015-30
09.pdf,
p. 4
37 S
cience Alert, N
ature, S
cientist Says The San Andreas Fault Is "Locked, Loaded, And Ready to Roll", F iona Macdonald, 5
M
ay 2016, h
ttps://www.sciencealert.com/the-s
an-a
ndreas-f
ault-is-l
ocked-l
oaded-a
nd-re
ady-to-ro
ll-s
ay-s
cientists
APPX_000425
19 s
pills, f
ires and explosions, and can spread to other tanks and facilities. Crude oil fires can cause
e
xtremely smoky air pollution that is
ha
rmful to pe
ople br
eathing it
we
ll downwind.
Some known
e
xamples of tank failures during earthquake are shown below. T hese include b
oth f
ires an
d failures
c
aused by a lar
ge e
arthquake i
n Japan,
and a
major fire that regulators in
vestigated as potentially
c
aused by a s
mall e
arthquake in the San Francisco Bay Area (
which were found as the cause of oil
r
efinery incidents at the same time).
i. A
2008 J
apanese study of tank failures s
howed mult
iple seismic vulnerabilities
A J
apanese 2008 s
tudy of s
eismic
da
mage to pe
troleum storage tanks
de
monstrated im
pacts including sloshing,
f
ires, spills, weld-s
plitting, pontoon
buc
kling, r
oof sinking,
and more.
T
his study included both an e
xperiment
(whe
re a
full scale storage tank wa
s built
a
nd s
ubjected to s
haking to verify
c
alculations) a
s well as doc
umentation of
a
ctual f
ires and other damage to storage
tanks
dur
ing major earthquakes inc
luding
the
Tokachi-oki S
ept. 28, 2003, (
also
known a
s the
Hokkaido 2003 e
arthquake,
8. 138 on
the Richter scale),
and others. T
he
s
tudy s
lides in
English a
re shown at right
a
nd below.39
38 G
eotimes, 9/26/2003, American Geological Institute, h
ttp://www.geotimes.org/sept03/WebExtra092603japan.html
39 E
xperimental Study of Floating Roof Integrity for Seismic Sloshing, O ctober 8, 2008 Haruki NISHI, Dr. Eng. National
Re
search Ins
titute of Fire and Disaster Fire and Disaster Management Agency, Japan, at:
ht
tps://mycommitte
es.api.org/standards/cre/scast/Shared%20Documents/Meeting%20Minutes%20and%20Presentations/Stor a
geTankConf2008NISHISloshing.pdf
APPX_000426
20 Da
mage to
tanks in Japan included s
moking fires,
which are difficult to extinguish, and which can
c
ause health harms far downwind depending on weather conditions ( see below). T
he slides a
lso
identif
ied both
short and long period shaking de
pending on tank size. Shorter period means faster
s
haking, longer period means slower shaking;
both
can be damaging.
APPX_000427
21 ii. A San
Francisco Bay Area major storage tank fire fol
lowed a s
mall earthquake,
impacting a
w
hole region for hours,
illustrating the significant impacts of tank
fires
Ma
ny de
tails a
re available on
the m
inute-
by-mi
nute breakout of
a dr
amatic f
ire on
Oc
t. 15, 2019, whe
n a s
torage tank
at NuS
tar
E
nergy pe
troleum storage in
C
rockett,
C
alifornia e
xploded.
This wa
s doc
umented
by
extensive news media,
by f
ire department
a
nd regulatory
agency p
ress c
onferences
dur
ing the many hour
s o
f the fire, a
nd in
a
f
ollow-up publi
c he
aring. I
t is worthwh
ile
t
o e
valuate the r
eal-li
fe impacts o
f s
torage
t
ank fires
in general in
California.
N
uStar, s
lides f
rom C
ontra Costa County 10/
22/19 he
aring
T
his f
ire d
emonstrated the complexity of impacts and emergency response necessary when just
on
e p
etroleum t
ank c
atches f
ire. The f
ire invol
ved two
tanks and mea
nt r
isk of spreading fire (
from the
tanks
and ensuing brush fire), blac
k smoke ha
rmful to breathing, e
vacuation of the very small ne
arby
c
ommunity of Tormey, a
nd a
Shelter-in-P
lace order for the rest of the e
xtensive s
urrounding
c
ommunities. (S
ome in the Shelter-in-P
lace area wa
nted to evacuate due to poor air quality but could not
due
to widespread gridlock)
. T
he fire invol
ved major f
reeway a
nd road s
hutdown f
or hours, a
nd
e
xtensive use of emergency response resources.
Top
10/
15/2019,
A
BC7 News
Bot
tom P
hoto,
D
ick Lyon,
N
uStar fire
from
Treasure
Is
land, SF (~20
m
iles)
APPX_000428
22 T
he NuS
tar t
anks burned for seven hours,40 c
reating smoke over the Bay Area and high
leve
ls of f
ine particulate matter (PM2.5) mea
sured by loca
l regulatory agencies.
(S
ee da
ta be
low.)
This e
xplosion followed a small
e
arthquake that was felt throughout
t
he region (
Richter Scale 4.5).
This
wa
s de
termined by C
ounty o
fficials a
s
the c
ause of
malf
unctions and flaring a
t
two
refineries.41 Likew
ise the
e
arthqua
ke was identif
ied as a potential
c
ause of the NuSt
ar e
xplosion.42 (
The
f
inal determination of c
ause was never
publi
cized.) W
hether it ha
d the same
c
ause as the r
efinery malf
unctions
(
earthquake),
the NuSt
ar e
xplosion
de
monstrates how
one tank fire can
im
pact a whole region. If the
NuSt
ar
e
vent wa
s caused by s
ome other r
oot-
c
ause,
it ne
vertheless il
lustrates tha
t the
potential
impac
ts due to a tank fire at
the
World Oil facility P
roject in
Long
B
each, a
re significant,
regardless of
c
ause.
A
fire b
reaking out at
only one tank
in
a p
etroleum t
ank f
arm always
p
resents a danger to t
he ot
her t
anks. In
the
case of NuSt
ar the f
ire e
ngulfing two
e
thanol tanks
did thr
eaten other tanks
ne
arby,
for example shown by scorch
mar
ks at right.43 C
ontra Costa County
pr
aised firefighters for keeping the fire
only
to the two tanks, when it could have been much worse,
during its public he
aring discussion. The
40 Con
tra Costa County Board of Supervisors hearing, 10/22/2019, Item D.3, CONSIDER update on the status of the NuStar E
nergy inci
dent, Crocket area. (Randy Sawyer, Director of Hazardous Materials Program and Lewis Broschard, CCC Fire P
rotection District Fire Chief), Video of hearing including slides available at: h ttps://contra-
c
osta.granicus.com/MediaPlayer.php?view_id=2&clip_id=1635# V
ideo download also available on this webpage.
41M
edia agencies were told by Randy Sawyer, Director of the Hazardous Materials Program, Contra Costa County, tha t the
t
wo refinery malfunctions were caused by this earthquake. K QED, Wed. update to Tuesday 10/15/2020 article [“T
he
s
tronger quake [4.5] caused malfunctions at the Shell and M arathon oi
l refineries in Martinez, said Randy Sawyer, Contra
Cos
ta County's chief environmental health and hazardous materials officer.”] a t: h
ttps://ww
w.kqed.org/news/11780107/4-5-
m
agnitude-e
arthquake-ne
ar-p
leasant-hi
ll-r
attles-ba
y-a
rea
42 By
the Associated Press in ABCNews, Earthquake probed as possible cause of California fuel fire, 10/16/19 [
“CROCKETT, Calif. -- O
fficials were trying to determine Wedne
sday if a 4.5 magnitude earthquake triggered an explosion at
a fuel storage facility in the San Francisco Bay Area that started a fire and trapped thousands in their homes for hours be
cause of potentially unhealthy air.”], at: ht
tps://abcnews.go.com/Business/wireStory/earthquake-pr
obed-c
alifornia-f
uel-
f
ire-6
6319966
43 K
PIX 5, S
helter in Place for People Near NuStar Facility by Crockett & Rodeo, 10/15/2019, available at:
ht
tps://www.youtube.com/watch?v=VZNTLNclIzQ&app=desktop
P
hoto by By Dick Lyon
P
hoto above fi
eld blackened by fire, nearby freeway later
shu
tdown), from ABC 7 News video, 10/15/2019
P
hoto above fi
eld blackened by fire, nearby freeway later
shu
tdown), from ABC 7 News video, 10/15/2019
APPX_000429
23 ta
nks are c
onnected by pipeline to other facilities (
such as the nearby oil refinery), r
aising que
stions
a
bout potential s
preading ha
zards. Dr
ainage from the bermed area surrounding each tank was connected to
the Bay,
threatening dis
charge of petroleum products and firefighting foam.
Doz
ens of fire
fighters als
o h
ad to battle t
he b
rushfire c
aused by
NuS
tar,
using a h
elicopter, tractor, and b
y h
and ne
ar an o
il refinery,
publi
c roads, a
nd a
major f
reeway (
which had to be shut down).
Additi
onal petroleum storage tanks at the nearby Phillips 66 refinery we
re uphil
l from NuSt
ar.
W
orkers had to flee following the ini
tial e
xplosion, and locked
the
gate on their way out, hampering firefighter entrance,
and failing to
tur
n on fire-s
uppression equipment. One
contractor was unable to
e
scape and had to hide in a ditch until firefighter
s r
eached him. The
tank f
ires ke
pt
re-igni
ting, and took many hours to put out. (F
irefighters
s
tated that the
ethanol fires
weren’t particularly ha
rder to address than
other
kinds of petroleum fires,
indicating s
uch tank
fires a
re all difficult
to c
ontrol.44) I
n addition to the two ethanol tank fires, firefighters had to c
onstantly spray cooling water on surrounding tanks licked by flames.
Af
ter the fire was put out, other tanks had to be carefully depressurized in the f
ollowing days.45
B
y comparison
, Wor
ld Oil in
Long Beach h
as a heightened fire
r
isk due to an expected (and much larger) earthquake which can oc
cur at any time. T
here is a significant risk that a major earthquake c
ould c
ause a NuSt
ar-li
ke fire
dur
ing the li
fespan of the P
roject. The higher concentration of petroleum storage a t World Oil would
a
lso incr
ease da
nger of
one incident (fire at one tank) spreading to another. I measured the distance
us
ing an aerial map46 be
tween a bur
ned tank at NuSt
ar and a
nother
NuStar tank
shown as scorched in
the
photo on the previous page.
I f
ound it was much farther than the distance between existing World Oil
tanks, and proposed tanks, yet the NuStar burned tank still endangered the nearby tank. This is a
nother indication that
adding two W
orld Oil tanks
increases cumulative risk of fire due to earthquake or
other
accidents involving fire at the facility due
to proximity of new tanks.
T
he Bay Area Air Quality Management District’s incident report during the r elease reported large
plum
es of black smoke, a major highway closure for many hours (during rush hour), and a shelter-in- plac
e ordered:47
44 A
BC News, Oct. 15, 2019, L
atest: California oil fire health warning lifted, [“H
e says ethanol blazes are not necessarily
a
ny more difficult to fight than gasoline or diesel fires.”],
ht
tps://abcnews.go.com/US/wireStory/latest-fue
ls-c
ompany-c
ooling-n
earby-t
anks-s
tem-fi
re-663
02190
45 K
QED News, 10/16/2020, [‘“
They're going to vent adjacent tanks ... to relieve pressure and prevent fire," Hill said at a ne
ws conference.’], available at: ht
tps://www.kqed.org/news/11780224/shelter-in-pl
ace-or
der-i
ssued-f
or-r
odeo-c
rockett-
f
ollowing-f
ire-at-nus
tar-e
nergy-f
acility
46 NuSt
ar site on google map. N
uStar tanks were over 80’ apart, whereas World Oil new tanks would only be ~30’ from e
xisting World Oil tanks.
47 BA
AQMD, INCIDENT REPORT, NuStar Energy LP (Site #A0581), 90 San Pablo Ave Crockett, CA, October 15, 2019, ht
tps://www.baaqmd.gov/~/media/files/compliance-a
nd-e
nforcement/incident-
re
ports/2019/nustar_incident_report_10152019_final-p
df.pdf?la=en
N
uStar fire
APPX_000430
24 L
arge plumes of black smoke were observed throughout the Bay Area. Winds at the time were li
ght and variable. Both directions of Highway 80 were closed at approximately 3:00PM and are e
xpected to remain closed until at least 11:30PM. A shelter-in-plac e was or
dered by Contra
C
osta County Sherriff’s office shortly after 2:00PM for Rodeo and Crockett.
T
he Contra Costa County Board of Supervisors held a public hearing 10/22/2019, where Randy S
awyer (Director of Hazardous Materials Program, Contra Costa County) a nd Lewis Broschard, Fire
C
hief testified and presented data and slides on the NuStar explosion. M uch of the material above was
de
scribed in the County presentations as well. I
n addition, Mr. S
awyer m
ade the following points:
• He
be
lieved the
source of the heavy smoke was not the ethanol it
self in
the storage tanks, but the
int
roduction of dies
el, jet fuel, or other
petroleum products into the fire due
to c
ompromised
pipi
ng c
aused by the
fire/explosion.48
• He
reported on C
ounty
mea
surements of PM2.5
a
nd pr
ovided the
c
hart at
r
ight s
howing that levels
we
re in some cases in the
highes
t category
(
Hazardous –-a
bove
0. 2505 mg/m3
(
milligrams per cubic
mete
r of air)).
His chart
s
howed other samples
r
ose to Unhealthy levels
(
for a
ll individuals - ove
r
0. 0555 mg/m3).
• He
stated generally that
P
M2.5 in the
thick black
s
moke is unhealthy, and
wa
s the reason for the
S
helter-in-P
lace.
L
ewis Broschard, Coun
ty F
ire Chief als
o made many points similar to t
he above descriptions
of
the fire,
and stated d
uring the County hearing an
d further s
tated:
• I
t was necessary to r
ely heavily on
the joint response of refinery fire departments
(P
etrochemical
M
utual Aid Organization,
or P
MAO including C
hevron, Marathon, Phillips 66 r
efineries and
other
s), who pr
ovided s
ubstantial additional f
irefighting s
taff and equipment.
• T
he County ha
d to keep replacing f
ire suppression foam to
remove the oxygen source from the
f
lames in the
tanks, whic
h re-igni
ted a
few times. T
his necessitated receiving much a
dditional
48 A
t time 1:33 of the CCC County hearing, https://contra-c osta.granicus.com/MediaPlayer.php?view_id=2&clip_id=163 5 APPX_000431
25 f
oam f
rom P
MAO,
as well as indus
trial pumping facilities with ladders that c
ould put out twice
a
s much f
oam quickly. T
hey used up
most of
the
foam by
the end of the night. T
he County
indica
ted this access was key.
• The
County Timeline a
t right shows
it took hours to
put
resources in place, and stop the fire.49
I
n summary, storage tanks containing pe
troleum
mate
rials are vulnerable to earthquakes, tsunamis, and
other
malfunctions, which can cause fires, explosions,
s
pread to other tanks, cause spills, spread fire to
s
urrounding lands
, cause major air pollution episodes, and shutdown regional transpor tation. T
hese are
s
ignificant impacts, and the World Oil Project significantly increases the risk of these oc curring.
T
he addition of even one new petroleum storage tank significantly increases this risk, moreso for t
wo. Additi
onal photos below.
49 C
ontra Costa County hearing, Timeline Slide presented at time 1:13
ht
tps://www.kron4.com/news/i-80-s
hutdown-t
raffic-i
mpacts-from-r
efinery-fi
re-in-c
rockett/
ht
tps://www.usnews.com/news
/us/articles/2019-10-15
/the-l
atest-
fue
ls-c
ompany-c
ooling-ne
arby-t
anks-to-s
tem-fi
re
K
PIX 5, Moment when T
ank Roof explodes
APPX_000432
26 V. E
nvironmental Justice an
d Cumulatively Significant Impacts
A. T
he State of California and many r
egulators have recognized that
e
xisting impac
ts and haz
ards
in
the surrounding community are already considerable and
need to be reduced
The
c
ommunity surrounding this Project in
the general harbor area is
recognized as disadvantaged
due
to extreme concentration of he
avy industry, with high levels of c
umulative impacts to a
ir, water, and
s
oil contamination, exacerbated by health burdens and other socioeconomic disadvantages. T he worst
im
pacted are communities of color and low-income
communities. T
his is not a matter of opinion, but
we
ll-doc
umented a
nd accepted by the State of
California and AQMD, be
cause of s
tudies too
numerous
to
list. As
a result, most public agencies have adopted Environmental Justice policies to address such
inequiti
es. F
or example, the C
alifornia Coastal C
ommission adopted an Environmental Justice Policy
in
2019.50 I
t states:
Heavy
industrialization and environmental contamination of some portions of California’s c
oast has effectively eliminated much of the public coastal use in these industrialized and c
ontaminated areas. T
he Commission will also work with the relevant public agencies to c
onsider project impacts to air quality and soil health in disadvantaged communities which r
educe the positive health and recreational benefits associated with coastal access and coastal re
sources for pollution-bur
dened communities. .
. . The intent will be to ensure that low-income
c
ommunities and communities of color, and other disadvantaged communities are not dis
proportionately affected by water contamination or overuse, or diminished e nvironmental
s
ervices such as those provided by healthy ecosystems, fully-f unctioning wetlands, and clean
wa
ters and lands in the coastal zone.
T
o evaluate such cumulative impacts, C
alEPA’s OEHHA publishes C
alEnviroScreen, a mapping
pr
ogram which maps
and
scores concentrated e
nvironmental and socioeconomic burdens in California.
OE
HHA de
scribes it
s tool a
s follows:51
Wh
at is CalEnviroScreen?
• C
alEnviroScreen is
a mapping tool that
helps identify California communities that are most
a
ffected by many sources of pollution, and where people are often especially vulnerable to poll
ution’s effects.
• C
alEnviroScreen uses environmental, health, and socioeconomic informa tion to produce
s
cores for every census tract in the state.
• T
he scores are mapped so that different communities can be compared. An area with a high
s
core is one that experiences a much higher pollution burden than areas with low s
cores.
• C
alEnviroScreen ranks communities based on data that are available from state and federal gove
rnment sources.
(
emphasis added)
50 A
vailable at: h
ttps://documents.coastal.ca.gov/assets/env-j
ustice/CCC_EJ_Policy_FINAL.pdf
51 ht
tps://oehha.ca.gov/calenviroscreen/about-c
alenviroscreen
APPX_000433
27 Th
e CalEnviroScreen maps below s
how t
hat r
esidential areas around the ports where World
Oi
l is located ar
e am
ong t
he highest s
cored p
ollution burdens in the state (
over 91% highest
im
pact scores in the red a
nd orange z
ones). 52 No
areas near the ports show green (the healthiest, least
im
pacted areas, which only appear far
ther a
way f
rom the ports). Grey areas are indus
trial or commercial
a
reas (non-r
esidential) not scored by CalEnviroScreen, although workers at these offsite areas can a lso
ha
ve high impacts. I
added the Blue Arrow to show the location of the World Oil (Ribost) Terminal.
I
n addition to overall pollution burdens, CalEnviroScreen provides separate scoring for Toxic Air
Contaminants, including the following ports area map. The yellow stars are addresses of toxic
s
ources (such as refineries). T
he map specifically identifies Ribos
t Terminals (World Oil), a
s one of
thes
e Toxic Release Facilities, a
nd shows this area at the
highest-im
pact leve
l (
over 90% worst im
pacted
by
Toxic Releases, s
hown as da
rk purple in the Le
gend at right).
52 T
o get to the maps shown in this comment letter, the CalEnviroScreen website is available at the following link, and by
z
ooming in on specific areas of the state, or inputting cities or zip codes. ht
tps://oehha.maps.arcgis.com/apps/webappviewer/index.html?id=4560 cfbce7c745c299b2d0cbb07044f5
APPX_000434
28 T
he South Coast Air Quality Management District
also has an Environmental Justice Policy,53
an
d developed a Community Emission Reduction Plan (CERP) f or t
he Wilmington / Carson / W.
L
ong Beach (
WCWLB) ar
ea. T
his was adopted in 2019 by AQMD, and f
inalized 2020 by the
C
alifornia Air Resources Board. T
he p
orts area is identified in
the CERP as
one of the 6 main
p
riorities for emissions r
eductions.54
T
he Wilmington, Carson, West Long Beach community identified the following air quality pr
iorities to be addressed by this plan:
• R
efineries
•
Ports
•
Neighborhood Truck Traffic
•
Oil Drilling and Production
•
Railyards
•
Schools, Childcare Centers,
and Homes
At
its core, thi
s plan seeks to address the identified priorities with ac tions that reduce air
p
ollution emissions from sources within this local community a s well as reduce air pollution
e
xposures to the people in this community. (
emphasis added)
53 ht
tp://www.aqmd.gov/nav/about/initiatives/community-e
fforts/environmental-
j
ustice#:~:text=The%20purpose%20of%20South%20Coast,of%20air%20within%20their%20communities. 54 A
QMD, Com
munity Emission Reduction Plan, Wilmington, Carson, West Long Beach, Sept. 2019
Final, p. ES-5
,
ht
tp://www.aqmd.gov/docs/default-s
ource/ab-617-ab-1
34/steering-c
ommittees/wilmington/cerp/final-c
erp-
wc
wlb.pdf?sfvrsn=8
APPX_000435
29 Note
that in addition to the Ports, related priorities include the refineries (which use crude oil and lease tanks
from the World Oil terminal) d
rilling operations (which produce crude oil), a
nd neighborhood
tr
uck traffic, which would be incr
eased by the Project. In addition, schools, childcare centers, and homes in
the area of the ports are impacted by cumulative air pollution due to the Project (for example, when winds
blow in their direction); these are also listed as priority areas to r eceive additional protections and
r
eductions in pollutants.
B
ecause of high impacts, WCWLB wa
s chosen by the California Air Resources Board as one in only ten
communities in
the state to
receive a specialized CERP in
the first year of this program,
out of
many
doz
ens whic
h a
pplied to receive one.
Ne
ighbors and community organizations in the Ports area W CWLB ha
ve long s
ought protective
mea
sures to slow the concentration of ne
w poll
uting and hazardous sources a
nd reduce pollution. T
his
r
equires serious evaluation of cumulative impacts, rather than streamlining of permitting and e
nvironmental assessment,
as in
the ND’s cumulative impacts a
nalysis.
At a
minimum, environmental assessment before f
inalizing a permit is
ne
cessary and appr
opriate,
but
the Project received a permit even before the ND was published (early this year).
Unfortunately,
ins
tead of the especial importance of evaluating cumulative impacts in this area, the ND analysis is very
inade
quate, and would allow the Proje
ct to add ha
zards and pollution which are significant by
thems
elves, but also cumulatively significant.
B. C
umulative Impacts of the Project are Significant
T
he Project analysis gave short shrift to many
specific c
umulative impacts. T
his area contains
a
rguably the most intensive concentration of petroleum pr ocessing a
nd impacts on the West Coast, and
e
xpansion of such sources continues.
Cum
ulatively Significant impacts of the Project in
clude t
he following examples (
but are not
li
mit
ed to these).
T
he Project a
dds both to
existing high-leve
ls in the region a
nd to
ne
w projects (some
of
which are listed below):
• VOC
emissions including benzene a
nd others a
re already cumulatively significant in the
a
rea, and the Project s
ignificantly adds to this cumulative impact. For example, the WCWLB C
ERP found 2017 VOC emissions in this area a
t o
ver 5,640
tons per year of VOCs with
the
major
ity from stationary and are
a sources. (T
hese a
re even larger than the lar
ge mobi
le
s
ource e
missions
in the area).
(p. Appendix 3b-2) T
his loca
lized inventor
y does not include
the
underestimation of VOCs a
nd benzene f
ound in the studies documented earlier in my
c
omments,
which would
make the cumulative VOCs, and the Project VOCs, even worse.
T
here are many new P
roject approvals permitted in the area since 2017, which should be identif
ied. F
or example, t
he M
arat
hon / T
esoro refinery received approval by
S
CAQMD late in 2019 to add
6 new crude oil storage tanks in this area,
which must be
APPX_000436
30 e
valuated cumulatively with the World Oil Project, as part of an adequate evaluation of c
umulative impacts.55
• Cum
ulative H2S odor impacts in the ports area is particularly of concern, since t he
P
orts have already been found as a source of
significant and persistent H2S odors that
t
ook years for AQMD to locate. (S
ee my earlier comments regarding H2S.) Such impacts
don’
t have to occur exactly simultaneously to be cumulatively significant; the se sources are
us
ually episodic in nature, but the presence of new sources mean the potential for more f
requent episodes, adding to the community burden.
• Ot
her cumu
lative H2S impacts ar
e potentially s
ignificant because of the e
xtreme
c
oncentration o
f petroleum s
torage and processing in this area. As
dis
cussed e
arlier,
AQ
MD found a
ccidental release of ha
zardous materials c
an occur due to e
arthquakes.
mec
hanical failure, hu
man error,
or during tr
ansport including
pipe
lines. E
arthquakes in
pa
rticular could ca
use multiple relea
ses including
H2S whic
h could be cumulatively
c
onsiderable,
and which the Project adds to.
• Die
sel t
rucking emissions add to the already e
xtremely heavy diesel emissions in this area
to
and from
the ports. T
he WCWLB CERP also found: “.
. . DP
M [
Diesel Particulate
M
atter]is
the biggest contributor to the overall cancer risk in the c ommunity, followed by
1,
3-butadi
ene, hexavalent chromium and benzene.” (
p. 3b-5) I
t is important that a
ll these
c
ancer-c
ausing and other toxic e
missions decrease, not increase,
and that they be evaluated as
c
umulative, ongoing impacts.
• Add
itional p
otentiall
y high d
iesel e
missions f
rom portable diesel equipment dur
ing
tempor
ary terminal activities previously described a
nd not evaluated in the ND (e
.g. E
quilon)
would
add to already too-high
local cumulative impacts.
• I
mpacts due to cumulative hazards from f
ires a
nd r
isks d
ue to earthquakes, tsunami,
an
d general industrial m
alfunctions,
include e
xplosions
, s
preading fires, spills, and
h
eavy smoke c
ausing h
igh leve
ls of PM2.5. The
City of Los Angeles a
lso identif
ied f
or the
r
egion that f
ire risk from earthquakes could c
ause s
preading c
onflagrations, made
worse by
br
oken fire-f
ighting infrastructure s
uch as water pipes, and gridlock.56 The
World Oil Project
a
dds significantly to s
uch cumulative hazards in the region, because such disasters can cause mul
tiple fires a
nd multiple demands on emergency resources, making
individual project risks
wor
se. Othe
r new Projects (including the new Marathon crude oil tanks) must also be e
valuated
cumulatively for these risks.
55 S
CAQMD, Notice of Determination, Tesoro LARIC including storage tanks, Nov. 5, 2019, ht
tps://www.aqmd.gov/docs/default-s
ource/ceqa/notices/notices-of-de
cision-or-d
etermination/2019/tesoro-l
aric---nod-
(oc
tober-2019)
.pdf?sfvrsn=6
56 F
or exa
mple, the City of LA, Emergency Operations Plan, Earthquake, Hazard Specific Annex, p. 12 [“F.
Fire Following
Ear
thquake:
It is anticipated that earthquakes in urban areas may cause major fires. In areas of dense woodframe c
onstruction, t
hese fires may gr
ow quickly to involve tens or hundreds of City blocks, known as conflagrations. The fire r
isk will be exacerbated due to damage to the water distribution system and possibly by traffic gridlock and blocked or dam
aged roadways. W
eather and building density
will also play a factor in the rate with which fires spread f ollowing an
e
arthquake. In particular, an earthquake during Red Flag conditions, can magnify the danger of conflagration. Tens and e
ven hundreds of City blocks could potentially be lost to fire f ollowing earthquake.”]
ht
tps://emergency.lacity.org/sites/g/files/wph496/f/Earthquake%20Annex%202018.pdf APPX_000437
31 • S
ince the new tanks are owned by World Oil,
the potential throughput to the World Oil
r
efinery in southeast Los Angeles must also be evaluated. As stated earlier, no pe
rmit
c
ondition was identif
ied l
imiting the overall R
ibost (World Oil) ter
minal
throughput.
The
ne
w tanks’ pe
rmitted throughput of 150,000 bbls/month would
be a
dditional feedstocks
a
vailable to be
utilized in the World Oil refinery (
as well as by other refiners including
M
arathon / T
esoro). T
he Project needs to provide an evaluation regarding r
elated projects in
W
orld Oil or other refineries whic
h would
e
nta
il in
creased r
efinery throughput using thi
s
c
rude oil. T
his would r
equire evaluation of
the ne
w tanks as part of any larger refinery
pr
oject.
Gre
enhouse gas emissions (
GHGs such as CO2 and others) ar
e als
o c
umulatively significant.
T
hese a
re a
lready very high in
this area due
to e
xtraction, transport, p
rocessing and c
ombustion of
hydr
ocarbons
fossil fuels (
crude oil, gasoline, diesel, etc.).
The
Project adds c
umulatively to
the
a
lready-high GHG im
pacts by
allowing an additional 150,000 barrels per month of fossil fuel feedstock thr
oughput (
which is explicitly allowed by the AQMD permit, a
nd whic
h doe
s not limit the overall
ter
minal throughput)
. T
he ND states that terminal throughput would not increase, bu t identifies no
pe
rmit requirement which would enforce this general statement. T hese P
roject tanks provide new
inf
rastructure to accommodate fossil fuel f
eedstocks
for the purpose of either refining them int
o products
that
will be combusted, or
directly used a
s fuels that will be combusted.
In
either case, they wil
l cause
C
O2 e
missions, adding to the cumulative im
pacts in the
region. Othe
r new tanks and Projects in the
r
egion must also be evaluated cumulatively.
T
hese emissions are not
being r
educed by the State’s Cap and Trade program (see below), in fact,
s
uch permitting is expanding in
the region de
spite the urgency of climate impacts. W
CWLB include
s 5
major
oil refineries (Marathon / Tesoro’s Wilmington and Carson refineries, Phillips 66’s Wilmington
a
nd Carson refineries, and the Valero Wilmington refinery), many storage tank farms and terminals
whic
h provide the fossil fueled feedstocks, a
major oil field (the Wilmington Oil Field)
, a
nd the
largest
por
ts complex in the nation. T
his region
represents the highest concentration of fossil fuel processing on the
West Coast,
and these facilities frequently expand. The c
umulative impacts s
hould be evaluated i
n
the
ND,
notwithstanding the unusual pandemic year that temporarily reduced such permitt ing.
Alar
ming climate impacts are we
ll-doc
umented a
nd urgent.
One
recent a
rticle publi
shed by
Yale
r
egarding NO
AA and NASA r
eports showed f
ive e
xtreme weather events caused bil
lion-doll
ar disasters
globally
in October a
lone thi
s year, including dis
astrous wildf
ires, hurricanes, and flooding, as well as
r
ecord temperatures.57 (
The billion-doll
ar description doesn’t cover the human and environmental c osts,
it
is only
meant to ill
ustrate that the e
conomic scope is
major.
) M
any scientis
ts have warned that we
mus
t act soon to
meet climate goals necessary to avoid the worst climate disasters, a s S
cienceNews ha
s
r
eported:58
.
. . the United Nations' Intergovernmental Panel on Climate Change released a r
eport de
scribing what it
w
ould take to keep global temperatures from rising more than 1.5 degr ees Celsius, a goal of the Par
is
c
limate agreement.
The report explained that countries would have to cut their anthropogenic carbon di
oxide emissions . . . to ne
t zero by around 2050. T
o reach that goal . . . CO2 emissions would have to
57 F
ive global billion-dol
lar weather disasters in October ht
tps://yaleclimateconnections.org/2020/11/october-202
0-w
as-
fourt
h-w
armest-o
ctober-on-r
ecord-no
aa-a
nd-n
asa-r
eport/
58 A
ug 27, 2019, https://insideclimatenews.org/news/27082019/12-y ears-c
limate-c
hange-e
xplained-i
pcc-sc
ience-s
olutions
APPX_000438
32 st
art dropping "well before 2030" and be on a p
ath t
o fall by about 45 percent by around 2030 . .
.
(
emphasis added)
B
ut instead, the
World Oil Project is a
dding new fossil fuel infrastructure without basic ne
cessary
e
valuation on
climate impacts. T
hese cumulative impacts must receive due attention in the ND.
Re
garding the State’s m
ain device for c
utting o
verall in
dustrial GH
Gs (Cap & Trade) –
Calif
ornia has fou
nd it
s p
olicy is
not making progress.
The
refore loca
l permitting and environmental
r
eview is even more essential, to prevent increased impacts. I n the 2017-2018
budget of the State of
C
alifornia, the L
egislative Analyst’s Office (LAO)
LAO stated: “T
he cap is likely not having much, if
an
y, effect on overall emissions in the first several years of the program.”59 L AO found that
the 2008
r
ecession & other policies (f
or example, the State’s Renewable Portfolio Standard for e lectricity)
, were
r
esponsible for reducing Greenhouse Gases (GHGs)
, not
Cap & Trade. Only
Electricity had s
ubstantial
e
mission c
uts that
were not
related to the recession.
T
he updated GHG inventory published in
2020
(for 2018 da
ta) s
howed the same p
roblem -
n
o reduction in in
dustrial GHGs (a
s s
hown in
C
ARB’s c
hart at
right)
. Transportation
e
missions went down slightly compared to 2017,
but
were still significantly higher than previous
ye
ars (2011- 2015)
. Once more, the electricity
s
ector was the only one which s
howed s
ubstantial
pr
ogress.
Other sector e
missions
went up.
T
he largest industrial sector contributing
t
o GHGs in California is Oil Re
fining,
which is
in
herently connected with the use of the World
Oi
l storage tanks.
C
alifornia’s GHG inventory is
available
onli
ne. I
reviewed and downloaded data from the
C
ARB we
bsite f
or the WCWLB area, below.60
T
he top GH
G emitters in
the AQMD Air Basin are alm
ost e
ntirely in
the WCWLB area, an
d
ar
e d
ominated by oil refining and related facilities (
which includes hydrogen production used in oil
r
efining). T
esoro (now Marathon), which leases fr
om World Oil, is notably the top emitter in the region
(
and also the top in the state). This sector (which includes the World Oil Project) heavily impacts r
egional and state GHG emissions; the Project needs cumulative impact analysis within this context.
59 T
he 2017-2
018 Budget, Cap and Trade, California LAO, https://lao.ca.gov/Publications/Report/3553 60 Y
ear 2018, industrial sources, Wilmington, Carson, Long Beach, Total GHGs, (This is filtered from all sites in the AQMD Ba
sin, choosing the
highest Total GHG emitters, in units of million metric tons per year).downloaded 11/17/2020 from ht
tps://ww3.arb.ca.gov/ei/tools/pollution_map/
APPX_000439
33 Fa
cility P
rimary Sector T
otal GHG
T
esoro Refining & Marketing Company LLC - C
arson /
Wi
lm. (now Marathon) Refi
nery 6
,367,797
C
hevron - E
l Segundo Refinery, 90245 Refi
nery 3
,398,468
T
orrance Refinery Refi
nery 3
,049,473
P
hillips 66 Wilmington Refi
nery Refi
nery 1
,923,613
U
ltramar Inc - Val
ero Wilmington Refi
nery 1
,070,130
P
hillips 66 Carson Refi
nery Refi
nery 9
36,704
A
ir Products Wilmington Hydrogen Plant H
ydrogen Plant 8
09,984
A
ir Products C
arson Hydrogen Plant H
ydrogen Plant 7
29,776
A
ir Liquide El Segundo Hydrogen Plant H
ydrogen Plant 5
74,150
T
esoro Wilmington Calciner O
ther Combustion Source 2
82,971
C
alifornia Resources Production Corporation – L
ong Beach O
il and Gas P
roduction 2
76,431
T
he WCWLB CERP also found that refineries are f
requently the
largest source of
criteria pollutants,
e
ven though the a
rea has extreme diesel trucking emissions, due to the Ports complex. T hese pollutants
a
re emitted at the same time as GHGs. The CERP f
ound regarding refineries and related petroleum
mar
keting (including
terminals):61
o VOCs
– “
The largest contribution to VOC emissions are from p
etroleum production
an
d marketing,
due to presence of several petroleum refineries in this community.” * o P
M2.5 – F
ine particulate matter c
omes mostly from in
dustrial and petrochemical
pr
ocess fuel combustion. (PM2.5 causes premature deaths for vulnerable people.) o NOx – P
etroleum refinery operations are the 2nd largest source, (including sulfur
r
ecovery and hydrogen plants). Oce
an-goin
g vesse
ls are the largest (a
nd thes
e include
many
oil industry vessels delivering crude oil to refineries.) De
spite all of the above, the
ND finds C
umulative Impacts are less than significant (
page 4-65).
I
dis
agree with every statement in this paragraph, be
caus
e of the pr
oblems which I
list be
low.
Although
the proposed project has impacts that were determined to be less than significant that may
incrementally affect other resources, they are not considered cumulatively considerable due to
the relatively nominal
level and area of impact, highly de
veloped industrial surroundings, and
tempor
ary nature of the proposed project. Generally, c
ontributions to air quality and greenhouse
ga
s emissions impacts are cumulative due to the regional and global nature of air poll ution and
c
limate change, respectively. .
. . T
he proposed project, as well as all other current projects in the r
egion, would comply with applicable SCAQMD standards, recommendations, and regulations, whic
h are designed to limit air quality impacts wit
hin its jurisdiction, as well as State laws. As
s
uch, all potential cumulative impacts regarding air quality and greenhouse gas emissions would be
limited and minimized. The construction activities are minor and would be completed within a
pproximately 10 mont
hs. Operational activities would not substantially change. As such, the pr
oposed project’s cumulative impacts are considered less than significant.
61 S
CAQMD air emissions inventory for the WCWLB Com
munity Emission Reduction Plan ,
Sept. 2019, WCWLB CERP,
V
OCs: (p. 3b-6
), PM2.5 (p. 3b-3)
, NOx (p. 3b-2)
APPX_000440
34 F
irst, the highly industrialized area of the ports is also s urrounded by tens
of thousands of residents
ve
ry nearby in W. Long Beach and Wilmington,
and as described earlier, the communities are heavily
im
pacted by the c
umulative impacts of indus
trial a
ir pollution. I
could document this through
C
alEnviroScreen populations on a census tract basis, but this is a basic fact which the environmental
r
eview itself should correct.
S
econd, workers at other commercial operations in the area are also he avily im
pacted by cumulative
poll
ution impacts.
T
hird,
the ND focused on construction impacts and minimized the signif icance of
ope
rational
e
missions, which are significant a
nd ongoing (not temporary).
F
ourth,
compliance with existing regulations and laws do not
prelude a
project causing s
ignificant
e
missions.
If they did, the region would not be in extreme non-a
ttainment
with Clean Air Act health
s
tandards. Ne
ither would
this area include the
high levels of cancer-c
ausing air emissions which are
c
umulatively pr
esent. T
his is again basic information well known to the ports and AQMD.
E
nvironmental analysis provides an a
dditional layer of protection, to identif
y the potential for
de
terioration due
to ne
w projects.
I
n addition, the Port itself lists a large number of
P
rojects that should have been evaluated as part of a
C
umulative Impacts analysis. They include a
t least
the
s
even listed to the right, which is a screen capture from the
Port of Long Beach website Environmental
Doc
uments page.62 Nor
mally a lead agency will
identif
y other projects such as those to the right at the
P
orts, as well as others in the area (such a
s the Tesoro
c
rude oil tanks identified above), which are part of
s
ignificant new cumulative impacts in the region. I
did
not
see any such list in the ND.
VI
. Conclu
sion - T
he Negative Declaration is inadequate, potential impacts are significant an
d extens
ive, and d
etailed environmental as
sessment is necessary
I
n conclusion, the ND does not establish that there would be no significant impacts from the Project, doe
sn’t evaluate many key issues or inadequately evaluates others. The evidence shows that the Project ha
s the potential for many significant impacts, req
uiring in depth evaluation.
62 P
ort of Long Beach, s
creen capture, 11/17/2020. ht
tps://www.polb.com/documents/#ceqa-ne
pa
APPX_000441
35 At
tachments
Attac
hment 1 - R
esume of
J
ulia E
. M
ay,
Senior Scientist, CBE
Attac
hment 2 - E
xcerpt Dr. Sahu T
esoro Savage Te
stimony on
Tanks
APPX_000442
36 A
TTACHMENT 1
Ju
lia E. May,
S
enior Scientist
j
[email protected]
E
xperience
1989-p
resent Energy and Industrial Air Pollution Engineering Evaluation
– O
il Refinery, industrial air pollution source evaluation including criteria pollutants, toxics, greenhouse ga
ses, pollution prevention methods and engineering solutions. – R
esearch best
and worst industrial practices, chemical and fossil fuel phaseout methods, policy, and t
echnologies.
– Eva
luation of energy issues including electricity planning, natural gas and coal-f ired power plant
pe
rmitting and impacts, transmission and reliability i
ssues, alternative energy and policy options.
– A
nalyzing permit language, conditions, emissions and air monitoring data; compiling health and e
nvironmental impacts data. Evaluation regulatory compliance with environmental laws. Negotiating pr
actical issue
s of regulation with industry and government agencies to craft health-pr otective policy and
r
egulatory language.
– Tr
anslating inaccessible technical information into lay language and educational materials. Providing t
echnical assistance and cumulative impa
cts analyses to communities facing severe pollution burdens.
A
ssisting communities and workers in achieving environmental health protections in permitting and pol
icy.
– Ma
naged science department for statewide environmental organization (CBE). Hired by regul atory
a
gency as technical advisor to identify feasible air pollution control methods not previously adopted, and t
o assist communities submitting comments during regulatory proceedings.
E
ducation
1981 B
.S. Electrical Engineering,
University of Michiga
n, Ann Arbor
P
roject examples:
– Eva
luation of pr
oposed refinery, oi
l extraction, a
nd pipeline e
missions, i
mpacts, pe
rmitting a
nd regulation
i
n California since 1989, including Northern and Southern California refineries. Eva luation r
elati
ng to
c
rude oil f
eedstock i
ncluding C
anadian tar sands a
nd North Dakota Bakken c
rude oil nationally. Oil
dr
illing operations, air impacts, in residential Los Angeles ne ighborhoods.
Pipeline transport impacts of
c
rude oil, hydrogen, and other oil industry feedstocks in California and Midwe st. Evaluation of coal
ga
sification plant emissions.
– Eva
luation of California Long Term Procurement Planning in 2010-2014 (electricity planning) and
C
alifornia power plant permitting, reliability requirements and low carbon solutions, transmission issues, e
nvironmental impacts, local and system capacity needs, quantification of available renewable and energy st
orage resources.
– D
evelopment of model California oil industry criteria pollutant regulation, and proposed greenhouse gas r
egulation and alternatives analysis, including flares, pressure relief devices, storage tanks, fugitive c
omponents, marine loading, and others. (1990s t
o present)
APPX_000443
37 Posi
tions
2004- pr
esent
S
enior Scientist, Communities for Better Environment and In
dependent Environmental Consultant – E
nergy Use / Industrial pollution quantification / Alternatives a
nalysis, engineering analysis of proposed and existing industrial permits, analysis of statewide goals and energy pl
anning, e
nvironmental pol
icy analysis. Analysis of impacts and solutions to envi ronmental problems including
t
rends in fossil fuel use, renewable energy, oil industry feedstocks, associated equipment changes, emissions of c
riteria pollutants, toxic emissions, and greenhouse gases. Technical consultant in community campaigns on i
ndust
rial regulation. Geographic areas including Southern California, N orthern California, and multiple U.S.
st
ates and tribal areas.
2001-2003 S
tatewide CBE Lead Scientist, CBE, O
akland, CA
R
esponsible for team providing e
nvironmental t
echnical evaluation i
n comm
unity and environmental law
e
nforcement campaigns. Eva
luation of electric power plant expansion air emissions in communiti es of
color with
hi
gh asthma rates: identification of alternatives to fossil fueled plants, including conservation, renewables ge
ne
ration, a
nd i
mproved transmission, in California Energy Commission proceeding. Analysis a nd
r
ecommendations for regulation in Bay Area Ozone Attainment Plan (flares, pressure relief devices, wastewater ponds,
storage tanks, others) which were ultimately ado
pted. Evaluation of Environmental Impact Reports and
Tit
le V permits for refineries and chemical plants, including emissions, community impacts, alternatives.
S
uccessfully assisted negotiating Good Neighbor Agreements by identifying technical solutions to e nvironmental
vi
olations to bring facilities into compliance.
1990-2001 C
lean Air Program Director, Northern California Region, CBE A
nalysis of permits, regulation, air pollution inventories and other emissions information for oil refinery, power pl
ant,
cement kiln, smelter, dry cleaner, consumer product, lawn mower, mobile source, and other air pollution sour
ces, neighbor and worker health impacts, with pollution prevention policy development. Successfully a
dvocated for national models of oil refinery r
egulation. Evaluation and documentation of root causes of i
ndustrial chemical accidents as part of community campaigns for industrial safety. Technical assistance to c
ommunity members negotiating Good Neighbor Agreements with refineries. Evaluations towards adoption of
pol
icies eliminating ozone depletors in favor of alternatives.
1987-1990 R
esearch Associate, CBE
C
ampaign with maritime workers and refinery neighbors for adoption of stringe nt o
il refinery marine loading
va
por recovery regulation, which beca
me statewide and national model. Member of technical working group at B
AAQMD evaluating emissions, controls, safety, and costs. Also school pesticide analysis, successful policy c
ampaign for integrated pest management on school grounds.
1986 A
ssistant Ed
itor of appropriate technology publication, Rain Magazine, Portland, OR
P
roduction of publication on innovative energy and environmental success models around the U.S. and the world.
C
ompiled, co-e
dited, wrote, and provided production for non-pr
ofit publi
cation.
1981-1985 E
lectrical Engineer, National Semiconductor Corp., Santa Clara, CA Ele
ctronics engineering design team member for analog-to-di gital automotive engine controls for reducing air
e
missions. Troubleshooting hardware and evaluating fault-ana lysis software efficacy.
APPX_000444
38 A
TTACHMENT 2
E
xcerpt,
Dr
. Sahu
T
esoro Savage Te
stimony,
S
torage T
anks Unde
restimation
APPX_000445
Attac
hment - Dr
. Sahu Transcript excerpt:
APPX_000446
APPX_000447
APPX_000448
APPX_000449
APPX_000450
APPX_000451
APPX_000452
APPX_000453
APPX_000454
APPX_000455
APPX_000456
APPX_000457
APPX_000458
APPX_000459
APPX_000460
APPX_000461
APPX_000462
APP
ENDIX B
APPX_000463
APPX_000464
APPX_000465
APPX_000466
APP
ENDIX C
APPX_000467
APPX_000468
APPX_000469
APPX_000470
APP
ENDIX D
Document not attached, available for viewing and download at https://earthjustice.sharefile.com/d-s5312b425ff2c44f2a0c0415cd0f45d4a APPX_000471
A
PPENDIX E
Document not attached, available for viewing and download at https://earthjustice.sharefile.com/d-s5312b425ff2c44f2a0c0415cd0f45d4a APPX_000472
APP
ENDIX F
APPX_000473
1 R
eport on Bakersfield Crude Terminal Permits to Operate
P
hyllis Fox, Ph.D., PE
1 2/24/2014
TABLE OF CONTENTS
INTRODUCTION ...........................................................................................................................2
THE BAKERSFIELDS CRUDE TERMINAL SHOULD HAVE BEEN PERMITTED AS A MAJOR SOURCE ................................................................................................................. 4 I. VOC Emissions Round Up To The Major Source Threshold .............................................5 II. Terminal VOC Emissions Were Underestimated ................................................................6 A. Roof Landing, Degassing, and Cleaning Emissions Omitted ..................................6 B. Pipeline Cleaning Emissions Omitted .....................................................................9 C. Tank Flashing Emissions Omitted .........................................................................10 D. Water Draw Tank Emissions Omitted ...................................................................10 E. Pump Pit Emissions Were Omitted........................................................................11 F. Sump Tanks and API Separator Emissions Were Omitted ....................................11 G. Cargo Carrier Emissions ........................................................................................12 H. Stationary Combustion Sources .............................................................................13 III. Permit Conditions Are Not Enforceable ............................................................................14 A. Tank Permit Conditions Are Not Enforceable .......................................................14
1. Vapor Pressure (RVP)................................................................................15
2. VOC Emission Calculation ........................................................................18
3. Fixed Roof Tanks Are Required ................................................................20 B. Unloading Rack Permit Conditions Are Not Enforceable .....................................21
1. Disconnect Emissions ................................................................................21
2. Fugitive Emissions .....................................................................................23
3. Other Unloading Emissions .......................................................................25
4. Loading Into Tanker Trucks ......................................................................25 IV. Reporting Requirements Are Not Adequate To Assure Compliance ................................25
APPX_000474
2 INTRODUC
TION
On Ma
y 16, 2012, Bakersfield Crude Terminal, LLC (“Applicant”) submitted an Applica
tion for an Authority to Construct (“ACT”) permit (“2012 Application”) for the B
akersfield Crude Terminal (“Terminal”) to the S
an Joaquin Valley Air Pollution Control
Dist
rict (“the District”).1 The Appli
cant requested expedited processing and worked with the Dist
rict to reduce emissions below the major source threshold for volatile organic compounds (V
OCs) to avoid Title V permitting and below the daily threshold to avoid public notice. The
Author
ities to Construct were issued July 31, 2012 for two 150,000 ba rrel (bbl) internal floating
roof
crude oil storage tanks and an organic liquid transfer operation with light crude oil railcar
unloading
rack and associated offloading, transfer and booster pumps.2
The
proposed Terminal consisted of
two rail spurs to receive and offload up to two unit
tra
ins per day of 104 rail cars each, two 150,000-barrel internal-floating-roof tanks t o store the
c
rude oil, a light crude oil unloading rack that individually unloads each car, and c onnecting
pipelines. The
loading rack was proposed to be 1800 feet by 44 feet wide and include 15 pump pit
s with pumps designed to be connected to four ra
ilcars each. The pumps were to be evenly
dist
ributed along the entire length of the loading rack so 120 rail cars could be simultaneously unloade
d at full buildout.3
1 HDR, Authority to Construction Application Package, Bakersfield Crude Terminal, LLC, Taft, CA, May 2012 (“2012 Terminal Application”).
2 SJVAPCD, Authority to Construct Permit Nos.: (1) S-8165-1-0 (150,000 bbl internal floating roof tank); (2) S- 8165-2-0 (150,000 bbl internal floating roof tank); (3) S-8165-3-0 (liquid transfer operation with railcar unloading rack and associated offloading, transfer and booster pumps), July 31, 2012. 3 E-mail from Joe Henderson, RPMS Engineers, to Michael C. Ernst, SJVAPCD, Re: Follow-up on Tank Questions for Crude Oil Terminal, June 25, 2012; E-mail from K. Rickard to K. Thao, Re: RO RMR Project for Bakersfield Crude, June 25, 2012.
APPX_000475
3 Figure 1 - Facility Design
The
Facility was to be designed fo
r a maximum throughput of 168,000 bbd/day or
61,320,000 bbl/
yr. The proposed maximum combined throughput for both tanks was 168,000 bbl/
day or 25,550,000 bbl/yr. The balance of the crude oil (61,320,000 – 2 5,550,000 =
35,770,000 bbl/
yr) would bypass the tanks and be delivered directly to the pipeline.4 The
Applica
tion identified a new 1.5 mile pipeline segment to connect the Facility with an existi ng
pipeline, Pl
ains Line 1.5 The oil characteristics were described as having an API gravity of
43.3o and a Reid Vapor Pressure (RVP) of 8.3 psia.6
P
lains Marketing, L.P. acquired all of the assets, including the name, of the Bakersfield C
rude Terminal LLC (BCT) and on March 18, 2013, re-subm
itted the ATC Application, without
a
ny changes, to transfer the title to Plains.7
4 E-mail from Michael C. Ernst, HDR Inc. to Ashley Dahlstrom and Clint Meyer, SJVAPCD, Re: Additional Information Required, June 1, 2012.
5 Kern County Planning and Community Development Dept., Notice of Intent to Adopt a Mitigated Negative Declaration for 5568TT; Nonexclusive Franchise Pipeline Agreement (Bakersfield Crude Terminal Pipeline Project by Bakersfield Crude Terminal, LLC (PP14145), March 27, 2014, pdf 119. 6 2
012 Application, p. 1 & Attachs. B & C.
7 Letter from Glen Mears, Plains Marketing, L.P., to Leonard Scandura, SJVAPCD, Re: Authority to Construct Application Bakersfield Crude Terminal, LLC, March 18, 2013 APPX_000476
4 On Septe
mber 8, 2014, Plains LPG Services, L.P, submitted an application for an Author
ity to Construct for four fixed roof tanks and an oil/water separator ( Tanks/Separator
Applica
tion), to be located at the Terminal. The Air District concluded that the a ddition of this
ne
w equipment did not increase emissions of VOC above the new source threshold, a s their
e
missions were excluded using a District rounding policy (APR 1130).8 The District issued
ATCs for the new equipment on September 23, 2014.9
On O
ctober 16, 2014, Plains Marketing, L.P. submitted an application for an Authority to C
onstruct for installation of two 399-hp emergency diesel-fueled, fire water pumps.10 The Air
Dist
rict concluded that the addition of this new
equipment did not increase VOC emissions
a
bove the new source threshold or the daily public notice threshold. In its Application Review for
these fire water pump
s, the Air District modified potential to emit calculations that it pr
eviously relied on to i
ssue the July 13, 2012 Authorities to Construct for the Terminal, c
laiming fugitive emissions did not have to be included.11
T
HE BAKERSFIELDS CRUDE TERMINAL SHOULD HAVE BEEN
PERMITTED AS A MAJOR SOURCE
The
Bakersfield Crude Terminal emits volatile or
ganic compounds (VOCs) from tanks;
e
quipment leaks from valves, pumps, and connectors (fugitive emiss ions); and disconnect losses,
a
s well as other sources not included in the District’s analysis. To qua lify as a minor source,
VOC
emissions must be less than 20,000 lb/yr.12
The
District’s July 25, 2012 Application Review13 e
stimated volatile organic compound
(V
OC) emissions from two new 150,000 barrel internal floating roof c rude oil storage tanks and
a
n organic liquid transfer operation consisting of a ra
ilcar unloading rack and associated
of
floading transfer pipelines and booster pumps. The VOC emissions include d in the District’s
c
alculations a
rise from tank breathing and working losses, fugitive components (valves, pump se
als, connectors), and disconne
ct losses. The emissions were estimated as summarized in Table
1. 8
SJVAPCD, Authority to Construct Application Review, Fixed Roof Tanks, September 20, 2014 (September 2014 Application Review).
9 SJVAPCD, Authority to Construct Permit Nos.: (1) S-8165-9-0 (24 bbl fixed roof sump tank); (2) S-8165-10-0 (24 bbl fixed roof sump tank); (3) S-8165-11-0 (24 bbl fixed roof sump tank); (4) S-8165-12-0 (24 bbl fixed roof sump tank); (5) S-8165-13-0 (20,000 gallon oil/water separator). 10 Letter from Glen Mears, Plains Marketing, L.P., to Leonard Scandura, SJVAPCD, Re: Authority to Construct Application Bakersfield Crude Terminal, LLC, October 16, 2014. 11 SJVAPCD, Authority to Construct Application Review, Diesel-Fired Emergency Firewater Pump IC Engine, November 13, 2014 (November 2014 Application Review).
12 Regulation 2201, Sec. 3.24.1.
13 SJVAPCD, Authority to Construct Application Review, July 25, 2012 (“7/25/2012 Application Review”).
APPX_000477
5 T
able 1
B
akersfield Crude Terminal VOC Emissions (ton/yr)
Po
tential to Emit Calculation from 7/25/2012 Application Review, p. 8
I. VOC
Emissions Round Up To The Major Source Threshold
I
f VOC emissions equal or exceed 20,000 lb/yr, the facility is a major source.14 The
e
missions from the Terminal were reported by the District to be 19,992 lb/yr.15 This value
round
s up to 20,000 lb/day. Thus, the Terminal should have been permitted as a major source in 2012.
The
VOC emissions of 19,992 lb/yr were c
alculated from a number of inputs, which were
a
ll reported to only two significant figures, e.g., crude density of 7.1 lb/gal; disconnect volume of
3.2 m
L per disconnect; valve emission factor of 4.3E-05 kg/hr; RVP = 8.3 psia. How ever, the
re
sults of the emission calculations is reported to five significant figures, viz., 19,992 lb/yr. I f the
c
orrect number of significant figures had been used in the VOC emission calcula tions, the VOC
e
mission increase would equal 20,000 lb/yr, classifying the source as major. The District did not
follow standa
rd procedures for reporting results of calc
ulations, taught in basic math, statistics
a
nd science courses and EPA air pollution courses.
The number of significant figures is simply the number of figures that are known with some de
gree of reliability. It is well established among professional engineers and scientists that the r
esult of a calculation should be written with no more than the smallest number of significant fig
ures of any of the factors included in the calculation, viz., “The product often has a different pr
ecision than the factors, but the significant figures must not increase.”16 This is standard practice throughout the engineering and scientific professions.17 This rule is taught in EPA air
14 District Rule 2201, Sec. 3.24.
15 7/25/12 Application Review, p. 6.
16 E
.A. Avallone and T. Baumeister III (Eds.), Marks’ Standard Handbook for Mechanical Engineers, 10th E d.,
Mc
Graw-Hill, New York, 1996, p. 2-4.
17 See, e.g., Philip R. Bevington, Data Reduction and Error Analysis for the Physical Sciences, McGraw-Hill, Inc., 1 969, pp. 4, 9; Lothar Sachs, Applied Statistics. A Handbook of Techniques, 2nd Ed., Springer-Verlag, New York, 1 984, p. 21.
APPX_000478
6 poll
ution training courses.18
The EPA Manual instructs: "When approximate numbers are multiplied or divided, the result is expressed as a number having the same number of significant digits as the expression in the problem having the least number of significant digits. In other words, if you multiply a number having four significant digits by a number having two significant digits, the correct answer will be expressed to two significant digits. "19 The Air
District’s Guidance APR 1105, Guidelines for the Use of Significant Figures In Engineering Calculations is in accord. The Guidance instructs that “Rounding off is accomplished by dropping the digits that are not significant. The digits 0, 1, 2, 3, and 4 are dropped without altering the preceding digit. The preceding digit is increased by one when a 5, 6, 7, 8, or 9 is dropped.”
Thus, the results of the multiplications and additions used in the District’s emission calculations should have been rounded off to the same number of significant figures as the factor with the least number of significant figures, which is two. Therefore, the results of the annual VOC calculations should have been reported to no more than two significant figures, corresponding to the number of significant figures in the underlying factors used in the calculations, not to six significant figures, or 19,992. Rounding 19,992 to two significant figures yields 20,000 lb/yr. This equals the major source significance threshold for VOC, classifying the Terminal as a major source under Rule 2201, Sec. 3.24.
II. Terminal VOC Emissions Were Underestimated
The
7/25/12 Applica
tion Review underestimated total VOC emissions from the Terminal b
y a significant amount due to several errors and omissions. The emissions from the Terminal, whe
n operated at its maximum capacity based on its physical and operational design would e mit
more
than 20,000 lb/yr of VOCs and thus would be a major source. Operational and other li
mitations were imposed in the ATC permits in an attempt to reduce VOC emissions to 19,992 lb/
yr, just 8 lb/yr shy of the major source threshold. However, as explained below, the pote ntial
to emit
calculations did not include all sources of emissions, whic h are thus not limited in the
pe
rmits. Further, many of the conditions for emission sources that we re included in the potential
to emit
calculations are not enforceable as they do not include adequate monitoring or any re
porting.
A. Roof Landing, Degassing, and Cleaning Emissions Omitted
VOC emissions from the two new storage tanks were estimated using EPA’s TANKS
4.0.9d model (TANKS).20 However, this model only estimates rim seal losses, withdrawal losses, deck fitting losses, and deck seam losses. It does not estimate roof landing losses,
18 U.S. EPA, APTI Virtual Classroom, Course SI 100: Mathematics Review for Air Pollution Control, Available at:
Lesson 2 Significant Figures and Rounding off, Available at:
http://yosemite.epa.gov/oaqps/EOGtrain.nsf/DisplayView/SI_100_0-5?OpenDocument; and Lesson 2, Available at:
http://yosemite.epa.gov/oaqps/EOGtrain.nsf/fabbfcfe2fc93dac85256afe00483cc4/4939717614a0227e85256f400062 252e/$FILE/Lesson2.pdf.
19 EPA Manual, p. 2-5/2-6.
20 7/25/12 Application Review, Appx. E.
APPX_000479
7 inspection losses, or flashing losses. Thus, it underestimated tank emissions. These emissions should be estimated and added to other tank emissions.
The Project includes two new internal floating roof tanks. The new tanks could be constructed with a leg-supported or self-supporting roof. The TANKS model input in Appendix E
of the 7/25/12 Application Review indicates that the roofs are not self supported.21 In floating
roof tanks with leg-supported roofs, the roof floats on the surface of the liquid inside the tank and reduces evaporative losses during normal operations. However, when the tank is emptied, the roof sits on the legs and is essentially uncontrolled, resulting in high VOC emissions.
I
n February 2010, the EPA explained that the TANKS model does not include roof landings, and recommended that they be estimated with the equations in EPA’s Compilation of Air Pollutant Emission Factors (“AP-42”). In other words, the EPA TANKS model estimates evaporative emissions for normal operations only, i.e., it assumes that the floating tank roof is always floating.22 However, when a tank is emptied to the point that the roof no longer floats on the liquid but lands on deck legs, evaporative losses occur.
Af
ter the floating roof is landed and the liquid level in the tank continues to drop, a vacuum is created which could cause the floating roof to collapse. To prevent damage and to equalize the pressure, a breather vent is actuated. Then, a vapor space is formed between the floating roof and the liquid. The breather vent remains open until the roof is again floated, so whenever the roof is landed, vapor can be lost through this vent.
23 The
se losses are called “roof landing losses.”
I
n addition, “degassing and cleaning losses” occur when tanks are drained and degassed for inspection and/or cleaning. These include both roof landing emissions, complete tank degassing, and emissions from cleaning out accumulated sludge. These emissions are essentially u
ncontrolled tank emissions.24
The
EPA recommends methods to estimate emissions from degassing and cleaning and roof landing losses.25 The method for estimating emissions depends on the construction of the tank, e.g., the flatness of the tank bottom and the position of the withdrawal line (the so-called liquid “heel”). De
gassing and cleaning and roof landing losses continue until the tank is refilled to a sufficient level to again float the tank roof. Total VOC emissions from floating roof tanks
21 See, e.g., 7/25/12 Application Review, Appx. E, 6/27/12 run, p. 1 of 5. (Self Supp. Roof? (y/n) = N). 22 EPA, TANKS Software Frequent Questions, Updated February 2010; h
ttp://www.epa.gov/ttnchie1/faq/tanksfaq.html. (“How can I estimate emissions from roof landing losses in the tan
ks program? … In November 2006, Section 7.1 of AP42 was updated with subsection 7.1.3.2.2 Roof Landings.
The TANKS program has not been updated with these new algorithms for internal floating roof tanks. It is based on the 1997 version of section 7.1.”).
23 EPA, AP-42, Chapter 7.1 Organic Liquid Storage Tanks, November 2006; h
ttp://www.epa.gov/ttn/chief/ap42/ch07/final/c07s01.pdf.
24 See EPA guidance on estimating these emissions at: h ttp://www.epa.gov/ttnchie1/faq/tanksfaq.html#13
.
25 “How Can I Estimate Emissions from Degassing and Cleaning Operation During a Tank Turnaround? And How Can I Estimate Emissions from Roof Landing Losses in the TANKS Program:?”, Available at:
h
ttp://www.epa.gov/ttnchie1/faq/tanksfaq.html#13
.
APPX_000480
8 during
a roof landing is the sum of standing idle losses and filling losses. They can be estimated using formulas contained in EPA’s Compilation of Air Pollutant Emission Factors (“AP-42”), Chapter 7.1, Organic Liquid Storage Tanks, Section 7.1.3.2.2. These emissions are routinely included in emission inventories, tank emission potential to emit calculations, and are limited in permits.26 They are required to be reported, for example, in Texas.27 They are also included in the e
mission inventory of crude oil terminals.28
Ta
nk roof landing emissions are large, typically comprising about 40% of total tank emissions. Thus, for the subject tanks, roof landing emissions alone could be 6,300 lb/yr. This is sufficient to classify the Terminal as a major source, just based on VOC emissions from the tanks.
Tank permit Condition 8 addresses roof landing emissions, but does not limit them. It only requires that “[w]hen the roof is resting on the leg support, the process of filling, emptying, or refilling shall be continuous and shall be accomplished as rapidly as possible.” “As rapidly as possible”
does not limit VOC emissions in an enforceable manner. Further, this condition also requires that “[w]henever the permittee intends to land the roof on its legs, the permittee shall notify the APCO in writing at least five days prior to performing the work.” Similarly, notifying the District does not control VOC roof landing emissions.
Tank Permit Condition 34 additionally requires the permittee to maintain records of roof landing activities, but only those performed pursuant to Rule 4623, Sections 5.3.1.3 and 5.4.3.
These records only have to be “maintained.” There is no requirement that the records be reported to the District. Maintaining records does not limit VOC emissions. Further, the failure to report the records
to the District limits the District’s and affected parties’ ability to estimate roof landing emissions to determine if emissions are large enough to qualify the Facility as a major source.
If the facility wishes to be a minor source, it should be required to control total tank emissions
enough to reduce Terminal VOC emissions below the major source threshold.
Emissions from degassing, cleaning, and roof landing losses can be reduced by greater than 95% by modifying the design of the tanks to include self-supporting roofs or to use external floating roof tanks, equipped with geodesic domes.
Geodesic domes are feasible, satisfy best available control technology (BACT), and are widely used. Over 10,000 aluminum domes have been installed on petrochemical storage tanks
26 See, e.g., Enbridge, Superior Terminal Enhancement Project Permit Application, October 9, 2012, pp. --, Tables 1-1 and 2-2 and Wisconsin Dept. of Natural Resources, Air Pollution Control Construction Permit No. 12-DCF-205, EI Facility No. 816010580, Enbridge Energy Co., Superior, Wisconsin, May 21, 2013 27 Memorandum from Dan Eden, Deputy Director, Office of Permitting, Remediation, and Registration; David C.
Schanbacher, Chief Engineer; and John Steib, Deputy Director, Office of Compliance and Enforcement, Re: Air Emissions During Tank Floating Roof Landings, December 5, 2006, Available at:
h
ttp://www.tceq.state.tx.us/assets/public/permitting/air/memos/tank_landing_final.pdf .
28 See, e.g., Tesoro Savage, Application for Site Certification Agreement, Section 5.1.2.1.4, Available at:
h
ttp://www.efsec.wa.gov/Tesoro%20Savage/Application/EFSEC%202013-01%20Volume%20I/EFSEC%202013- 0 1%20-%20Compiled%20PDF%20Volume%20I.pdf
.
APPX_000481
9 in t
he United States.29 The ExxonMobil Torrance Refinery: “completed the process of covering all floating roof tanks with geodesic domes to reduce volatile organic compound (VOCs) emissions from facility storage tanks in 2008. By installing domes on our storage tanks, we’ve reduced our VOC emissions from these tanks by 80 percent. These domes, installed on tanks that are used to store gasoline and other similar petroleum-derived materials, help reduce VOC emissions by blocking much of the wind that constantly flows across the tank roofs, thus decreasing evaporation from these tanks.”
30 A tank c
rude storage capacity increase project, recently proposed at the Phillips 66 Los Angeles Carson Refinery, required external floating roof tanks with geodesic domes to store crude oil with an RVP of 11.
31 The ConocoPhillips Wilmington Refinery added a geodesic dome to an existing oil storage tank to satisfy BACT.32 Similarly, Chevron proposes33 to use domes on several existing tanks to mitigate VOC emission increases at its Richmond Refinery.34 The
U.S. Department of Justice CITGO Consent Decree required a geodesic dome on a gasoline storage tank at the Lamont, Texas refinery.35 Further, numerous vendors have provided geodesic domes for refinery tanks.36
B. Pipeline Cleaning Emissions Omitted
A “
pig” is a physical device used in pipelines during product transfer, product separation, and maintenance. The pig varies in size and shape and can be made of a variety of materials such as plastic, urethane foams, and rubber. Pigs can be solid, inflatable, foam, or made of a viscous gel.
The Terminal includes a “pig launcher area,”37 so pigging is anticipated and pigging emissions should have been included in the potential to emit calculations.
29 M. Doxey and M. Trinidad, Aluminum Geodesic Dome Roof for Both New and Tank Retrofit Projects, Materials Forum, v. 30, 2006, Available at:
h
ttp://www.materialsaustralia.com.au/lib/pdf/Mats.%20Forum%20page%20164_169.pdf . 30 Torrance Refinery: An Overview of our Environmental and Social Programs, 2010, Available at:
h
ttp://www.exxonmobil.com/NA-English/Files/About_Where_Ref_TorranceReport.pdf . 31 See, e.g., Phillips 66 Los Angeles Refinery Carson Plant – Crude Oil Storage Capacity Project, September 6, 2013, Table 1-1, Draft Negative Declaration, Available at:
h
ttps://www.aqmd.gov/CEQA/documents/2013/nonaqmd/Draft_ND_Phillips_66_Crude_Storage.pdf 32 SCAQMD Letter to G. Rios, December 4, 2009, Available at:
h
ttp://yosemite.epa.gov/r9/air/epss.nsf/e0c49a10c792e06f8825657e007654a3/e97e6a905737c9bd882576cd0064b56 a/$
FILE/ATTTOA6X.pdf/ID%20800363%20ConocoPhillips%20Wilmington%20- %2
0EPA%20Cover%20Letter%20%20-AN%20501727%20501735%20457557.pdf . 33 City of Richmond, Chevron Refinery Modernization Project, Environmental Impact Report, Volume 1: Draft EIR, March 2014 (Chevron DEIR), Available at: h
ttp://chevronmodernization.com/project-documents/
.
34 Chevron DEIR, Chapter 4.3.
35 CITGO Petroleum Corp. Clean Air Act Settlement, Available at: h ttp://www2.epa.gov/enforcement/citgo-
p
etroleum-corporation-clean-air-act-settlement.
36 See, e.g., Aluminum Geodesic Dome, Available at: h
ttp://tankaluminumcover.com/Aluminum-Geodesic-Dome;
L
arco Storage Tank Equipment, Available at: h
ttp://www.larco.fr/aluminum_domes.html;
Vacono Dome, Available
at: h
ttp://www.easyfairs.com/uploads/tx_ef/VACONODOME_2014.pdf ; P eksay Ltd., Available at:
h
ttp://www.peksay.info/oil_terminals/geodesic_domes.htm; United Industries Group, Inc., Available at:
h
ttp://www.thomasnet.com/productsearch/item/10039789-13068-1008-1008/united-industries-group-inc/geodesic- alu
minum-dome-roofs/;
37 1/17/2014 Application, Supplemental Information, p. 1 APPX_000482
10 Pigging following product transfer is used to remove residual product from the pipeline after loading occurs. Pigs can also be used for product separation when switching products in the lines, as well as for maintenance activities such as pipeline cleaning, gauging, or dewatering.
Pipeline blowdowns can occur during repair work or when lines are taken out of service. During pigging, a pig is inserted into the pipeline and forced through by a compressed gas, such as nitrogen. When the pig gets to the end
of the line, it is trapped in a receiver. The gas is bled off from behind the pig.
As the
pig travels through the pipeline, residual vapors are pushed through the line. If the vapors are not routed to a control device, typically a flare or incinerator, they escape through openings on devices
such as hatches, doors, or vents. Emissions can be significant, depending on the amount and vapor pressure of the product. Depending on the gas used to push the pig, the bleed
-off step can also emit significant amounts of VOC. Pigging vapors are commonly vented to a control device.38 The Application and Application Review do not disclose these emissions or identify any control method.
C. T
ank Flashing Emissions Omitted
Many of the cost-advantaged light crudes that the Terminal could import are transported raw, without stabilization, due to the lack of facilities in the oil fields. These unstabilized or “live” crude oils have high concentrations of volatile materials entrained in the bulk crude oil.
Tank
flashing emissions occur when these crude oils are exposed to temperature increases or pressure drops. When this occurs, some of the compounds that are liquids at the initial pressure/temperature transform into gases and are released or “flashed” from the liquid. These
emissions are in addition to working and breathing emissions from tanks and are not estimated by the EPA TANKS 4.0.9d model. These emissions can be calculated using standard procedures.
39 The VOC potential to emit calculations did not mention or calculate these emissions, nor do the tank permits include a permit condition that allows only stabilized crude oils to be received.
D. Wate
r Draw Tank Emissions Omitted
Crude oil typically contains small amounts of water, which is separated from the crude oil and accumulates in the bottom of storage tanks. This accumulated water, referred to as tank water draw, is typically transferred from the crude oil storage tanks into a smaller water draw surge tank for processing prior to disposal. Over time, a thick layer of crude oil forms in the
38 Eastern Research Group, Inc., Preferred and Alternative Methods for Estimating Air Emissions from Oil and Gas Field Production and Processing Operations, September 1999, Available at:
h
ttp://www.epa.gov/ttnchie1/eiip/techreport/volume02/ii10.pdf.
39 See, e.g., calculation methods at: Paul Peacock, Marathon, Bakken Oil Storage Tank Emission Models, March 23, 2 010, Available at: www
.ndoil.org/image/cache/peacock_-_march_23_2010._ppt.pdf; TCEQ, Air Permit Reference
Gu
ide APDG 5941, Available at:
h
ttp://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/guidance_flashemission.pdf ; Kan
sas Dept. of Health & Environment, Available at:
h
ttp://www.kdheks.gov/bar/download/Calculation_Flashing_Losses_Handout.pdf ; B . Gidney and S. Pena, Upstream
Oil a
nd Gas Storage Tank Project Flash Emissions Models Evaluation, July 16, 2009, Available at:
h
ttp://www.bdlaw.com/assets/htmldocuments/TCEQ%20Final%20Report%20Oil%20Gas%20Storage%20Tank%20 P
roject.pdf
.
APPX_000483
11 wa
ter draw surge tank.40 The water draw surge tank and processing of wastewaters from it emit VOCs. The tanks may be closed and vented to a control device. The Application Review does not mention water draw, or include emissions from storing or processing it. The oily water from the tank water draw would likely be collected in a sump and processed in the oily water sewer system, separatel
y permitted in 2014 (Comment f), thus linking this separate permit action to the Terminal permits.
E. P
ump Pit Emissions Were Omitted
The
Terminal as originally proposed in 2012 was designed to includ e 15 pump pits, each
with pum
ps designed to be connected to four railcars each. The pump pits are remote from the unloading
rack and were preliminarily designed to be about 20 ft by 20 ft by 5 ft deep.41 P ump
lea
ks would collect in these pits and evaporate, emitting VOCs. These VOC emissions were not include
d in the potential to emit calculations. Further, the collection system to rec over and treat
c
ollected leaks was permitted as a separate project in September 2014. The oily water from
these
pump pits would likely be processed in the oily water sewer system, separately permitted in S
eptember 2014 (Comment f), thus linking this separate permit action to the Terminal permits.
F. Sump Tanks and API Separator Emissions Were Omitted
I
n September 2014, the new owner, Plains, applied for an Authority to Construct for a drain tank system and an oil/water separator at the Terminal.42 The equipment covered by this application is the oily water sewer system for the Terminal and should have been included in the original 2012 Application. As noted by Argonne National Laboratory, “[a]ll pipeline terminals need to handle the draina
ge of lubricants and pipeline products, sampling dump stations, contaminated condensates, etc.”43
This
2014 modification included four 24-barrel sump tanks and a 20,000-gallon oil/water separator, each separately controlled by a 200-lb carbon canister. The emissions from this new equipment were erroneously omitted from the VOC potential to emit calculation. The September 2014 Application explains that the sump tanks would be used as lift stations, to collect equipment drains and equipment pad surface drainage in the offloading metering, pump stations, pipeline booster pump, and pig launcher areas. The oil/water separator would treat water from
40 See, for example, TRW Environmental Operations, Emission Test Report, Petroleum Refinery Wastewater Treatment System, Chevron U.S.A., Inc., El Segundo, California, March 1984, EMB Report 83- WWS-2, March 1984, pdf 68 and Fig. 3-1, Available at:
http://nepis.epa.gov/Exe/ZyPDF.cgi/9100EN7A.PDF?Dockey=9100EN7A.PDF; Linda M. Curran, Waste Minimization Practices in the Petroleum Refining Industry, 1992, Available at:
h
ttp://infohouse.p2ric.org/ref/39/38867.pdf
and Kimman Process Solutions B.V., Automatic Tank Dewatering, Av
ailable at: http://www.kpsnl.com/en/applications-en/miscellaneous-refineries-en/tank-dewatering-en. 41 E-mail from Michael C. Ernst to Joe Henderson, RPMS Engineers, Re: Follow-up on Tank Question for Crude Oil Terminal, June 25, 2012 2:28 PM.
42 Letter from Glen Mears, Plains LPG Services, L.P., to Leonard Scandura, SJVAPCD, Re: Authority to Construct Application, Bakersfield Crude Terminal, LLC, September 8, 2014 (“September 2014 Application”). 43 T.C. Pharris and R.L. Kolpa, Overview of the Design, Construction, and Operation of Interstate Liquid Petroleum Pipelines, Argonne National Laboratory Report ANL/EVS/TM/08-1, November 2007, p. 5, Available at:
http://corridoreis.anl.gov/documents/docs/technical/APT_60928_EVS_TM_08_1.pdf.
APPX_000484
12 the oily water sewer by separating the oil from the water and routing VOC-laden vapors to carbon canisters. Separated oil would be removed by vacuum truck.
The
District estimated VOC emissions from this equipment as 100 lb/yr for each of the sump tanks and 109 lb/yr for the oil/water separator, for a total of 509 lb/yr.44 These emissions plus those from the Terminal, as permitted in 2012, add up to 20,501 lb/yr, which exceeds the major source threshold.
How
ever, rather than concluding that the Terminal is a major source, the District cites its Policy APR 1130 and asserts that new units with emissions of 0.54 lb/day or less are not included in major source determination calculations. As each proposed unit (the four tanks and the oil/water separator)
has emissions of less than 0.54 lb/day, according to the District, the facility will remain a minor source.45 However, the District has misapplied its policy.
T
his policy only applies to “increases in permitted emissions.” The subject equipment should have been permitted in 2012 with the rest of the Terminal as the equipment is required for the Terminal to operate. This type of equipment is used at all crude oil terminals and should have been anticipated and included in the original 2012 Terminal Application. Sump tanks, for example, are used at crude loading terminals to: (1) collect any material, such as drips from equipment such as pumps that might be released during a malfunction or process upset; (2) to collect material from spill cleanups; (3) to collect tank water draws; and (4) to collect crude oil from pigging operations and maintenance activities. An oil/water separator is required to treat the oily water
before it is discharged into the environment, e.g., receiving waters or a septic/leach field. Thus, the subject emissions should not be treated as “increases in permitted emissions,” but rather
should have been included in the emissions to make the original major source determination. The project has been piecemealed by separately permitting components required for the Terminal to operate.
Further, this policy circumvents federal law, which requires that all sources of emissions be included in potential to emit calculations, regardless of their magnitude. This policy was not adopted in EPA’s approval of the District’s NSR rule and cannot be used to make a federal minor source claim.
G. Cargo Carrier Emissions
The Terminal at buildout would receive and offload up to two unit trains per day of 104 rail cars each and is expected to operate 14 hours per day. District Rule 2201, Section 4.7, requires that emissions from cargo carrier
s while present on site be included in the potential to emit. Section 3.12 defines cargo carriers as “trains dedicated to a specific Stationary Source….” The District’s Application Review for the similar Alon Terminal (2 unit trains per day designed to simultaneously unload 150,000 bbl/day of crude oil into new tanks) concluded that on-site emissions from the locomotives
meet the definition of “cargo carriers” as “..once the trains arrive at Alon, the applicant and the District agree that the trains are under the complete control of Alon
44 SJVAPCD, Authority to Construction Application Review, September 20, 2014 (“Tank/Separator Application Review”).
45 September 2014 Application Review, p. 5.
APPX_000485
13 mana
gement, are dedicated to the refinery, and are in fact “Cargo Carriers” subject to Rule 2201.
Specifically, the resulting onsite emissions from these Cargo Carrier operations are subject to the requirements of Rule 2201.”46
The
District included 1.0 lb/day and 380 lb/yr of VOC emissions from cargo carriers in its potential to emit for the Alon Facility.47 The cargo carrier emissions from the Bakersfield Crude Terminal would be larger, as it will unload 168,000 bbl/day, compared to 150,000 bbl/day at Alon. Thus, cargo carrier emissions from Bakersfield Crude Terminal would about 1.12 times greater than from the Alon Terminal or about 426 lb/yr. Cargo carrier emissions, when added to the District’s 2012 potential to emit of 19,992 lb/yr, results in VOC emissions of 20,418 lb/yr,48 e
xceeding the major source threshold and classifying the Bakersfield Crude Terminal as a major source under Rule 2201.
H. S
tationary Combustion Sources
A f
acility that handles flammable material, such as crude oil, is re quired by the fire code
to have
a fire pump and diesel generator. To assure that these are in good operating condition whe
n needed, they are periodically tested. These are typically fossil-fue l fired and thus generate
e
missions, including VOCs, when tested. The
se emissions were not included in the potential to
e
mit.
On O
ctober 16, 2014, Plains Marketing, L.P. applied to the Air District to construct two emergency fire water pumps fired by diesel engines.49 In the Air District’s Authority to Construct Application Review, each pump was projected to emit 2 lbs of VOCs per year, or 4 pounds per year total.50 This permit should have been included with the initial 2012 permitting action. The project has been piecemealed by separately permitting components required for the Terminal to operate.
46 SJVAPCD, Authority to Construct Application Review, Alon USA – Bakersfield Refinery, October 14, 2014 (“Alon Application Review”), p. 7.
47 Alon Application Review, p. 26.
48 Bakersfield Crude Terminal cargo carrier emissions, estimated from Alon Terminal cargo carrier emissions = (380 lb/yr)(168/150) = 426 lb/yr. The revised PTE = 19,992 + 426 = 20,418 lb/yr. 49 Letter from Glen Mears, Plains Marketing, L.P., to Leonard Scandura, SJVAPCD, Re: Authority to Construct Application, Bakersfield Crude Terminal, LLC, October 16, 2014. 50 SJVAPCD, Authority to Construct Application Review, Fire Pumps, November 13, 2014.
APPX_000486
14 III. Permit Conditions Are Not Enforceable
The
emissions from the Terminal, when operated at its maximum capacity based on its ph
ysical and operational design, would emit more than 20,000 lb/yr of VOCs and thus should be a major source. Operational limitations were imposed in the ATC permits to attempt to re duce
VO
C emissions to 19,992 lb/day, just 8 lb/yr shy of the major source threshold. Ope rational
li
mitations, such as those imposed here, can only be relied on to limit t he potential to emit if they
a
re incorporated into the permit as enforceable conditions.51 Most of these o perational
li
mitations are not enforceable. Further, the permits require no reporting, precluding District and c
itizen enforcement.
A. T
ank Permit Conditions Are Not Enforceable
The
total Terminal VOC emissions were calculated in the District’s 7/25/12 Application Review as the sum of emissions from two tanks (2 x 9,460 = 18,920 lb/yr), fugitive components (617 lb/yr), and disconnect losses (455 lb/yr).52 The tank permits (S-8165-1 and -2) limit the emissions from both tanks combined to 18,920 lb/yr.53 These limits are not enforceable because the permits do not require adequate monitoring, fail to specify how VOC emissions would be calculated, and do not require any reporting.
VO
C emissions from tanks are generally not measured but rather are calculated using the EPA computer model, TANKS 4.0.9d. The key input parameter that determines tank VOC emissions is the Reid Vapor Pressure (RVP) of the material stored in the tank. The RVP is a measure of the volatility of the material. The higher the volatility (and RVP), the higher the VOC emissions. The tank emission limit of 18,920 lb/yr was estimated in the Application Review with the TANKS model, assuming a RVP of 8.3 psia, which yielded 9,460 lb/yr for each tank.54
How
ever, the tank permits allow materials to be stored in the tanks with an RVP of up to
11.0 psia.55 This vapor pressure limit would allow VOC emissions from each tank of 13,961 lb/yr.56 Under this limit, VOC emissions from both tanks would be 27,922 lb/yr, which exceeds the major source threshold of 20,000 lb/yr, without including emissions from fugitive components, disconnects, and various omitted sources discussed elsewhere.
Thus, VOC
emissions from the tanks alone would qualify the Terminal as a major source, unless the permits contain operational or other limits that would restrict the potential to emit VOCs to less than 20,000 lb/yr.
This could be done by placing enforceable limits on emissions from the tank, which are the major source of emissions from the Terminal.
T
he tank permits attempt to address this issue in Condition 7, which requires: “If any shipment of organic liquid with an RVP greater than 8.3 psia is introduced, placed, or stored in this tank in any calendar year, compliance with annual combined emission limit for tanks listed
51 District Rule 2201, Sec. 3.27.
52 7/25/12 Application Review, pp. 4-5.
53 ATC Permits S-8165-1-0 and 8165-2-0, Condition 5.
54 7/25/12 Application Review, pp. 4-5 and Appx. E, 6/27/12 TANKS run for RVP = 8.3 psia. 55 ATC Permits S-8165-1-0 and 8165-2-0, Condition 6.
56 7/25/12 Application Review, Appx. E, 7/17/2012 TANKS Run for RVP=11 psia (p. 2 of 5).
APPX_000487
15 on S-8165-1 and ‘-2 [the tank permits] shall be demonstrated by calculating and maintaining an annual emission summ
ary using the EPA’s TANKS program.” This condition renders the tank emission limit of 18,920 lb/yr unenforceable as a practical matter for two reasons.
1. Vapor Pressure (RVP)
T
he volatility of a crude oil is measured in pounds per square inch absolute (psia) and is typically reported as Reid Vapor Pressure (RVP) at 100oF.57 Vapor pressure is an indirect measure of the evaporation rate of volatile compounds in the crude oil such as VOCs, with higher vapor pressures indicating greater losses of VOCs from evaporation. There is a well established relationship between the vapor pressure of a crude oil and the amount of VOC emissions released from equipment containing the crude oil.58 This relationship is incorporated into the EPA TANKS 4.0.9d model, universally used to estimate VOC emissions from tanks, including in the subject permits.
The
crude oil RVP is the key input into the TANKS program used to calculate VOC emissions. However, the tank permits do not require that the RVP of materials stored in the tanks be measured. The permits do not disclose how (method), where (field, shipping point, unit train), or by whom (supplier, shipper, applicant) the RVP will be determined. This is a major omission as tank VOC emissions cannot be estimated without the RVP of the “stored” material.
E
-mail correspondence between the applicant and District suggest that “supplier published oil assays” would be used.59 The applicant proposed the use of “oil assays” and stated:
“We would be able to assign a RVP value to each shipment based on assay data for its place of origin.”
60 Tanks Condition 7 refers to the RVP of “any shipment”, suggesting that “shipment” RVP would be used. Shipment vapor pressure is not adequate to control VOC emissions from the tanks.
How
ever, the permits themselves do not require any vapor pressure measurements, not even shipment or supplier assays or any other source, leaving this critical metric essential to calculate
VOC emissions to the discretion of the applicant to specify. The applicant, for example, could simply estimate the RVP, based on a shipment’s point of origin as suggested in e-mails, or some other arbitrary criterion, such as marketing assays, picked to assure emissions remain below the major source threshold. Thus, the VOC emission limit in Condition 5 of both tank permits is unenforceable.
If shipment or
supplier assays were used, VOC emissions would likely be incorrectly estimated, as the RVP of crude oils is known to vary substantially from field to field, from well
57 Measured by American Society for Testing and Materials Method ASTM D323-08, Standard Test Method for Vapor Pressure of Petroleum Products (Reid Method) is used to determine the vapor pressure at 100 F with initial boiling point above 32 F.
58 See AP-42, Section 7.1: Organic Liquid Storage Tanks. 59 E-mail from Michael C. Ernst, HDR Inc., to Kristopher Rickards, SJVAPCD, Re: Bakersfield Crude Terminal, LLC, July 17, 2012 12:33 PM (“I just want to be clear we would be getting the RVP from the suppliers published oil assays, not sampling and analyzing each train.”)
60 E-mail from Michael C. Ernst, HDR Inc., to Kristopher Rickards, SJVAPCD, Re: Bakersfield Crude Terminal, LLC, July 17, 2012 8:22 AM.
APPX_000488
16 to we
ll within a field, and from time to time within the same well.61 Further, a unit train may include tanks cars carrying crude oil from several different sources. The tank permits, as written, give the applicant the flexibility to pick a vapor pressure that assures VOC emissions remain below the VOC emission limit.
T
he characteristics of one of the crude oils that likely would be handled at the Terminal, Bakken crudes, was surveyed by the American Fuel & Petrochemical Manufacturers (AFPM) of it members, at the request of the Department of Transportation. This survey revealed that these crudes have an RVP of up to 15.5 psi, far above the upper permitted limit of 11.0 psia. Vapor pressure data collected in this survey62 and summarized in Figures 2 and 3 indicate that the vapor pressure of these crudes is highly variable. Bakken crude oil offered for transportation was found to have RVP values ranging from 0.8 to 15.54 psia, as summarized in Figure 2. Thus, a single
published shipper assay would be worthless for determining compliance with the VOC limits in the subject tank permits.
F
igure 2.63
Othe
r data collected in the AFPM survey show significant seasonal variation in RVP, ranging from 8 psia for warmer times of the year and an average 12.5 psia during colder periods.
Figure 3. Thus, a single published shipper assay is worthless for determining compliance with the tank VOC limits.
61 Department of Ecology, State of Washington, Washington State Draft 2014 Marine & Rail Oil Transportation Study, December 1, 2014, Publication No. 14-08-015, Table 78 [VPCR 4 @ 100oF (psia)], Available at:
https://fortress.wa.gov/ecy/publications/publications/1408015.pdf. 62 Dangerous Goods Transportation Consulting, Inc., A Survey of Bakken Crude Oil Characteristics Assembled for the U.S. Department of Transportation, Submitted by American Fuel & Petrochemical Manufacturers, May 14, 2 014, Available at: https://www.afpm.org/WorkArea/DownloadAsset.aspx?id=4229. 63 Dangerous Goods Transportation Consulting, Inc., May 14, 2014, p. 19.
APPX_000489
17 Figure 3.
S
easonal Variation in RVP64
The
AFPM survey further indicated that “[r]ecipients monitor crude oil for RVP to ensure complianc
e with these environmental regulations. One respondent noted that they test the RVP of every rail shipment at the time of loading and upon receipt.” Due to increased potential for
pump cavitation, other respondents noted “[a] limiting RVP of 10 psia was reported as typical for crude oils transported by pipeline where pumping is required.”65 However, the subject tank permits require no monitoring of RVP to determine compliance with VOC emission limits.
The
tank permits limit VOC emissions from the tanks based on the vapor pressure of material stored in the tank. Tank permit Condition 6 limits the RVP of “liquid introduced, placed, or stored in the tank.” Condition 35 further requires daily and annual records of throughput and annual tank emissions “if any liquid is introduced, placed, or stored in the tank that has an RVP greater than 8.3 psia.” Thus, the permit is clear that the RVP limit applies to the tank, not the rail car, pipeline, shipper, or oil field.
However, the permits do not require RVP to
be measured or reported anywhere, rendering the tank VOC limits unenforceable.
A shipper published assay for a crude oil from a given field, or for a given shipment, does not satisfy this per
mit language. These shipper assays are typically average or typical assays for a field, not assays for materials “introduced, placed, or stored” in the Terminal tanks. Even if the shipper assay were based on a specific unit train, substantial variability could occur among the cars, as a unit train
contains 104 rail cars, each containing about 30,000 gallons of oil. Each rail car could contain oil from a different source, with a different vapor pressure.
F
urther, only a portion of each unit train load, 2,940,000 gallons per day or 42% on average, is routed through the tanks.66 The balance, 7,056,000 gallons per day, is sent directly to the pipeline. The pipeline portion would have to meet pipeline vapor pressure limits, which are
64 Dangerous Goods Transportation Consulting, Inc., May 14, 2014, p. 20. 65 Dangerous Goods Transportation Consulting, Inc., May 14, 2014, p. 20. 66 E-mail from Michael C. Ernst, HDR Inc. to Ashley Dahlstrom, SJVAPCD, Re: Additional Information Required, June 1, 2012 12:15 PM.
APPX_000490
18 in t
he range of 8.2 to 8.3 psia,67 much lower than the tank vapor pressure limit of 11.0 psia.
Thus, it is reasonable to expect that higher vapor pressure material would be routed to the tanks for blending.
F
urther, as only a portion of each load is stored in the tanks, and given the substantial demonstrated variability in crude oil vapor pressure, the vapor pressure must be measured at the tank itself. To assure compliance with daily limits, the vapor pressure must be measured every day.
The tank permits do not require any vapor pressure measurements, anywhere, let alone at the emission point, the tanks themselves, on a daily basis.
Under these permits, the actual vapor pressure of the stored material in the tanks would never have to measured or be used to estimate tank emissions. Thus, the VOC emission limits in Condition 5 of the tank permits are not enforceable.
2. VOC Emission Calculation
C
onditions 7 of the tank permits require that if any shipment with an RVP greater than
8.3 psia is “introduced, placed, or stored in this tank in any calendar year, compliance with annual combined emission limit for tanks listed on S-8165-1 and ‘-2 shall be demonstrated by calculating and maintaining an annual emission summary using the EPA’s TANKS program.” The combined limit is
18,920 lb-VOC/yr in Condition 5. This limit was calculated by the District using the TANKS program, run in the annual mode with an RVP of 8.3 psia and many other
input assumptions. However, at the Terminal, the RVP varies from day to day. The District expressed concern, noting “the only issue we would have is how the actual averaging of vapor pressure would be calculated for the annual emissions.” 68 The permits are silent on how
this calculation should be made. Further, the tank permits do not limit any of the other TANKS input variables. Thus, Condition 7 cannot be used to enforce Condition 5.
First, the ta
nks combined VOC limit of 18,920 lb/yr was calculated using the TANKS model for a specific set of input values, including crude oil characteristics (RVP of 8.3 psia; molecular weight of 207) and tank characteristics, including tank dimensions, paint characteristics, rim-seal system, deck characteristics, and deck fitting/status. One simple change in these inputs, from a roof condition of “good” to “poor,” for example, was sufficient to tip the
VOC emissions over the major source threshold in the District’s emission calculations.69 The tank permits do not require that the roof be maintained in “good” condition, nor do they require that the tanks be built to meet the specifications assumed in the TANKS model run used to estimate the VOC emission limit. Thus, the combined tanks VOC limit of 18,920 lb/yr is not enforceable via calculation with the TANKS model as all of the inputs are not limited by permit conditions.
67 E-mail from Michael C. Ernst, HDR Inc, to Kristopher Rickards, SJVAPCD, Re: Bakersfield Crude Terminal, LLC, July 11, 2012 12:37.
68 E-mail from Kristopher Rickards, SJVAPCD, to Michael Ernst, HDR Inc., Re: Bakersfield Crude Terminal, LLC, July 16, 2012 3:21 PM.
69 See E-mail from Michael Ernst, HDR Inc. to Kristopher Rickards, SJVAPCD, June 27, 2012.
APPX_000491
19 Se
cond, Condition 7 does not explain how the TANKS model would be used to demonstrate compliance. The TANKS model calculates annual or monthly VOC emissions for a single vapor pressure input and tank throughput (number of turnovers), but not for other time steps with varying vapor pressures and throughputs.70 The dual vapor pressure limit, a maximum of 11.0 psia and an annual average of 8.3 psia, requires a non-standard use of the TANKS model that is not specified in the permit, granting the applicant discretion as to how compliance will be determined.
T
he TANKS model does not calculate annual average VOC emissions under varying flow and vapor pressure conditions, as required here to determine compliance with dual vapor pressure limits. This is a novel use of the TANKS model that has never been used in a District permit and that has not been demonstrated to yield reliable, enforceable results. The applicant and the District considered various approaches including: (1) use of daily throughputs to calculate a rolling average RVP to show the average RVP is less than 8.3 for any 12 months;71 (2)
use of volume-weighted average RVP; and (3) run the entire year’s throughput for each tank through TANKS to sh
ow that the annual emissions are below permitted levels.72 However, the permit is silent on the approach that must be used to demonstrate compliance.
The
lack of a tested method to calculate compliance using the TANKS model is discussed in e-mail correspondence between the applicant and the District. The District advised as follows:
“…for ongoing annual compliance I’m not sure this [an average RVP] would be feasible for the facility to do, and I would have to run this by our compliance department to see if that’s something they could enforce as well. To my knowledge (and after searching permit condition language of District permits)
using an average TVP [total vapor pressure] hasn’t been written into any permits here, but if we could find a way to make it work we could go from there.” 73 Thus, e
-mail correspondence acknowledges that using the TANKS model to determine compliance with the vapor pressure limit is not straightforward and that there is no precedent for an
annual average vapor pressure limit. However, the permit fails to specify a method.
The
tank permits do not explain how the TANKS program would be used to determine compliance with the volume-weighted VOC limit in Condition 5. Conditions 5 and 7 are not enforceable without specifying
a calculation method. An inspector, for example, could not determine on the spot whether the facility was in compliance, except at the end of each year when the annual average is calculated. Compliance could not be determined at all during the first year of operation. And the inspector would not know how to make the calculation.
The District permit engineer noted: “Keeping daily records of the throughput and RVP
should allow us to verify compliance over any twelve month period. Let me know if this works
70 U.S. EPA, User’s Guide to Tanks, September 30, 1999, Section 5.0, Available at:
http://www.epa.gov/ttn/chief/software/tanks/tank4man.pdf. 71 E-mail from Michael C. Ernst, HDR Inc. to Kristopher Rickards, SJVAPCD, Re: Bakersfield Crude Terminal, LLC, July 17, 2012 12:33 PM.
72 E-mail from Kristopher Rickards, SJVAPCD, to Michael Ernst, HDR Inc., Re: Bakersfield Crude Terminal, LLC, July 18, 2012, 16:14:20 GMT.
73 E-mail from Kristopher Rickards, SJVAPCD, to Michael C. Ernst, HDR Inc., Re: Bakersfield Crude Terminal, LLC, July 17, 2012 17:28:30 GMT.
APPX_000492
20 for
you.”74
I agree. The most accurate method to calculate annual VOC emissions under varying throughput and RVP conditions would be to measure/record daily tank throughput and daily vapor pressure for each tank and run the TANKS model for each day. This would yield 365 estimates of daily emissions, which could be summed to yield annual VOC emissions. This approach is consistent with the use of the TANKS model to estimate VOC emissions when the tank stores different liquids during the year. The EPA recommends to “[e]stimate emissions for the time period over which each liquid was stored, and sum the emissions to obtain the annual emissions.”
75 T
he tank permits do not require that adequate data be collected to determine compliance with the annual VOC limit, regardless of how the VOC limit is expressed or calculated. Tank permits Condition 35 only require daily and annual “records” (not measurements) of tank throughput and annual emissions only if liquid with an RVP greater than 8.3 psia is introduced.
However, to make the annual calculation required to determine compliance, daily measurements of RVP and throughput are required regardless of the RVP.
Throughput measurements and annual emissions are only required to be “maintained”
(not measured) if vapor pressure is less than 8.3 psia. Thus, the throughput information required to adjust the TANK output does not have to be collected or recorded, leaving it to the discretion of the applicant as to how these throughputs and vapor pressures would be determined.
Condition 35
should be modified to require daily and annual measurement and recording of tank vapor pressure and throughput, regardless of the vapor pressure. Finally, the tank permits should be modified to require that all of the data is reported to the District on a quarterly basis.
3. Fixed Roof Tanks Are Required
Condition 6 of the tank permits limits the RVP of liquid stored in the tanks to 11.0 psia.
District Rule 4623 does not allow the use of floating roof tanks if the total vapor pressure (TVP) of the stored material is greater than or equal to 11.0 psia. Pressure vessels or fixed roof tanks
vented to vapor recovery are required. Rule 4623, Sec. 5.1.1. The TVP corresponding to an RVP of 11.0 psia varies depending upon the temperature of the stored liquid. An RVP of 11.0 psia corresponds to a TVP of 11.0 psia
at a temperature of about 78 F.76 Higher temperatures,
which are feasible on a hot summer day in Bakersfield, would exceed the TVP limit for floating roof tanks.
For example, the District predicted the following tank surface temperature and corresponding TVPs for a crude oil RVP of 11.0 psia for a modification at the Terminal:77
May: 82.17oF, TVP =11.96 psia
June: 86.51oF, TVP = 12.75 psia
July: 88.94oF, TVP =13.20 psia
August: 87.00oF, TVP = 12.84 psia
74 E-mail 7/17/12 Ernst to Ricards.
75 TANKS Software Frequent Questions: “My tank stores different liquids during the year. How do I account for this variability?” Available at: http://www.epa.gov/ttn/chief/faq/tanksfaq.html#18. 76 AP-
42, Section 7.1, Organic Liquid Storage Tanks, Figure 7.1-13a, Available at:
http://www.epa.gov/ttn/chief/ap42/ch07/final/c07s01.pdf. 77 SJVAPCD, Authority to Construct Application Review, Fixed Roof Tanks, April 24, 2014, Appendix C, pdf 29.
APPX_000493
21 September: 82.28oF, TVP = 11.98 psia
The 2012 Application, Attachment B, asserts the maximum storage temperature will be 65 F. However, the tank permits do not limit the storage temperature of the tanks (or the material that can be stored) or require tank temperature measurements.
B. Unloading Rack P
ermit Conditions Are Not Enforceable
The District’s potential to emit calculations for the unloading rack are based on two sources of VOC emissions: (1) disconnect losses (455 lb/yr) and (2) fugitive emissions (617 lb/yr). The unloading rack ATC permit (8165-3) does not limit either source of VOC emissions to the assumed levels.
1. Disconnect Emissions
The
unloading rack is individually connected to each rail car with a 4-inch Todo-Matic drybreak connector by NovaFlex.78 When the loading rack is attached and disconnected from the rail cars, some of the crude oil within the connector spills to the ground and evaporates, releasing VOCs.
The
VOC emissions from hooking up each rail car with the loading rack and disconnecting it were calculated from the number of railcars per day (208), the average volume of spilled oil per disconnect (3.2 mL), and the density of the crude oil (7.1 lb/gal). 79 This
resulted in 1.2 lb/day and 455 lb/yr of VOCs.80 To make these VOC emissions enforceable, and assure they remain below the major source threshold (20,000 lb/day) and the public notice threshold (100 lb/day), the unloading rack permit would have to limit each of these factors to the levels assumed in the Application Review calculations (208 disconnects/day, 3.2 mL/disconnect,
7.1 lb/gal) and require measurement and recording of each factor on a daily basis. The permit fails this test.
The
unloading rack permit (S-8165-3) does not limit disconnect VOC emissions to either
1.2 lb/day or 455 lb/yr as assumed in the Application Review nor does it require that all three factors required to calculate disconnect VOC emissions are measured daily. These factors are:
number of disconnects per da
y, volume of each disconnect, and density of spilled material.
There is no limit at all on VOC emissions, e.g., the permit does not contain a condition limiting disconnect VOC emissions to 1.2 lb/day and 455 lb/yr.
Rather than limiting VOC
emissions, the permit takes the approach of limiting inputs to the VOC calculation. However, the permit
fails to specify how the VOC emissions should be calculated to demonstrate compliance. Even i
f the permit required compliance by calculation, and specified the calculation
78 E-mail from Joe Jenderson, RPM Engineers to Michael C. Ernst, SJVAPCD, Re: Follow-up on Tank Question for Crude Oil Terminal, June 26, 2012 7:23 AM.
79 7/25/12 Application Review, p. 4.
80 From 7/25/12 Application Review, p. 4: Annual disconnect VOC emissions = (208 disconnects/day)(365 day/yr)(3.2 mL/disconnect)(0.000264 gal/mL)(7.1 lb/gal) = 455 lb VOC/yr.
APPX_000494
22 method, there would be no obligation to meet any specific emission level, as the permit contains no target, e.g., 1.2 lb/day and 455 lb/yr.
There are additional problems with the undisclosed calculated method hinted at in the unloading rack permit. This calculation method is assumed to be that used in the 7/25/12 Application Review. However, the
unloading rack permit fails to limit all three calculation inputs and only requires monitoring for one of them.
First, Condition 5 limits spill volume to 3.2 milliliters per disconnect based on the use of drybreak couplers. This value was selected “to keep the potential facility emissions below 20,000 lb/years (results in 19,991 lb-VOC/year). This would work but would leave very little margin for compliance.”
81 How
ever, the permit does not require the use of drybreak couplers, nor any testing of disconnects to determine if 3.2 milliliters per drop is a reasonable estimate or is achievable at all.
Further, the unloading rack permit is silent on methods that would be used to measure the disconnect volume from “3 consecutive disconnects”. Thus, Condition 5 is not enforceable.
Daily spill volume could be simply determined by locating a collection sump beneath the connection points and periodically measuring the accumulated volume.
Second
, the number of disconnects is limited to 208 per day and 75,920 per year in Condition 2 and recordkeeping for the number of disconnects is required in Condition 15.
However, spills could occur when the unloading rack arm is connected to the rail car and again
when it is disconnected. Thus, up to two spills are possible for each rail car, which would double disconnect VOC emissions, compared to the potential to emit calculations, exceeding the major source threshold. Total VOC emissions would increase from 19,992 lb/yr, just under the major source threshold, to 20,447 lb/yr, which is over the threshold if drops during connects were
included. This would not be discovered as the permit does not require any monitoring of either the number or volume of connection spills.
T
hird, the unloading rack permit does not limit the density of the spilled material. The 7/24/12 Application Review assumed a default crude density of 7.1 lb/gal from AP-42, Table
7.1-2.82 However, the permits do not limit either the density or type of crude oil that will be unloaded at the facility. There are many cost-advantaged crudes available for transport by rail that have higher densities than assumed in these calculations, such as Canadian tar sands DilBit crudes.
83 The current owner of the Terminal, Plains, has rail access to the Bakersfield area from Canada, North Dakota, the midcontinent, the Permian Basin, and the Eagle Ford Basin. Further, it has pipelines that ca
n move crudes to refineries in both northern and southern California.84 Thus, c
rudes with a wide range of densities (as well as vapor pressures) could be handled at the
81 E-mail from Kristopher Rickards, SJVAPCD, to Michael C. Ernst, Re: Bakersfield Crude Terminal, LLC, June 27, 2012 4:08 PM.
82 7/25/12 Application Review, p. 3.
83 See, for example, heavy sour unconventional (density: 7.71 – 7.75 lb/gal) and heavy sour synbits (density: 7.77 –
7.82 lb/gas), Available at: http://www.crudemonitor.ca/home.php. 84 h
ttp://california.maps.arcgis.com/apps/OnePane/basicviewer/index.html? ap
pid=928033ed043148598f7e511a95072b89.
APPX_000495
23 Te
rminal. If a Canadian tar sands DilBit crude were handled at the facility, for example, disconnect VOC emissions would increase from 455 lb/yr to 493 lb/yr. This small change alone would be sufficient to increase the potential to emit from 19,992 lb/yr to 20,030 lb/yr.85
I
n sum, the unloading rack permit does not limit the VOC emissions from disconnect losses to 1.2 lb/day or 455 lb/yr due to inadequate monitoring and recordkeeping. The permit as written would allow a substantial increase in VOC emissions from disconnect losses above those assumed in the potential to emit calculations, enough to classify the Terminal as a major source under rule 2201.
2. Fugitive Emissions
The
VOC emissions relied on by the District to co
nclude this is not a major source
include
617 lb/yr of fugitive emissions. Fugitive emissions are equipment lea ks. The
Applica
tion Review estimated these VOC emissions assuming 350 va lves, 19 pump seals, and
800 c
onnectors “per tank”.86 All of the
fugitive emissions were included in the unloading rack
pe
rmit, even though some of them are associated with the tanks.
C
ondition 3 of the permit limits VOC emissions from these components to 1.7 lb/day and
617 lb/
yr, consistent with the District’s potential to emit calculations. The se VOC emission
li
mits are not e
nforceable and they fail to limit the potential to emit VOCs from fugitive c
omponents.
F
irst, the unloading rack permit (S-8165-3)
is for “organic liquid transfer operation with
li
ght crude oil railcar unloading rack and associated offloading, transfer and booster pumps.” Man
y of the fugitive components are associated with the connecting pipelines and tanks. The e- mails
in which fugitive emissions are calculated, for example, lump some of the components with t
he tanks. Thus, there is ambiguity as to which fugitive components are regulated under the unloading
rack permit.
S
econd, Conditions 3 and 16 require that
compliance is determined by counting the
number
of components of each type (valve, pump, connector) and multiplying by EPA e mission
fa
ctors. The fugitive emission potential to emit calculations were based on 350 valves, 19 pump se
als and 800 connectors.
However, as some of these components are associated with the tanks a
nd pipelines, they may not all be counted for the unloading rack permit.
The
permit does not place any limit on the number or type of components, even though the permit engineer stated: “The component counts will be on the permit though as they account for emissions and must be accounted for under New Source Review (recordkeeping of
85 VOC emissions if crude with a density of 7.7 lb/gal were unloaded: 19,992 – 455 + (7.7/7.1)(455) = 20,030 lb/yr. 86 7/25/12 Terminal Application Review, p. 5, Table: “Fugitive Emissions from Components”, second column:
“Number of Components per Tank”.
APPX_000496
24 c
omponents will be required).”87 Other similar permits issued by the District require the Permittee to submit a count of all fugitive emission sources to the District.88
Thus, the pote
ntial exists to underestimate fugitive emissions by excluding some of the fug
itive components.
S
econd, the permit does not require any reporting of either fugitive VOC emissions or
c
omponent counts to the District, pr
ecluding the District and citizens from discovering violations a
nd enforcing the permit. S
ee, for example, Pentland Pump Station Permit to Operate, Condition 10: “T
he operator shall submit reports of any require
d monitoring at least every six months
unless a
different frequency is required by an applicable requirement.”
Third, it
appears that the District may have underestimated fugitive emissions. The
7/25/
14 Application Review uses the “number of components per tank” to calculate VOC e
missions of 617 lb/yr. However, if the component count column heading is correct, thi s
c
alculation is only for a single tank. The emissions from both tanks would be double this amount
or 1,234 lb/yr. Revised total potential to emit would be 20,609 lb/yr,89 whic h exceeds the major
sourc
e threshold.
F
ourth, Condition 8 requires that components be maintained in a “leak-f ree condition.”
How
ever, the permit does not require periodic monitoring of the components to assure they are “
leak-free”. Other permits issued by the District have been modified to re quire that components
be
inspected annually for gas and liquid leaks pursuant to District Rule 2520, Sec. 9.3.2 to assur e
the
y are enforceable.90
F
inally, in the November 2014 Application Review for Emergency Firewater Pumps, the Dist
rict alleges for the fir
st time that fugitive emissions are not included in major source de
termination calculations as the facility is not one of the source categories specified in 40 CFR
51.165.91 However, fugitive emissions must be included for “petroleum storage and transfer unit
s with a total storage capacity exceeding 300,000 barrels.” 40 CFR 51.165(a)(iv)(C)(22).
The
ATCs do not limit the capacity of the tanks that would be installed. Further, the pipe line
s
ystem itself serves as storage as well as conveyance. Thus, the storage capacity exceeds
300,000 barrels, qualifying the Terminal as one of the listed sources in 40 CFR 51.165.
In
a
ddition, fugitive emissions must be included under 40 CF R 51.165 for stationary sources
re
gulated under EPA’s New Source Performance Standa
rds (NSPS), 40 CFR
51.165(
a)(iv)(C)(27). The facility includes organic liquid storage tanks, for which EPA has
iss
ued NSPS standards in 40 CFR Park 60, Subpart Kb. Thus, fugitive emissions were properly
87 E-mail from K. Rickards to Michael C. Ernst, RE: Follow-up on Tank Question for Crude Terminal, June 25, 2012 9:48 AM.
88 SJVAPCD, Permit to Operate, Plains Pipeline LP, Pentland Pump Station, July 28, 2011, condition 45, Available at: http://www.valleyair.org/notices/Docs/2011/07-28-11%20%28S- 1091242%29/Public%20Notice%20Package.pdf.
89 Revised Terminal emissions = 2x617 + 2x9,460 + 455 = 20,609 lb/yr. 90 Notice of Preliminary Decision – Federally Mandated Operating Permit, District Facility # S-1337, June 22, 2012, pdf 43, Condition 16, Available at: http://www.valleyair.org/notices/Docs/2012/06- 22-12%20%28S- 1112449%29/Public%20Notice%20Pkg.pdf.
91 November 2014 Application Review, p. 5, footnote to table: “Rule 2201 Major Source Determination.” APPX_000497
25 include
d by the Air District when calculating Terminal emissions in t he 2012 Application
R
eview.
3. Other Unloading Emissions
Finally, Condition 6 of the unloading rack permit (S-8165-3) sets a VOC emission limit for “transfer operations” of 0.08 pounds per 1000 gallons transferred. This is the ONLY condition limiting total VOC emissions from the unloading rack. Emissions from this rack may include other emission sources, not otherwise included in potential to emit calculations, such as emissions from open rail car hatches, rail car fitting leaks, pump sump emissions, etc.
E
-mail correspondence indicates that the total Terminal throughput is 7,056,000 gallons per day.92 Thus, this condition would allow 0.08 lb/1000 gal x 7,056,000 gal/day = 564.5 lb/day of VOC emissions or 206,035 lb/yr. Therefore, this condition does not limit the potential to emit VOCs to the level assumed in the Application Review to classify the Terminal as a minor source.
This limit would allow the Terminal to exceed both the public notice limit of 100 lb/day and the major source
limit of 20,000 lb/yr. While it is a generic limit applied to transfer of organic liquids under District Rule 4624, in this case, it would allow the major source threshold to be exceeded as the permit contains no
enforceable limits to otherwise control total Terminal VOC emissions.
This l
imit is not enforceable, as the permit does not limit the amount of organic liquid that can be transferred and it does not require any testing to determine compliance, as specifically required by Rule 4624, Sec. 6.2.1.3.2 A.
4. Loading Into Tanker Trucks
The rail cars could be unloaded directly into tanker trucks, rather than the tanks or pipeline and shipped to market, bypassing
both the tanks and pipeline. This is currently being
practiced at several rail terminals in California, including the Kinder Morgan Terminal in Richmond, the Interstate Terminal in Sacramento,
and the Paloma Terminal in Bakersfield. This
would increase VO
C emissions above those included in the VOC limits in the permits. Thus, to assure emissions remain below the VOC emission limits, which are calculated, rather than measured, the permits should be conditioned to prohibit loading into tanker trucks.
IV. Reporting Requirements Are Not Adequate To Assure Compliance The permits do not require any reporting of collected data to the District, except Condition 33 in permits S-8165-1 and
-2, which requires reporting of floating roof tank
inspections. Thus, there is no way for either the District or citizens to determine if the Terminal
92 E-mail from Michael C. Ernst, HDR Inc. to Ashley Dahlstrom, SJVAPCD, Re: Additional Information Required, June 1, 2012 12:15 PM.
APPX_000498
26 is i
n compliance. Permits for similar facilities typically require periodic reporting of conditions set to limit emissions, as well as prompt reporting of deviations.93
93 S
ee, e.g., South Coast Air Quality Management District Annual Emission Reporting Program, available at h
ttp://www.aqmd.gov/home/regulations/compliance/annual-emission-reporting ; SJVAPCD, Permit to Operate,
P
lains Pipeline LP, Pentland Pump Station, July 28, 2011, Available at:
http://www.valleyair.org/notices/Docs/2011/07-28-11%20%28S-1091242%29/Public%20Notice%20Package.pdf.
APPX_000499
APP
ENDIX G
APPX_000500
FACILITIES WITH STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020 BY TYPE 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020 Total Alcohols 1 1
Amines 4 4
Ammonia 3 5 2 10
Asphalt 1 2 1 6 1 2 13
Benzene 1 1
Butane 12 12
Butylenes 2 2
Caustic 4 4
Chems. Inorg. 2 2
Coke 4 2 6
Crude 10 8 37 8 2 12 6 1 1 1 86
Diesel 9 2 3 1 15
Fuel Oil 4 12 8 24
Gas 1 5 5 19 2 4 36
Gas-Oil 1 1 1 3 2 8
Gasoline 3 25 51 36 11 6 68 7 2 2 211
Hydrocarbons 1 2 29 50 4 16 3 3 108
Hydrocarbons Misc. 1 1 4 5 1 2 14
Jet-A 2 1 2 5
JP-5 1 1
LPG 2 24 26 52
Lube Oil & Grease 1 1
Misc. Inorganic Chemicals 1 1 2
Misc. Materials 8 14 17 1 40
Misc. Organic Materials 2 2 4
MTBE 1 1
Naphtha 4 1 2 7
Organic Chemicals Misc. 2 6 8
Perchloroethyle 1 1
Pet. Dis. 6 1 6 4 17
Pet. Light Dis. 1 4 5
Pet. Mid. Dis. 1 24 23 9 19 13 2 91
Petroleum Coke 1 1
Polyvinyl Chloride 1 1
Propylene & Polypropylene 7 7
Residual 1 1
Residual Oil 1 1
Soda Ash 1 1
Solvents 2 4 6
Sour Water 3 1 4
Spent Sulfuric Acid 1 1
Sulfur 2 2 2 6
Sulfuric Acid 1 1
Toluene 1 1
Waste fuels 2 2
Waste oil 1 2 3
Waste water 1 2 4 1 5 1 13 27
Total 14 38 187 248 40 8 229 42 36 4 9 855
Appendix G
1 of 27
APPX_000501
PENDING STORAGE TANK APPLICATIONS FOR SCAQMD PERMITS
Facility
ID
Application
No. Equipment Description Application Date Application Status Type of Material in Tank
111238 614274 STORAGE TANK FX RF W/INT FLT
GASOLINE 6/25/2019 PERMIT TO CONSTRUCT GRANTED1 Gasoline 111238 614275 STORAGE TANK FX RF W/INT FLT
GASOLINE 6/25/2019 PERMIT TO CONSTRUCT GRANTED Gasoline 171107 612525 STORAGE TANK FX RF W/CTL
AMMONIA 5/9/2019 PERMIT TO CONSTRUCT GRANTED Ammonia
171107 612630 STORAGE TANK FX RF W/CTL
AMMONIA 5/14/2019 PERMIT TO CONSTRUCT GRANTED Ammonia
171107 616651 STORAGE TANK W/EXT FLOAT
ROOF SOUR WATER 10/24/2019 ASSIGNED TO ENGINEER - CLASS I Sour water 171107 616652 STORAGE TANK W/EXT FLOAT
ROOF SOUR WATER 10/24/2019 ASSIGNED TO ENGINEER - CLASS I Sour water 174655 617776 STORAGE TANK FX RF W/CTL
CRUDE OIL 12/10/2019 ASSIGNED TO ENGINEER - CLASS III Crude 174694 598464 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174694 598465 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174694 598466 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174694 598467 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174694 598468 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174694 598469 STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/31/2017 ASSIGNED TO ENGINEER - CLASS I Crude 174705 606740 STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 8/21/2018 APPLICATION CHANGED FROM
CLASS I - III Gas
174705 606741 STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 8/21/2018 APPLICATION CHANGED FROM
CLASS I - III Gas
174727 596334 STORAGE TANK FX RF W/CTL
MISC 7/26/2017 ASSIGNED TO ENGINEER - CLASS I Misc. Materials 800436 612436 STORAGE TANK FX RF W/CTL
GASOLINE 5/3/2019 ASSIGNED TO ENGINEER - CLASS I Gasoline 800080 603730 STORAGE TANK FX RF W/CTL PET
MID DISTILL 5/8/2018 APPLICATION CHANGED FROM
CLASS I - III Pet. Mid. Dis.
800080 620866 STORAGE TANK FX RF W/CTL PET
MID DISTILL 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800080 620867 STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800080 620868 STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800080 620869 STORAGE TANK FX RF W/CTL PET
MID DISTILL 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800080 620870 STORAGE TANK FX RF W/CTL PET
MID DISTILL 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800080 620871 STORAGE TANK FX RF W/CTL PET
MID DISTILL 4/16/2020 ASSIGNED TO ENGINEER - CLASS I Pet. Mid. Dis. 800057 619038 STORAGE TANK FX RF W/INT FLT
GASOLINE 2/13/2020 ASSIGNED TO ENGINEER - CLASS I Gasoline 181667 597009 STORAGE TANK PRESSURE TANK
BUTANE 8/24/2017 APPLICATION CHANGED FROM
CLASS I - III Butane
181667 599684 STORAGE TANK W/ VAPOR
CONTROL AMMONIA 12/22/2017 APPLICATION CHANGED FROM
CLASS I - III Ammonia
181667 609401 STORAGE TANK W/ VAPOR
CONTROL AMMONIA 12/26/2018 ASSIGNED TO ENGINEER - CLASS I Ammonia 1Although the Permit to Construct has been issued by SCAQMD, the Permit to Operate for the facilities on this table with status 'Permit to Construct Granted' is still pending. See SCAQMD, Permits: Permit Types and Type of Application Permits, http://www.aqmd.gov/home/permits.
Appendix G
2 of 27
APPX_000502
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
111238 431211 G20256 8/29/2012 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/15/2004
PERMIT TO OPERATE
GRANTED Pet. Dis.
111238 560137 G34095 1/13/2015 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
111238 560138 G34224 1/22/2015 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 1/28/2014
PERMIT TO OPERATE
GRANTED Crude
111238 560139 G34225 1/22/2015 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
111238 560140 G34226 1/22/2015 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
111238 560141 G34227 1/22/2015 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
111238 560142 G34228 1/22/2015 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
111238 560143 G34229 1/22/2015 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 1/28/2014
PERMIT TO OPERATE
GRANTED Gasoline
167981 525935 G16308 12/23/2011 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 8/5/2011
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
167981 525940 G16310 12/23/2011 ACTIVE STORAGE TANK WASTE WATER 8/5/2011
PERMIT TO OPERATE
GRANTED Waste water
167981 525941 G16311 12/23/2011 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 8/5/2011
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
167981 529203 G39669 3/23/2016 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 11/15/2011
PERMIT TO OPERATE
GRANTED Hydrocarbons
167981 529205 G39670 3/23/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 11/15/2011
PERMIT TO OPERATE
GRANTED Hydrocarbons
167981 546309 G25783 7/17/2013 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 1/8/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171107 535315 G17856 5/3/2012 ACTIVE
STORAGE TANK SPENT SULFURIC
ACID 3/27/2012
PERMIT TO OPERATE
GRANTED Spent Sulfuric Acid
171107 535327 G17898 5/3/2012 ACTIVE STORAGE TANK MISC MATERIALS 3/27/2012
PERMIT TO OPERATE
GRANTED Misc. Materials
171107 535328 G17899 5/3/2012 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535329 G17900 5/3/2012 ACTIVE STORAGE TANK FUEL OIL 3/27/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171107 535333 G17902 5/3/2012 ACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 3/27/2012
PERMIT TO OPERATE
GRANTED Gas-Oil
171107 535334 G17903 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535335 G17904 5/3/2012 ACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
171107 535339 G17905 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535344 G17906 5/3/2012 ACTIVE STORAGE TANK FUEL OIL 3/27/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171107 535345 G17907 5/3/2012 ACTIVE
STORAGE TANK FX RF W/CTL
FUEL OIL 3/27/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171107 535346 G17923 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535348 G17924 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535352 G17926 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535353 G17929 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535355 G17931 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535360 G17933 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535362 G17936 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535366 G17939 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535368 G17942 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535369 G17943 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535372 G17944 5/3/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171107 535374 G17961 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535376 G17965 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535378 G17969 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535379 G17971 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535380 G17973 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535381 G17976 5/3/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
3 of 27
APPX_000503
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171107 535382 G17977 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535383 G17979 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535385 G17983 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF RESIDUAL 3/27/2012
PERMIT TO OPERATE
GRANTED Residual
171107 535387 G17987 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535388 G17988 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535389 G17990 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535391 G17994 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535393 G17998 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535395 G18001 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535396 G18003 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 3/27/2012
PERMIT TO OPERATE
GRANTED Misc. Materials
171107 535398 G18005 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535399 G18007 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535401 G18010 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535402 G18011 5/3/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535405 G18015 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535407 G18019 5/3/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535409 G18023 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535410 G18025 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535411 G18027 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535413 G18028 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535415 G18030 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535416 G18031 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF JET A 3/27/2012
PERMIT TO OPERATE
GRANTED Jet-A
171107 535417 G18033 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535418 G18034 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535422 G18038 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535425 G18041 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535426 G18042 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535427 G18044 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535428 G18046 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535429 G17851 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535430 G17853 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535431 G17855 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535432 G17858 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535433 G17861 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535434 G17862 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF JET A 3/27/2012
PERMIT TO OPERATE
GRANTED Jet-A
171107 535436 G17863 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535439 G17864 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF CHEMS INORG 3/27/2012
PERMIT TO OPERATE
GRANTED Chems. Inorg.
171107 535441 G17865 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535444 G17866 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF CHEMS INORG 3/27/2012
PERMIT TO OPERATE
GRANTED Chems. Inorg.
171107 535447 G17868 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535449 G17869 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
4 of 27
APPX_000504
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171107 535451 G17871 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF WASTE H20 3/27/2012
PERMIT TO OPERATE
GRANTED Waste water
171107 535453 G17873 5/3/2012 ACTIVE
STORAGE TANK W/EXT FLOAT
ROOF SOUR WATER 3/27/2012
PERMIT TO OPERATE
GRANTED Sour water
171107 535454 G17874 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535456 G17875 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 3/27/2012
PERMIT TO OPERATE
GRANTED LPG
171107 535457 G17876 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535458 G17877 5/3/2012 ACTIVE STORAGE TANK AMMONIA 3/27/2012
PERMIT TO OPERATE
GRANTED Ammonia
171107 535459 G17878 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535461 G17879 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535462 G17880 5/3/2012 ACTIVE STORAGE TANK AMMONIA 3/27/2012
PERMIT TO OPERATE
GRANTED Ammonia
171107 535464 G17881 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535466 G17882 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 3/27/2012
PERMIT TO OPERATE
GRANTED LPG
171107 535468 G17885 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535469 G17886 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535471 G17887 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535472 G17888 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535474 G17883 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 3/27/2012
PERMIT TO OPERATE
GRANTED Diesel
171107 535475 G17884 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535477 G17890 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535478 G17891 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535479 G17892 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535481 G17893 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535482 G17895 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171107 535484 G17896 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535502 G18049 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535503 G18050 5/3/2012 ACTIVE
STORAGE TANK OTHER W/CTL
PERCHLOROETHYLE 3/27/2012
PERMIT TO OPERATE
GRANTED Perchloroethyle
171107 535504 G18052 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535505 G18054 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535506 G18055 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535507 G18057 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535510 G18058 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535512 G18059 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535513 G18060 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535514 G18062 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535515 G18064 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535516 G18065 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535517 G18066 5/3/2012 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 3/27/2012
PERMIT TO OPERATE
GRANTED Gas
171107 535518 G18067 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535519 G18068 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535520 G18069 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535521 G18070 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF NAPHTHA 3/27/2012
PERMIT TO OPERATE
GRANTED Naphtha
171107 535523 G18071 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
5 of 27
APPX_000505
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171107 535525 G18072 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535526 G18073 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535537 G18074 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 535540 G18075 5/3/2012 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 3/27/2012
PERMIT TO OPERATE
GRANTED Gas
171107 535541 G18076 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF NAPHTHA 3/27/2012
PERMIT TO OPERATE
GRANTED Naphtha
171107 535543 G18077 5/3/2012 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 3/27/2012
PERMIT TO OPERATE
GRANTED Gas
171107 535545 G18078 5/3/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535547 G18079 5/3/2012 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 535548 G18080 5/3/2012 ACTIVE
STORAGE TANK PRESSURE TANK
BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535549 G18081 5/3/2012 ACTIVE STORAGE TANK BUTANE 3/27/2012
PERMIT TO OPERATE
GRANTED Butane
171107 535550 G18082 5/3/2012 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171107 542089 G28366 11/13/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 8/16/2012
PERMIT TO OPERATE
GRANTED Gasoline
171107 572452 G52056 5/3/2018 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 2/10/2015
PERMIT TO OPERATE
GRANTED Diesel
171107 573814 G48334 9/15/2017 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 4/1/2015
PERMIT TO OPERATE
GRANTED Gas
171109 535267 G17814 5/2/2012 ACTIVE STORAGE TANK FUEL OIL 3/27/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171109 535268 G17816 5/2/2012 ACTIVE
STORAGE TANK FX RF W/CTL
SULFUR 3/27/2012
PERMIT TO OPERATE
GRANTED Sulfur
171109 535269 G17817 5/2/2012 ACTIVE
STORAGE TANK FX RF W/CTL
SULFUR 3/27/2012
PERMIT TO OPERATE
GRANTED Sulfur
171109 535270 G17818 5/2/2012 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 3/27/2012
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
171109 535271 G17819 5/2/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535272 G17820 5/2/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535273 G17821 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535274 G17822 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171109 535275 G17823 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171109 535276 G17825 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535277 G17827 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535278 G17829 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535279 G17828 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535280 G17830 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535281 G17831 5/2/2012 ACTIVE
STORAGE TANK W/EXT FLOAT
ROOF SOUR WATER 3/27/2012
PERMIT TO OPERATE
GRANTED Sour water
171109 535282 G17832 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF WASTE H20 3/27/2012
PERMIT TO OPERATE
GRANTED Waste water
171109 535283 G17833 5/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535284 G17715 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535285 G17716 5/1/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Dis.
171109 535286 G17717 5/1/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535287 G17718 5/1/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171109 535288 G17719 5/1/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535289 G17720 5/1/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535290 G17721 9/7/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535291 G17722 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171109 535292 G17723 5/1/2012 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535293 G17724 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 3/27/2012
PERMIT TO OPERATE
GRANTED Misc. Materials
Appendix G
6 of 27
APPX_000506
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171109 535294 G17725 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535295 G17726 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535296 G17727 5/1/2012 ACTIVE
STORAGE TANK W/EXT FLOAT
ROOF SOUR WATER 3/27/2012
PERMIT TO OPERATE
GRANTED Sour water
171109 535297 G17728 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 3/27/2012
PERMIT TO OPERATE
GRANTED Misc. Materials
171109 535298 G17729 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535299 G17730 5/1/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535300 G17731 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171109 535301 G17732 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535332 G17733 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171109 535336 G17734 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 3/27/2012
PERMIT TO OPERATE
GRANTED Gasoline
171109 535338 G17735 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF NAPHTHA 3/27/2012
PERMIT TO OPERATE
GRANTED Naphtha
171109 535340 G17736 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171109 535341 G17737 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF SOLVENTS 3/27/2012
PERMIT TO OPERATE
GRANTED Solvents
171109 535347 G17738 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF SOLVENTS 3/27/2012
PERMIT TO OPERATE
GRANTED Solvents
171109 535351 G17739 5/1/2012 ACTIVE
STORAGE TANK FX RF W/CTL
MISC ORG CHEM 3/27/2012
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
171109 535356 G17740 5/1/2012 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535358 G17741 5/1/2012 ACTIVE
STORAGE TANK MISC INORGANIC
CHEMICALS 3/27/2012
PERMIT TO OPERATE
GRANTED
Misc. Inorganic
Chemicals
171109 535364 G17742 5/1/2012 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171109 535370 G17743 5/1/2012 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171109 535412 G17744 5/1/2012 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 3/27/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171109 535465 G17745 5/1/2012 INACTIVE
STORAGE CONTAIN, BAKER-TYPE
W/CTL CRUDE 3/27/2012
PERMIT TO OPERATE
GRANTED Crude
171109 535470 G17746 5/1/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Dis.
171109 535473 G17747 5/1/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 3/27/2012
PERMIT TO OPERATE
GRANTED Pet. Dis.
171109 535476 G17748 5/1/2012 ACTIVE STORAGE TANK AMMONIA 3/27/2012
PERMIT TO OPERATE
GRANTED Ammonia
171109 535483 G17750 5/1/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF NAPHTHA 3/27/2012
PERMIT TO OPERATE
GRANTED Naphtha
171109 535485 G17751 5/1/2012 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 3/27/2012
PERMIT TO OPERATE
GRANTED Gas
171109 544857 G51127 3/15/2018 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 11/27/2012
PERMIT TO OPERATE
GRANTED Gas
171109 544859 G51128 3/15/2018 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 11/27/2012
PERMIT TO OPERATE
GRANTED Gas
171109 544860 G51129 3/15/2018 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 11/27/2012
PERMIT TO OPERATE
GRANTED Gas
171109 544861 G51130 3/15/2018 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 11/27/2012
PERMIT TO OPERATE
GRANTED Gas
171109 547913 G25854 7/23/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/7/2013
PERMIT TO OPERATE
GRANTED Crude
171109 572719 G51283 3/28/2018 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 2/24/2015
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171109 572852 G51287 3/28/2018 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 2/24/2015
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171320 536476 G21848 12/4/2012 ACTIVE STORAGE TANK DIESEL 4/26/2012
PERMIT TO OPERATE
GRANTED Diesel
171320 536477 G21849 12/4/2012 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171320 536478 G21850 12/4/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171320 536479 G21851 12/4/2012 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171320 536484 G21855 12/4/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171320 587420 G43377 10/18/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 7/20/2016
PERMIT TO OPERATE
GRANTED Gasoline
171326 536489 G25388 6/28/2013 ACTIVE
STORAGE TANK OTHER W/CTL
MISC HYDROCARBS 4/26/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171326 536632 G25389 6/28/2013 ACTIVE
STORAGE TANK FX RF W/CTL
NAPHTHA 4/26/2012
PERMIT TO OPERATE
GRANTED Naphtha
Appendix G
7 of 27
APPX_000507
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171326 536634 G25390 6/28/2013 ACTIVE STORAGE TANK DIESEL 4/26/2012
PERMIT TO OPERATE
GRANTED Diesel
171326 536638 G25393 6/28/2013 INACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 4/26/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
171326 536640 G25394 6/28/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536641 G25395 6/28/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536644 G25396 6/28/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536646 G25397 6/28/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536660 G25404 6/28/2013 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 4/26/2012
PERMIT TO OPERATE
GRANTED Gas
171326 536662 G25405 6/28/2013 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 4/26/2012
PERMIT TO OPERATE
GRANTED Gas
171326 536701 G25406 6/28/2013 INACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 4/26/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171326 536745 G25407 6/28/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536746 G25408 6/28/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171326 536752 G25413 6/28/2013 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 4/26/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171326 540217 G46362 5/3/2017 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/28/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
171326 544827 G46363 5/3/2017 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 11/21/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
171326 563643 G46364 5/3/2017 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 4/15/2014
PERMIT TO OPERATE
GRANTED Hydrocarbons
171326 563644 G46365 5/3/2017 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/15/2014
PERMIT TO OPERATE
GRANTED Gasoline
171327 536494 G25989 7/31/2013 ACTIVE
STORAGE TANK OTHER
SOLVENTS N.E.C. 4/26/2012
PERMIT TO OPERATE
GRANTED Solvents
171327 536500 G26013 7/31/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536501 G25995 7/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536502 G25996 7/31/2013 ACTIVE STORAGE TANK FUEL OIL 4/26/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171327 536503 G26014 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536505 G26015 7/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536506 G25997 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536509 G25998 7/31/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536510 G25999 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536511 G26000 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536526 G26001 7/31/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536528 G26002 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536529 G26003 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF FUEL OIL 4/26/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171327 536530 G26004 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF FUEL OIL 4/26/2012
PERMIT TO OPERATE
GRANTED Fuel Oil
171327 536531 G26005 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536532 G26006 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536533 G26007 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 536534 G26008 7/31/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 4/26/2012
PERMIT TO OPERATE
GRANTED Crude
171327 536535 G26009 7/31/2013 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 4/26/2012
PERMIT TO OPERATE
GRANTED Gas
171327 536536 G26010 7/31/2013 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 4/26/2012
PERMIT TO OPERATE
GRANTED Gas
171327 536537 G26011 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171327 537347 G26012 7/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171329 536543 G21342 11/7/2012 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171329 536545 G21345 11/7/2012 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 4/26/2012
PERMIT TO OPERATE
GRANTED Gasoline
171329 536554 G21343 11/7/2012 INACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 4/26/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
Appendix G
8 of 27
APPX_000508
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
171329 596764 G51123 3/14/2018 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 8/9/2017
PERMIT TO OPERATE
GRANTED Hydrocarbons
172878 544080 G26546 8/27/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 10/18/2012
PERMIT TO OPERATE
GRANTED Crude
172878 544081 G26796 9/4/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 10/18/2012
PERMIT TO OPERATE
GRANTED Crude
172878 544082 G26547 8/27/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 10/18/2012
PERMIT TO OPERATE
GRANTED Crude
172878 544083 G26548 8/27/2013 INACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 10/18/2012
PERMIT TO OPERATE
GRANTED Crude
172878 544084 G26549 8/27/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 10/18/2012
PERMIT TO OPERATE
GRANTED Crude
172878 544086 G26551 8/27/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 10/18/2012
PERMIT TO OPERATE
GRANTED Misc. Materials
172878 572674 G38856 1/19/2016 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 2/24/2015
PERMIT TO OPERATE
GRANTED Crude
173239 545842 G22462 1/17/2013 INACTIVE
STORAGE TANK W/ EXT
FLOAT ROOF HYDROCARB 12/19/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
173239 545843 G22463 1/17/2013 INACTIVE
STORAGE TANK W/ EXT
FLOAT ROOF HYDROCARB 12/19/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
173239 545844 G22464 1/17/2013 INACTIVE
STORAGE TANK W/ EXT
FLOAT ROOF HYDROCARB 12/19/2012
PERMIT TO OPERATE
GRANTED Hydrocarbons
174591 552310 G27466 10/1/2013 ACTIVE STORAGE TANK DIESEL 6/5/2013
PERMIT TO OPERATE
GRANTED Diesel
174591 552315 G27469 10/1/2013 ACTIVE
STORAGE TANK ASPHALT
<=50,000 GALLONS 6/5/2013
PERMIT TO OPERATE
GRANTED Asphalt
174591 552342 G27482 10/1/2013 ACTIVE STORAGE TANK COKE 6/5/2013
PERMIT TO OPERATE
GRANTED Coke
174591 552345 G27483 10/1/2013 ACTIVE STORAGE TANK COKE 6/5/2013
PERMIT TO OPERATE
GRANTED Coke
174591 552348 G27484 10/1/2013 ACTIVE STORAGE TANK COKE 6/5/2013
PERMIT TO OPERATE
GRANTED Coke
174591 552350 G27485 10/1/2013 ACTIVE STORAGE TANK COKE 6/5/2013
PERMIT TO OPERATE
GRANTED Coke
174591 552356 G27487 10/1/2013 ACTIVE
STORAGE TANK PETROLEUM
COKE 6/5/2013
PERMIT TO OPERATE
GRANTED Petroleum Coke
174655 552769 G24861 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552770 G24862 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552824 G24918 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
WASTE WATER 6/5/2013
PERMIT TO OPERATE
GRANTED Waste water
174655 552827 G24921 6/19/2013 INACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552829 G24923 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
SULFURIC ACID 6/5/2013
PERMIT TO OPERATE
GRANTED Sulfuric Acid
174655 552831 G24925 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552834 G24928 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552837 G24931 6/19/2013 INACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552840 G24934 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552844 G24938 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552845 G24939 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552848 G24941 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 552851 G24943 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 552855 G24946 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 552856 G24947 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552859 G24950 6/19/2013 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
174655 552861 G24952 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
WASTE WATER 6/5/2013
PERMIT TO OPERATE
GRANTED Waste water
174655 552862 G24953 6/19/2013 ACTIVE
STORAGE TANK OTHER
SOLVENTS N.E.C. 6/5/2013
PERMIT TO OPERATE
GRANTED Solvents
174655 552864 G24955 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552866 G24956 6/19/2013 ACTIVE STORAGE TANK TOLUENE 6/5/2013
PERMIT TO OPERATE
GRANTED Toluene
174655 552869 G24959 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552871 G24961 6/19/2013 ACTIVE STORAGE TANK BENZENE 6/5/2013
PERMIT TO OPERATE
GRANTED Benzene
174655 552873 G24963 6/19/2013 INACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
Appendix G
9 of 27
APPX_000509
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174655 552875 G24964 6/19/2013 INACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552876 G24965 6/19/2013 ACTIVE STORAGE TANK GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552877 G24966 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 552880 G24968 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552882 G24970 6/19/2013 ACTIVE
STORAGE TANK OTHER W/CTL
SULFUR 6/5/2013
PERMIT TO OPERATE
GRANTED Sulfur
174655 552884 G24972 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552887 G24973 6/19/2013 ACTIVE
STORAGE TANK OTHER W/CTL
SULFUR 6/5/2013
PERMIT TO OPERATE
GRANTED Sulfur
174655 552889 G24975 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552892 G24978 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552895 G24981 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552897 G24983 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552901 G24874 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552904 G24881 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552907 G24886 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552909 G24991 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552912 G24994 6/19/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552915 G24996 6/19/2013 ACTIVE
STORAGE TANK ORGANIC
CHEMICALS MISC 6/5/2013
PERMIT TO OPERATE
GRANTED
Organic Chemicals
Misc.
174655 552918 G24998 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552921 G25001 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 552924 G25004 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 552928 G25008 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552929 G25009 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
SOLVENTS N E C 6/5/2013
PERMIT TO OPERATE
GRANTED Solvents
174655 552932 G25012 6/19/2013 INACTIVE STORAGE TANK GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552938 G25017 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552942 G25020 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552944 G25022 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552946 G25024 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552948 G25025 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552951 G25026 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552953 G25027 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 552957 G25029 6/19/2013 ACTIVE STORAGE TANK W/CTL LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552958 G25030 6/19/2013 ACTIVE STORAGE TANK W/CTL LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552960 G25032 6/19/2013 ACTIVE STORAGE TANK LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552961 G25033 6/19/2013 ACTIVE STORAGE TANK W/CTL LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552963 G25036 6/19/2013 ACTIVE STORAGE TANK BUTYLENES 6/5/2013
PERMIT TO OPERATE
GRANTED Butylenes
174655 552966 G25040 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552968 G25042 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552969 G25043 6/19/2013 ACTIVE STORAGE TANK BUTYLENES 6/5/2013
PERMIT TO OPERATE
GRANTED Butylenes
174655 552970 G25044 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552972 G25045 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552973 G25046 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
Appendix G
10 of 27
APPX_000510
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174655 552975 G25048 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552976 G25049 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552977 G25050 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552978 G25051 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552980 G25052 6/19/2013 INACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552981 G25053 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552983 G25055 6/19/2013 ACTIVE STORAGE TANK W/CTL LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 552984 G25056 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552985 G25057 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 552987 G25059 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552988 G25060 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552989 G25061 6/19/2013 INACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 552990 G25062 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 552991 G25063 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552992 G25064 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF SOLVENTS 6/5/2013
PERMIT TO OPERATE
GRANTED Solvents
174655 552993 G25065 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552995 G25067 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552996 G25068 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 552997 G25069 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 552998 G25070 6/19/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 552999 G25071 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553000 G25073 6/19/2013 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
174655 553001 G25074 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553002 G25075 6/19/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553003 G25076 6/19/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553004 G25077 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553005 G25078 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553006 G25079 6/19/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553007 G25080 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553009 G25082 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553010 G25083 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553011 G25084 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553012 G25085 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553013 G25086 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553014 G25087 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553015 G25088 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553017 G25090 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553018 G25091 6/19/2013 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
174655 553020 G25093 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553022 G25095 6/19/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553024 G25097 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
11 of 27
APPX_000511
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174655 553026 G25099 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553028 G25100 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553029 G25101 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553030 G25102 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553032 G25104 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553034 G25106 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553035 G25107 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553038 G25110 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553039 G25111 6/19/2013 INACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
174655 553041 G25113 6/19/2013 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 6/5/2013
PERMIT TO OPERATE
GRANTED Gas
174655 553042 G25114 6/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553045 G25117 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553046 G25118 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553047 G25119 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553052 G25122 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553053 G25123 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553056 G25209 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553059 G25128 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553060 G25129 6/19/2013 ACTIVE STORAGE TANK FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553062 G25131 6/19/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553064 G25133 6/19/2013 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553066 G25135 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553068 G25137 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553070 G25139 6/19/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553077 G25145 6/19/2013 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553078 G25146 6/19/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553079 G25147 6/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553080 G25148 6/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553083 G25151 6/19/2013 ACTIVE
STORAGE TANK PROPYLENE &
POLYPROPYLENE 6/5/2013
PERMIT TO OPERATE
GRANTED
Propylene &
Polypropylene
174655 553087 G25154 6/19/2013 ACTIVE
STORAGE TANK POLYVINYL
CHLORIDE 6/5/2013
PERMIT TO OPERATE
GRANTED Polyvinyl Chloride
174655 553089 G25156 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553092 G25159 6/19/2013 ACTIVE STORAGE TANK WASTE WATER 6/5/2013
PERMIT TO OPERATE
GRANTED Waste water
174655 553107 G25172 6/19/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553109 G25174 6/19/2013 ACTIVE STORAGE TANK GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553116 G25177 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553118 G25178 6/19/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF FUEL OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Fuel Oil
174655 553121 G25180 6/19/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553123 G25183 6/19/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 553125 G25185 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553128 G25187 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174655 553130 G25189 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
Appendix G
12 of 27
APPX_000512
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174655 553133 G25190 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553135 G25192 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553138 G25193 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553140 G25194 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553143 G25195 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553145 G25196 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553146 G25197 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553147 G25198 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553148 G25199 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553149 G25200 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553150 G25201 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553152 G25202 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553153 G25203 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553154 G25204 6/19/2013 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 6/5/2013
PERMIT TO OPERATE
GRANTED LPG
174655 553167 G26149 8/7/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553175 G49315 11/17/2017 ACTIVE STORAGE TANK AMMONIA 6/5/2013
PERMIT TO OPERATE
GRANTED Ammonia
174655 553180 G29114 12/20/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553184 G26954 9/10/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553185 G28049 10/30/2013 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 553186 G49316 11/17/2017 ACTIVE STORAGE TANK AMMONIA 6/5/2013
PERMIT TO OPERATE
GRANTED Ammonia
174655 553187 G28004 10/29/2013 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 553189 G28046 10/30/2013 ACTIVE
STORAGE TANK FX RF W/CTL
MISC 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174655 553192 G25205 6/19/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174655 557871 G30133 2/26/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GAS-OIL 11/6/2013
PERMIT TO OPERATE
GRANTED Gas-Oil
174655 557872 G30134 2/26/2014 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GAS-OIL 11/6/2013
PERMIT TO OPERATE
GRANTED Gas-Oil
174655 561258 G49314 11/17/2017 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/28/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174655 566352 G46222 4/25/2017 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 6/27/2014
PERMIT TO OPERATE
GRANTED Hydrocarbons
174655 573556 G54192 9/21/2018 INACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 3/24/2015
PERMIT TO OPERATE
GRANTED Gas-Oil
174655 598488 G60954 3/13/2020 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GAS-OIL 10/31/2017
PERMIT TO OPERATE
GRANTED Gas-Oil
174655 611843 G61904 6/4/2020 ACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 4/12/2019
PERMIT TO OPERATE
GRANTED Gas-Oil
174694 552532 G28162 11/1/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174694 552535 G28163 11/1/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174694 552538 G28164 11/1/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174694 552541 G28165 11/1/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174694 552543 G28166 11/1/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174694 552545 G28167 11/1/2013 ACTIVE STORAGE TANK JET-A 6/5/2013
PERMIT TO OPERATE
GRANTED Jet-A
174694 569077 G46956 6/19/2017 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/14/2014
PERMIT TO OPERATE
GRANTED Crude
174694 569078 G46957 6/19/2017 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/14/2014
PERMIT TO OPERATE
GRANTED Crude
174694 569079 G46958 6/19/2017 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/14/2014
PERMIT TO OPERATE
GRANTED Crude
174694 581041 G46959 6/19/2017 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 1/13/2016
PERMIT TO OPERATE
GRANTED Crude
174694 615957 G61906 6/4/2020 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 9/18/2019
PERMIT TO OPERATE
GRANTED Crude
Appendix G
13 of 27
APPX_000513
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174704 552586 G28101 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552588 G28102 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552590 G28103 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552594 G28104 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552597 G28105 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552599 G28106 10/31/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552605 G28109 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552608 G28110 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552610 G28111 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552612 G28112 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552615 G28113 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552617 G28114 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552620 G28116 10/31/2013 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174704 552642 G28126 10/31/2013 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552644 G28127 10/31/2013 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552645 G28128 10/31/2013 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552649 G28131 10/31/2013 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174704 552650 G28132 10/31/2013 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552651 G28133 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552652 G28134 10/31/2013 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174704 552653 G28135 10/31/2013 ACTIVE
STORAGE TANK FX RF W/ INT FLT
MTBE 6/5/2013
PERMIT TO OPERATE
GRANTED MTBE
174704 552654 G28136 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552655 G28137 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552656 G28138 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552657 G28139 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552658 G28140 10/31/2013 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174704 552660 G28142 10/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 552661 G28143 10/31/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174704 594228 G49085 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174704 594230 G49086 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174704 594231 G49087 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174704 594232 G49088 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174704 594234 G49089 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174704 594235 G49090 11/7/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 5/17/2017
PERMIT TO OPERATE
GRANTED Gasoline
174705 552593 G29333 1/10/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552596 G29335 1/10/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552598 G29336 1/10/2014 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 6/4/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174705 552600 G29337 1/10/2014 ACTIVE
STORAGE TANK FX RF W/CTL
WASTE WATER 6/5/2013
PERMIT TO OPERATE
GRANTED Waste water
174705 552601 G29338 1/10/2014 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552603 G29339 1/10/2014 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552606 G29340 1/10/2014 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
14 of 27
APPX_000514
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174705 552607 G29341 1/10/2014 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552611 G29343 1/10/2014 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174705 552614 G29345 1/10/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174710 552688 G27774 10/16/2013 ACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174710 552690 G27776 10/16/2013 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552755 G27778 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552756 G27779 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552757 G27780 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552758 G27781 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552759 G27782 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 552760 G27783 10/16/2013 ACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174710 553201 G27796 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 553202 G27797 10/16/2013 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174710 553203 G27798 10/16/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
174726 553210 G28504 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553211 G28505 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553212 G28506 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553213 G28507 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553214 G28508 11/19/2013 INACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
174726 553216 G28510 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553217 G28511 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553219 G28513 11/19/2013 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174726 553220 G28514 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174726 553221 G28515 11/19/2013 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174726 553222 G28516 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174726 553223 G28517 11/19/2013 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174726 553224 G28518 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174726 553225 G28519 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174726 553226 G28520 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553227 G28521 11/19/2013 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174726 553228 G28522 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553229 G28523 11/19/2013 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
174726 553230 G28524 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553231 G28525 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174726 553232 G28534 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174726 553233 G28537 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553234 G28538 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/5/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
174726 553235 G28539 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553236 G28540 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553237 G28541 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/5/2013
PERMIT TO OPERATE
GRANTED Gasoline
174726 553238 G28542 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
Appendix G
15 of 27
APPX_000515
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
174726 553239 G28543 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553240 G28544 11/19/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/5/2013
PERMIT TO OPERATE
GRANTED Crude
174726 553241 G28545 11/19/2013 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174726 553242 G28546 11/19/2013 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174726 553243 G28547 11/19/2013 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174726 553244 G28548 11/19/2013 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
174726 553246 G28550 11/19/2013 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/5/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
174727 553194 G27294 9/19/2013 ACTIVE STORAGE TANK MISC MATERIALS 6/5/2013
PERMIT TO OPERATE
GRANTED Misc. Materials
176377 558880 G29463 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558881 G29464 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558882 G29465 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558883 G29466 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558884 G29467 1/17/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558885 G29468 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558886 G29469 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558891 G29471 1/17/2014 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558892 G29472 1/17/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558893 G29473 1/17/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558894 G29474 1/17/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558895 G29475 1/17/2014 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Dis.
176377 558896 G29476 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 12/11/2013
PERMIT TO OPERATE
GRANTED Gasoline
176377 558897 G29477 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 12/11/2013
PERMIT TO OPERATE
GRANTED Gasoline
176377 558898 G29478 1/17/2014 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558899 G29479 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558900 G29480 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558903 G29483 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 12/11/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
176377 558905 G29484 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 12/11/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
176377 558910 G29485 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 12/11/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
176377 558913 G29486 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 12/11/2013
PERMIT TO OPERATE
GRANTED Gasoline
176377 558915 G29487 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558918 G29489 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558920 G29490 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558922 G29491 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 12/11/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
176377 558924 G29492 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 12/11/2013
PERMIT TO OPERATE
GRANTED Gasoline
176377 558926 G29493 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558928 G29494 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558929 G29495 1/17/2014 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 12/11/2013
PERMIT TO OPERATE
GRANTED Crude
176377 558930 G29496 1/17/2014 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 12/11/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
176377 558931 G29497 1/17/2014 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 12/11/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
176377 558932 G29498 1/17/2014 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 12/11/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
176377 558934 G29499 1/17/2014 INACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 12/11/2013
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
Appendix G
16 of 27
APPX_000516
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
176377 558939 G29501 1/17/2014 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 12/11/2013
PERMIT TO OPERATE
GRANTED Hydrocarbons
176377 573232 G36395 7/2/2015 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 3/13/2015
PERMIT TO OPERATE
GRANTED Crude
182752 586908 G42724 9/9/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182752 586909 G42725 9/9/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182752 586910 G42748 9/12/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182752 586911 G42726 9/9/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182752 586912 G42727 9/9/2016 ACTIVE STORAGE TANK WASTE WATER 6/30/2016
PERMIT TO OPERATE
GRANTED Waste water
182752 586913 G42729 9/9/2016 ACTIVE STORAGE TANK DIESEL 6/30/2016
PERMIT TO OPERATE
GRANTED Diesel
182752 586914 G42730 9/9/2016 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Dis.
182752 586917 G42733 9/9/2016 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Dis.
182752 586919 G42735 9/9/2016 ACTIVE STORAGE TANK MISC MATERIALS 6/30/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
182752 586920 G42736 9/9/2016 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182752 586921 G42737 9/9/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182752 586923 G42739 9/9/2016 ACTIVE STORAGE TANK DIESEL 6/30/2016
PERMIT TO OPERATE
GRANTED Diesel
182752 586925 G42741 9/9/2016 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Dis.
182752 586926 G42742 9/9/2016 ACTIVE STORAGE TANK ALCOHOLS 6/30/2016
PERMIT TO OPERATE
GRANTED Alcohols
182753 586986 G43132 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF FUEL OIL 6/30/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
182753 586987 G43133 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182753 586988 G43134 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182753 586989 G43135 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182753 586990 G43136 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
182753 586991 G43137 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
182753 586992 G43138 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182753 586993 G43139 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182753 586994 G43140 10/6/2016 ACTIVE STORAGE TANK WASTE WATER 6/30/2016
PERMIT TO OPERATE
GRANTED Waste water
182753 586995 G43141 10/6/2016 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
182753 586996 G43142 10/6/2016 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
182753 586997 G43143 10/6/2016 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
182753 586998 G43144 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182753 586999 G43145 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182753 587001 G43147 10/6/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182753 587003 G43149 10/6/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182753 587005 G43151 10/6/2016 INACTIVE STORAGE TANK RESIDUAL OIL 6/30/2016
PERMIT TO OPERATE
GRANTED Residual Oil
182753 587006 G43152 10/6/2016 ACTIVE STORAGE TANK FUEL OIL 6/30/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
182753 587008 G43154 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF FUEL OIL 6/30/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
182753 587011 G43157 10/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
MISC 6/30/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
182753 587012 G43158 10/6/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/30/2016
PERMIT TO OPERATE
GRANTED Crude
182753 587014 G43160 10/6/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 6/30/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
182753 590236 G45089 2/22/2017 ACTIVE STORAGE TANK RESIDUAL OIL 11/17/2016
PERMIT TO OPERATE
GRANTED Residual Oil
182822 587347 G43172 10/7/2016 INACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 587350 G43175 10/7/2016 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
17 of 27
APPX_000517
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
182822 587352 G43177 10/7/2016 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 6/30/2016
PERMIT TO OPERATE
GRANTED Pet. Dis.
182822 587354 G43179 10/7/2016 INACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 587355 G43180 10/7/2016 INACTIVE
STORAGE TNK,W/PASSIVE
CARBN,GASLN,s.s. 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 587356 G43181 10/7/2016 INACTIVE
STORAGE TNK,W/PASSIVE
CARBN,GASLN,s.s. 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 587357 G43182 10/7/2016 INACTIVE
STORAGE TNK,W/PASSIVE
CARBN,GASLN,s.s. 6/30/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 589837 G44659 1/30/2017 INACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 11/8/2016
PERMIT TO OPERATE
GRANTED Gasoline
182822 589838 G44661 1/30/2017 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 11/8/2016
PERMIT TO OPERATE
GRANTED Gasoline
800436 509881 G11756 2/4/2011 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 4/14/2010
PERMIT TO OPERATE
GRANTED Hydrocarbons
800436 509883 G9231 7/16/2010 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 4/14/2010
PERMIT TO OPERATE
GRANTED Hydrocarbons
800436 515442 G11754 2/4/2011 INACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 10/14/2010
PERMIT TO OPERATE
GRANTED Pet. Dis.
800436 518304 G13642 6/2/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/1/2011
PERMIT TO OPERATE
GRANTED Gasoline
800436 519205 G14567 8/11/2011 ACTIVE
STORAGE TANK OTHER W/CTL
CAUSTIC 2/25/2011
PERMIT TO OPERATE
GRANTED Caustic
800436 519207 G14568 8/11/2011 ACTIVE
STORAGE TANK OTHER W/CTL
CAUSTIC 2/25/2011
PERMIT TO OPERATE
GRANTED Caustic
800436 519208 G14569 8/11/2011 ACTIVE
STORAGE TANK OTHER W/CTL
CAUSTIC 2/25/2011
PERMIT TO OPERATE
GRANTED Caustic
800436 519209 G14570 8/11/2011 ACTIVE
STORAGE TANK OTHER W/CTL
CAUSTIC 2/25/2011
PERMIT TO OPERATE
GRANTED Caustic
800436 520256 G14316 7/19/2011 INACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 3/25/2011
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800436 529876 G17572 4/18/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/13/2011
PERMIT TO OPERATE
GRANTED Pet. Dis.
800436 529906 G17571 4/18/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/13/2011
PERMIT TO OPERATE
GRANTED Pet. Dis.
800436 529993 G17569 4/18/2012 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 12/15/2011
PERMIT TO OPERATE
GRANTED Pet. Dis.
800436 530223 G17570 4/18/2012 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/23/2011
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800436 532207 G21291 11/2/2012 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/10/2012
PERMIT TO OPERATE
GRANTED Gasoline
800436 535086 G21290 11/2/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 4/13/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800436 544561 G24483 5/15/2013 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 11/15/2012
PERMIT TO OPERATE
GRANTED Pet. Dis.
800436 556835 G49794 12/15/2017 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 10/8/2013
PERMIT TO OPERATE
GRANTED Crude
800436 559086 G32181 7/24/2014 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/18/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800436 601170 G53648 8/8/2018 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/27/2018
PERMIT TO OPERATE
GRANTED Gasoline
800198 443859 G18976 7/5/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 5/13/2005
PERMIT TO OPERATE
GRANTED Gasoline
800198 443860 G18977 7/5/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 5/13/2005
PERMIT TO OPERATE
GRANTED Gasoline
800198 443861 G18978 7/5/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 5/13/2005
PERMIT TO OPERATE
GRANTED Gasoline
800198 443862 G18979 7/5/2012 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 5/13/2005
PERMIT TO OPERATE
GRANTED Gasoline
800198 448253 G18980 7/5/2012 ACTIVE
STORAGE TANK OTHER W/CTL
MISC PRODUCTS 8/31/2005
PERMIT TO OPERATE
GRANTED Misc. Materials
800198 448254 G18981 7/5/2012 ACTIVE
STORAGE TANK OTHER W/CTL
MISC PRODUCTS 8/31/2005
PERMIT TO OPERATE
GRANTED Misc. Materials
800198 448255 G18982 7/5/2012 ACTIVE
STORAGE TANK OTHER W/CTL
MISC PRODUCTS 8/31/2005
PERMIT TO OPERATE
GRANTED Misc. Materials
800198 448256 G18983 7/5/2012 ACTIVE
STORAGE TANK OTHER W/CTL
MISC PRODUCTS 8/31/2005
PERMIT TO OPERATE
GRANTED Misc. Materials
800080 311106 G11278 1/6/2011 INACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 1/2/1996
PERMIT TO OPERATE
GRANTED Asphalt
800080 311478 G11277 1/6/2011 INACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 1/24/1996
PERMIT TO OPERATE
GRANTED Asphalt
800080 311480 G11276 1/6/2011 INACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 1/24/1996
PERMIT TO OPERATE
GRANTED Asphalt
800080 346308 G29170 12/26/2013 INACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/20/1998
PERMIT TO OPERATE
GRANTED Asphalt
800080 426410 G25521 7/3/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426411 G29186 12/26/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426412 G27847 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
Appendix G
18 of 27
APPX_000518
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
800080 426413 G29171 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426415 G27850 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426416 G27851 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426418 G27848 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426419 G27849 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426421 G29172 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 426422 G27852 10/18/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 3/2/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 493998 G29176 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 493999 G29177 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 494000 G29179 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 494001 G29180 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 494002 G29181 12/26/2013 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 494003 G29187 12/26/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 494004 G29182 12/26/2013 INACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 12/17/2008
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 539681 G46148 4/14/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 6/29/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 540826 G46147 4/14/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 7/26/2012
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 556990 G57442 5/29/2019 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/8/2013
PERMIT TO OPERATE
GRANTED Asphalt
800080 556992 G49458 11/28/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 10/8/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 556993 G49457 11/28/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 10/8/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 556994 G49456 11/28/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 10/8/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 556995 G49455 11/28/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 10/8/2013
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 564003 G48967 10/30/2017 ACTIVE STORAGE TANK WASTE OIL 5/1/2014
PERMIT TO OPERATE
GRANTED Waste oil
800080 564008 G51921 4/25/2018 ACTIVE
STORAGE TANK ASPHALT
<=50,000 GALLONS 5/1/2014
PERMIT TO OPERATE
GRANTED Asphalt
800080 564022 G49484 11/29/2017 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 5/1/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 564025 G49486 11/29/2017 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 5/1/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 564027 G49489 11/29/2017 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 5/1/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 564028 G49485 11/29/2017 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 5/1/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 564037 G49488 11/29/2017 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 5/1/2014
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 575578 G39544 3/16/2016 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 5/27/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 575579 G39543 3/16/2016 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 5/27/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 578903 G52272 5/16/2018 INACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/13/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 578904 G52275 5/16/2018 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/13/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 578905 G52273 5/16/2018 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/13/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 578906 G52274 5/16/2018 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/13/2015
PERMIT TO OPERATE
GRANTED Asphalt
800080 585587 G50169 1/17/2018 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 5/20/2016
PERMIT TO OPERATE
GRANTED Crude
800080 586970 G49129 11/8/2017 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 7/6/2016
PERMIT TO OPERATE
GRANTED Asphalt
800080 588765 G50171 1/17/2018 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 9/4/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
800080 589462 G54241 9/27/2018 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/14/2016
PERMIT TO OPERATE
GRANTED Asphalt
800080 589463 G54242 9/27/2018 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 10/14/2016
PERMIT TO OPERATE
GRANTED Asphalt
800080 597148 G62751 9/9/2020 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 8/30/2017
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 612432 G61752 5/20/2020 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 5/3/2019
PERMIT TO OPERATE
GRANTED Asphalt
Appendix G
19 of 27
APPX_000519
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
800080 613090 G60342 2/4/2020 ACTIVE
STORAGE TANK, ASPHALT >50,000
GALLONS 5/29/2019
PERMIT TO OPERATE
GRANTED Asphalt
800080 617116 G61753 5/20/2020 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 11/15/2019
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800080 617117 G62225 7/1/2020 ACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 11/15/2019
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
800080 617118 G62226 7/1/2020 ACTIVE
STORAGE TANK MISC ORGANIC
MATERIALS 11/15/2019
PERMIT TO OPERATE
GRANTED
Misc. Organic
Materials
800057 411564 G13971 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/7/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 411616 G13972 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/7/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416251 G15701 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416252 G15702 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416253 G15703 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416254 G15704 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416255 G15705 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416257 G15706 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416258 G15707 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 416259 G15708 11/4/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/30/2003
PERMIT TO OPERATE
GRANTED Gasoline
800057 427125 G13973 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/17/2004
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
800057 446094 G13974 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/8/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446095 G13975 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/8/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446096 G13976 6/28/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 6/8/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446894 G13977 6/28/2011 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 7/27/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446922 G13978 6/28/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 7/27/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446923 G13979 6/28/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 7/29/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 446926 G13980 6/28/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 7/29/2005
PERMIT TO OPERATE
GRANTED Gasoline
800057 460377 G13981 6/28/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 9/20/2006
PERMIT TO OPERATE
GRANTED Gasoline
800057 463461 G13982 6/28/2011 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 12/5/2006
PERMIT TO OPERATE
GRANTED Gas
800057 466317 G6027 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466318 G6033 1/1/2010 INACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466319 G6037 1/1/2010 INACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466320 G6038 1/1/2010 INACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466321 G6081 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466323 G6083 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466324 G6084 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466325 G6086 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466326 G6092 1/1/2010 INACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466327 G6096 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466328 G6099 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466329 G6101 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466330 G6102 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466331 G6104 1/1/2010 ACTIVE
STORAGE TANK FX RF W/ INT
FLOATER CRUDE 3/9/2007
PERMIT TO OPERATE
GRANTED Crude
800057 466332 G6108 1/1/2010 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 3/9/2007
PERMIT TO OPERATE
GRANTED Gasoline
800057 466333 G6109 1/1/2010 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 3/9/2007
PERMIT TO OPERATE
GRANTED Gasoline
800057 466335 G6111 1/1/2010 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 3/9/2007
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
20 of 27
APPX_000520
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
800057 506636 G11310 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506637 G11311 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506638 G11312 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506639 G11313 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506640 G11314 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506641 G11315 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 506642 G11316 1/10/2011 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 2/9/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 509918 G42888 9/23/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 4/15/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 509927 G42889 9/23/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 4/15/2010
PERMIT TO OPERATE
GRANTED Gasoline
800057 530391 G18333 5/17/2012 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 12/28/2011
PERMIT TO OPERATE
GRANTED Gasoline
800057 530481 G22194 12/21/2012 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 12/16/2011
PERMIT TO OPERATE
GRANTED Gasoline
800057 585264 G42897 9/23/2016 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 5/4/2016
PERMIT TO OPERATE
GRANTED Gasoline
800057 597863 G54537 10/5/2018 ACTIVE
STORAGE TANK,
UNDERGROUND, WASTE OIL 9/28/2017
PERMIT TO OPERATE
GRANTED Waste oil
800057 597864 G54539 10/5/2018 ACTIVE
STORAGE TANK,
UNDERGROUND, WASTE OIL 9/28/2017
PERMIT TO OPERATE
GRANTED Waste oil
800057 597865 G54540 10/5/2018 ACTIVE
STORAGE TANK,
UNDERGROUND, WASTE FUELS 9/28/2017
PERMIT TO OPERATE
GRANTED Waste fuels
800057 597866 G54541 10/5/2018 ACTIVE
STORAGE TANK UNDERGROUND
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
800057 597867 G54543 10/5/2018 ACTIVE
STORAGE TANK,
UNDERGROUND, WASTE FUELS 9/28/2017
PERMIT TO OPERATE
GRANTED Waste fuels
800057 606414 G55650 1/9/2019 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 8/8/2018
PERMIT TO OPERATE
GRANTED Gasoline
800057 606415 G55651 1/9/2019 ACTIVE
STORAGE TANK FX RF W/INT FLT
GASOLINE 8/8/2018
PERMIT TO OPERATE
GRANTED Gasoline
800026 420486 G27000 9/12/2013 ACTIVE STORAGE TANK WASTE WATER 9/23/2003
PERMIT TO OPERATE
GRANTED Waste water
800026 433988 G14535 8/10/2011 INACTIVE
STORAGE TANK FX RF W/CTL
SULFUR
8/31/2004
PERMIT TO OPERATE
GRANTED Sulfur
800026 433989 G14536 8/10/2011 ACTIVE
STORAGE TANK FX RF W/CTL
SULFUR 8/31/2004
PERMIT TO OPERATE
GRANTED Sulfur
800026 433990 G14537 8/10/2011 ACTIVE STORAGE TANK SULFUR 8/31/2004
PERMIT TO OPERATE
GRANTED Sulfur
800026 465213 G22717 1/29/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/6/2007
PERMIT TO OPERATE
GRANTED Crude
800026 465214 G22720 1/29/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/6/2007
PERMIT TO OPERATE
GRANTED Crude
800026 465215 G22723 1/29/2013 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE
2/6/2007
PERMIT TO OPERATE
GRANTED Crude
800026 465216 G22719 1/29/2013 INACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE
2/6/2007
PERMIT TO OPERATE
GRANTED Crude
800026 526261 G16203 12/16/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB
8/23/2011
PERMIT TO OPERATE
GRANTED Hydrocarbons
800026 526586 G16202 12/16/2011 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GAS-OIL 8/12/2011
PERMIT TO OPERATE
GRANTED Gas-Oil
800026 533688 G18299 5/15/2012 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 3/13/2012
PERMIT TO OPERATE
GRANTED Gas
800026 568889 G47723 8/1/2017 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 10/3/2014
PERMIT TO OPERATE
GRANTED Crude
800026 568890 G40483 6/2/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE
10/3/2014
PERMIT TO OPERATE
GRANTED Crude
800026 568891 G51371 4/4/2018 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB
10/3/2014
PERMIT TO OPERATE
GRANTED Hydrocarbons
800026 573521 G49725 12/12/2017 ACTIVE
STORAGE TANK W/INT. FLOAT
ROOF WASTE H20
3/20/2015
PERMIT TO OPERATE
GRANTED Waste water
800026 594704 G57915 6/28/2019 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 6/2/2017
PERMIT TO OPERATE
GRANTED Crude
181667 581864 G41141 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 581867 G41147 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581899 G41169 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
NAPHTHA 2/12/2016
PERMIT TO OPERATE
GRANTED Naphtha
181667 581904 G41174 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
FUEL OIL
2/12/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
181667 581905 G41175 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
FUEL OIL
2/12/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
181667 581906 G41176 7/1/2016 ACTIVE
Storage Tank W/EST Floatiing Roof JP-
5 2/12/2016
PERMIT TO OPERATE
GRANTED JP-5
Appendix G
21 of 27
APPX_000521
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
181667 581907 G41178 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581908 G41180 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581914 G41190 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF DIESEL 2/12/2016
PERMIT TO OPERATE
GRANTED Diesel
181667 581915 G41191 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 581917 G41193 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581918 G41195 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581919 G41197 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581920 G41199 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581921 G41201 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF WASTE H20 2/12/2016
PERMIT TO OPERATE
GRANTED Waste water
181667 581922 G41204 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581923 G41206 7/1/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 581925 G41208 7/1/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 581926 G41210 7/1/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 581928 G41215 7/1/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 581932 G41222 7/1/2016 ACTIVE STORAGE TANK LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 581933 G41223 7/1/2016 INACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 581936 G41229 7/1/2016 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
181667 581939 G41234 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 581940 G41235 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 581941 G41238 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 581942 G41240 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 581943 G41243 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581945 G41245 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581947 G41247 7/1/2016 ACTIVE STORAGE TANK AMMONIA 2/12/2016
PERMIT TO OPERATE
GRANTED Ammonia
181667 581949 G41249 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 581952 G41251 7/1/2016 ACTIVE STORAGE TANK AMMONIA 2/12/2016
PERMIT TO OPERATE
GRANTED Ammonia
181667 581953 G41252 7/1/2016 ACTIVE STORAGE TANK AMMONIA 2/12/2016
PERMIT TO OPERATE
GRANTED Ammonia
181667 581955 G41254 7/1/2016 ACTIVE STORAGE TANK AMMONIA 2/12/2016
PERMIT TO OPERATE
GRANTED Ammonia
181667 581956 G41505 7/5/2016 ACTIVE STORAGE TANK AMMONIA 2/12/2016
PERMIT TO OPERATE
GRANTED Ammonia
181667 581958 G41255 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 581960 G41257 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 581961 G41258 7/1/2016 ACTIVE
STORAGE TANK W/ EXT
FLOATING ROOF CRUDE 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 581962 G41260 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 581964 G41261 7/1/2016 ACTIVE STORAGE TANK LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 581967 G41262 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 581969 G41263 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 581986 G41293 7/1/2016 ACTIVE STORAGE TANK JET-A 2/12/2016
PERMIT TO OPERATE
GRANTED Jet-A
181667 581987 G41294 7/1/2016 ACTIVE
STORAGE TANK HYDROCARBONS
MISC 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons Misc.
181667 581994 G41304 7/1/2016 ACTIVE
STORAGE TANK W/INT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 581997 G41306 7/1/2016 ACTIVE STORAGE TANK FUEL OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
181667 581998 G41308 7/1/2016 ACTIVE STORAGE TANK FUEL OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
Appendix G
22 of 27
APPX_000522
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
181667 582004 G41311 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582009 G41317 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
MISC 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582010 G41319 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
MISC 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582012 G41323 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582013 G41325 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582014 G41327 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582016 G41331 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582017 G41333 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582018 G41334 7/1/2016 INACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582021 G41340 7/1/2016 INACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582027 G41347 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582028 G41349 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582029 G41142 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582030 G41143 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF MISC MATL 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582033 G41146 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582034 G41171 7/1/2016 ACTIVE
STORAGE TANK FX RF W/ INT FLT
PET DISTIL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Dis.
181667 582037 G41172 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582039 G41173 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
NAPHTHA 2/12/2016
PERMIT TO OPERATE
GRANTED Naphtha
181667 582040 G41177 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582041 G41179 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582042 G41181 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582043 G41184 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582044 G41186 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582045 G41188 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582046 G41194 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582047 G41196 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582048 G41198 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582049 G41200 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582050 G41202 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582051 G41203 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582052 G41205 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582053 G41207 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582054 G41209 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582055 G41211 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582056 G41213 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582057 G41216 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582058 G41217 7/1/2016 ACTIVE
STORAGE TANK PRESSURE TANK
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582062 G41230 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582063 G41232 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582064 G41236 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582065 G41237 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
Appendix G
23 of 27
APPX_000523
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
181667 582082 G41290 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF JET A 2/12/2016
PERMIT TO OPERATE
GRANTED Jet-A
181667 582083 G41292 7/1/2016 ACTIVE STORAGE TANK AMINES 2/12/2016
PERMIT TO OPERATE
GRANTED Amines
181667 582084 G41295 7/1/2016 ACTIVE STORAGE TANK AMINES 2/12/2016
PERMIT TO OPERATE
GRANTED Amines
181667 582085 G41297 7/1/2016 ACTIVE STORAGE TANK AMINES 2/12/2016
PERMIT TO OPERATE
GRANTED Amines
181667 582086 G41299 7/1/2016 ACTIVE STORAGE TANK AMINES 2/12/2016
PERMIT TO OPERATE
GRANTED Amines
181667 582112 G41315 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582113 G41318 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582114 G41320 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF WASTE H20 2/12/2016
PERMIT TO OPERATE
GRANTED Waste water
181667 582115 G41529 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582116 G41530 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582117 G41531 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582118 G41532 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582119 G41533 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582120 G41534 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582121 G41322 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582123 G41600 7/6/2016 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582124 G41326 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582125 G41328 7/1/2016 INACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582126 G41330 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582128 G41335 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
HYDROCARBONS 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582129 G41337 7/1/2016 ACTIVE
STORAGE TANK, W/EXT FLT RF
COKE 2/12/2016
PERMIT TO OPERATE
GRANTED Coke
181667 582130 G41339 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
MISC 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582131 G41341 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582132 G41342 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582134 G41346 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582135 G41348 7/1/2016 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 2/12/2016
PERMIT TO OPERATE
GRANTED Gas
181667 582136 G41350 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF HYDROCARB 2/12/2016
PERMIT TO OPERATE
GRANTED Hydrocarbons
181667 582137 G41351 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582138 G41352 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582139 G41353 7/1/2016 ACTIVE STORAGE TANK FUEL OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Fuel Oil
181667 582140 G41354 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582145 G41358 7/1/2016 INACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582147 G41360 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582149 G41361 7/1/2016 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582150 G41362 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582151 G41363 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582156 G41367 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582157 G41368 7/1/2016 ACTIVE STORAGE TANK GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582159 G41370 7/1/2016 ACTIVE
STORAGE TANK MISC INORGANIC
CHEMICALS 2/12/2016
PERMIT TO OPERATE
GRANTED
Misc. Inorganic
Chemicals
181667 582160 G41371 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582162 G41373 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
MIDDLE DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
Appendix G
24 of 27
APPX_000524
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
181667 582166 G41376 7/1/2016 ACTIVE STORAGE TANK WASTE WATER 2/12/2016
PERMIT TO OPERATE
GRANTED Waste water
181667 582168 G41378 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
LPG 2/12/2016
PERMIT TO OPERATE
GRANTED LPG
181667 582176 G41381 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582177 G41382 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582178 G41383 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582179 G41384 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL PET
MID DISTILL 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 582180 G41385 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582181 G41386 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582182 G41387 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 582183 G41388 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 582184 G41389 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582185 G41390 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
CRUDE OIL 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 582186 G41391 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582187 G41392 7/1/2016 ACTIVE STORAGE TANK GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582188 G41393 7/1/2016 ACTIVE STORAGE TANK SODA ASH 2/12/2016
PERMIT TO OPERATE
GRANTED Soda Ash
181667 582190 G41395 7/1/2016 ACTIVE
STORAGE TANK, W/EXT FLT RF
COKE 2/12/2016
PERMIT TO OPERATE
GRANTED Coke
181667 582191 G41396 7/1/2016 ACTIVE
STORAGE TANK FX RF W/CTL
LUBE OIL&GREASE 2/12/2016
PERMIT TO OPERATE
GRANTED Lube Oil & Grease
181667 582192 G41397 7/1/2016 ACTIVE
STORAGE TANK, CRUDE OIL W/O
CONTROL 2/12/2016
PERMIT TO OPERATE
GRANTED Crude
181667 582194 G41398 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
181667 582195 G41399 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
181667 582196 G41400 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
181667 582197 G41401 7/1/2016 ACTIVE
STORAGE TANK PETROLEUM
LIGHT DISTILLATE 2/12/2016
PERMIT TO OPERATE
GRANTED Pet. Light Dis.
181667 582198 G41402 7/1/2016 ACTIVE STORAGE TANK SOUR WATER 2/12/2016
PERMIT TO OPERATE
GRANTED Sour Water
181667 582207 G41403 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582208 G41404 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582209 G41405 7/1/2016 ACTIVE STORAGE TANK MISC MATERIALS 2/12/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 582212 G41551 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582213 G41552 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582214 G41553 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582215 G41554 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582216 G41555 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582217 G41556 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582218 G41557 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582219 G41558 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582220 G41559 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582221 G41560 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582222 G41561 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582223 G41562 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582224 G41563 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582225 G41564 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582226 G41565 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
25 of 27
APPX_000525
STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 - 2020
Facility ID Application
No.
Permit
Number Issue Date Permit Status Equipment Description Application Date Application Status Type of Material
in Tank
181667 582227 G41585 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582228 G41566 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582229 G41567 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582230 G41568 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582231 G41569 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582232 G41570 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582233 G41571 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582234 G41572 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582235 G41573 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582236 G41574 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582237 G41575 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582238 G41576 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582239 G41577 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582240 G41578 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582241 G41579 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582242 G41580 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582243 G41581 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582244 G41582 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582245 G41583 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 582246 G41584 7/6/2016 ACTIVE
STORAGE TANK FX RF W/CTL
GASOLINE 2/12/2016
PERMIT TO OPERATE
GRANTED Gasoline
181667 583490 G45533 3/14/2017 ACTIVE STORAGE TANK MISC MATERIALS 3/15/2016
PERMIT TO OPERATE
GRANTED Misc. Materials
181667 584435 G45552 3/14/2017 ACTIVE
STORAGE TANK W/ EXT FLOAT
RF PET MID DIS 3/11/2016
PERMIT TO OPERATE
GRANTED Pet. Mid. Dis.
181667 584483 G45534 3/14/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 3/15/2016
PERMIT TO OPERATE
GRANTED Gas-Oil
181667 584484 G45535 3/14/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 3/15/2016
PERMIT TO OPERATE
GRANTED Gas-Oil
181667 584485 G45536 3/14/2017 ACTIVE
STORAGE TANK FX RF W/CTL
GAS-OIL 3/15/2016
PERMIT TO OPERATE
GRANTED Gas-Oil
181667 588733 G44689 1/30/2017 ACTIVE
STORAGE TANK-GAS DOME
EXT.FLOAT ROOF 9/9/2016
PERMIT TO OPERATE
GRANTED Gas
181667 597847 G52789 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597848 G52797 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597849 G52799 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597850 G52800 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597851 G52802 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597852 G52804 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597853 G52796 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597854 G52805 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597855 G52806 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597857 G52807 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597859 G52808 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 597860 G52810 6/21/2018 ACTIVE
STORAGE TANK OTHER W/CTL
WASTE WATER 9/28/2017
PERMIT TO OPERATE
GRANTED Waste water
181667 600113 G52787 6/21/2018 ACTIVE
STORAGE TANK W/ EXT FLOAT
ROOF GASOLINE 1/16/2018
PERMIT TO OPERATE
GRANTED Gasoline
Appendix G
26 of 27
APPX_000526
FACILITIES WITH STORAGE TANKS PERMITTED BY SCAQMD FROM 2010 -2020 Facility ID Facility Name
111238 Ribost Terminal LLC
167981 Tesoro Logistics, Wilmington Terminal
171107 Phillips 66 Co./LA Refinery Wilmington
171109 Phillips 66 Co./Los Angeles Refinery
171320 Phillips 66 Colton Terminal - West
171326 Phillips 66 Pipeline LLC
171327 Phillips 66 Pipeline LLC
171329 Phillips 66 Colton Terminal - East
172878 Tesoro Logistics Long Beach Terminal
173239 Ultramar Inc. Valero Marine Tank Farm
174591 Tesoro Ref. & Mktg. Co. LLC, Calciner
174655 Tesoro Refining & Marketing Co., LLC
174694 Tesoro Logistics Carson Crude Terminal
174704 Tesoro Logistics East Hynes Terminal
174705 Tesoro Logistics, Colton Terminal
174710 Tesoro Logistics Vinvale Terminal
174726 Tesoro Refining & Mktg. Co. LLC, Marine
174727 Tesoro Refining Marketing Company LLC
176377 Tesoro Logistics Marine Terminal 2
181667 Torrance Refining Company LLC
182752 Torrance Logistics Company LLC
182753 Torrance Logistics Company LLC
182822 Torrance Logistics Company LLC
800026 Ultramar Inc.
800057 Kinder Morgan Liquids Terminals LLC
800080 Lunday-Thagard Co. DBA World Oil Refining
800198 Ultramar Inc.
800436 Tesoro Refining & Marketing Co., LLC
Appendix G
27 of 27
APPX_000527
APP
ENDIX H
APPX_000528
LONG BEACHLONG BEACH
SAN PEDROSAN PEDRO
CARSONCARSON
WILMINGTONWILMINGTON
TORRANCETORRANCE
LOMITALOMITA
SIGNAL
HILL
SIGNAL
HILL
RANCHO
PALOS
VERDES
RANCHO
PALOS
VERDES
WEST
CARSON
WEST
CARSON
PACIFIC COAST
7TH
OCEAN
PACIFIC COAST
ANAHEIM
223RD
WESTERN
4TH
LOMITA
SEPULVEDA
AVALON
ALAMEDAALAMEDAMAIN
FIGUEROA
MAGNOLIA
REDONDO
GAFFEY
LONG BEACH
PALOS VERDES
WILMINGTON
BROADWAY
PASEO DEL MAR
SHEPARD
HARBOR
OCEAN
SEPULVEDA
WILMINGTON
SANTA FE
ATLANTIC
WILLOW
AIRPORT
HARBOR SCENIC
SHORELINE
I 405
I 110
I 710
I 110
I 405
STATE HWY 47STATE HWY 47
DRAFT - ARB-PTSD-EIB/11-3-05
0 1,000 2,000500
Meters
Other
Schools
Hospitals
Airports
Parks
Intermodal Facilities (NTAD)
Major Railyards
Railroads
Roads
Wilmington Neighborhood Assessment Program (NAP) Facilities Wilmington NAP Facilities
PETROLEUM REFINING
PETROL PRODN, DISTRIBN
CHEMICAL RELATED
POWER PLANTS & RELATED
TRUCKING / WAREHOUSING
MARINE & RELATED
AUTO RELATED
WELDING RELATED
GOVT / MILITARY
MISC INDUSTR / COMMERC
MISC SERVICES
Changing Regulatory Culture to Address
Environmental Injustice & Environmental Racism
CAsE studIEs And RECommEndAtIons
october 2009
CumulAtIvE
ImpACts:
CBE Communities for a Better Environment
CBE
Communities for a Better Environment
5610 pacific Blvd., suite 203
Huntington park, CA 90255
phone (323) 826-9771
Fax (323) 588-7079
www.cbecal.org
APPX_000529
Cumulative Impacts
Changing Regulatory Culture to Address
Environmental Injustice & Environmental Racism
Case Studies and Recommendations
Author:
Bahram Fazeli, Research & Policy Analyst
With Contributions and Review From:
Jesus Torres, Julia May, Adrienne Bloch, Guillermo Jaimes, Juan Ramirez, Strela Cervas, and with special thanks to Shana Lazerow for her extensive comments.
Photography:
Yuki Kidokoro, Jennifer Ganata, Jesus Torres, Darryl Molina, Bertalina Chavac, Jesse Marquez, Rember Sosa
We thank the James Irvine Foundation for supporting CBE’s Environmental Health and Democracy Project and making this report possible.
Design and Layout: Design Action Collective, Oakland, CA Printing: Inkworks Press, Berkeley, CA. Printed on recycled paper.
October 2009
Communities for a Better Environment
5610 Pacific Blvd. Suite 203, Huntington Park, CA 90255 www.cbecal.org
CBE
APPX_000530
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Los Angeles: A Stark Example of Environmental Injustice and Cumulative Impacts . . . . . . . . . . . 3 SELA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Wilmington . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Health Impacts and Vulnerability . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Case Studies
Warren E & P . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 Industrial Services Oil Company, Inc . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 I-710 Expansion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 Conclusion / Recommendations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 Endnotes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 Table of Contents
APPX_000531
2 Communities for a Better environment
Introduction
t
he purpose of this report is to demonstrate to decision-makers the serious flaws in how our regulatory system approaches environmental justice issues, and to suggest steps they can take to address these flaws.
First, we describe the Los Angeles region as presenting a prime example of environmental injustice in the way environmental hazards are unequally distributed, giving rise to cumulative impacts of pollution in low-income communities of color. Then, we discuss three cases that show how shortcomings in our regulatory system create and accentuate the problems of environmental injustice and cumulative impacts in vulnerable communities throughout our region.
Three themes repeat themselves when confronting problems of environmental injustice:
1. There are structural gaps in almost all of our municipal and regulatory entities in addressing the issues of environmental justice (EJ) and cumulative impacts (CI).
2. There is inadequate enforcement of even the existing (and flawed) regulations in disproportionally impacted communities.
3. Community input in EJ communities is not sought proactively and often is not welcomed or even respected by many decision-makers.
We will explore these themes throughout the case studies and offer recommendations to remedy them.
APPX_000532
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 3 e
xtensive research has demonstrated that polluting
facilities are disproportionately located in low-income communities of color in Los Angeles. For example, the
US EPA designated Toxic Release Inventory (TRI)
facilities are disproportionately located in areas with high (relative to mean) concentration of racial minorities.
1 In
terms of siting of hazardous waste treatment, storage
and disposal facilities (TSDF) in Los Angeles County
and its disproportionate distribution in predominantly
communities of color, it has been demonstrated that both income and race independently play a significant factor in siting decisions.
2 These patterns of disparity have remained
the same over the past decade and current research indicates similar uneven distribution of environmental hazards across Los Angeles County.
3 Below
we will look at two areas
of Southeast Los Angeles
County and the community
of Wilmington, where
CBE has active organizing
bases, to demonstrate the
extent of the problem in EJ
communities.
Southeast Los Angeles
One of the most heavily
industrialized areas in Los
Angeles is South East Los
Angeles County (SELA),
home to a low-income
and overwhelmingly
Latino/a population. Here
a wide variety of polluting
industries, such as chrome
platers, hazardous waste
treatment storage and
disposal facilities, and
other major toxic emitters
combine with a high
concentration of mobile
sources of pollution to create
a toxic hot-spot. Modeling
studies by the South Coast
Air Quality Management
District (AQMD) indicate that the communities of SELA
have some of the highest levels of toxic air pollution in the four-county region of this air basin.
4 The map below shows
how a mix of large and small polluting facilities has given rise to the serious issue of cumulative impacts of pollution in SELA cities.
Extensive research has demonstrated that
polluting facilities are disproportionately
located in low-income communities of
color in Los Angeles County.
Los Angeles: A Stark Example of Environmental
Injustice and Cumulative Impacts
Figure 1. Some SeLA polluting facilities5
APPX_000533
4 Communities for a Better environment
Wilmington
Another area that is highly impacted by pollution is the community of Wilmington. Wilmington, located in the
southern tip of the odd-shaped City of Los Angeles,
is home to an overwhelming working class, Latino/a
population. This area has some of the highest levels of pollution in the region.
Wilmington hosts 13 major stationary polluting sources, categorized by US EPA as Toxic Release Inventory
facilities, responsible for releasing 718,000 pounds of pollution and generating 18,000,000 pounds of waste in
2007.
6 In addition, the Wilmington/Carson area is a place
with the highest concentration of refineries in California with about 650,000 barrels of crude oil processed per day (which is about a third of the state’s total).
7 Wilmington
is also near the San Pedro Bay Port Complex (ports of
Los Angeles/Long Beach), which is the largest and most
polluting port complex in the country.
Wilmington has some of the highest
cumulative levels of pollution in the region.
LONG BEACHLONG BEACH
SAN PEDROSAN PEDRO
CARSONCARSON
WILMINGTONWILMINGTON
TORRANCETORRANCE
LOMITALOMITA
SIGNAL
HILL
SIGNAL
HILL
RANCHO
PALOS
VERDES
RANCHO
PALOS
VERDES
WEST
CARSON
WEST
CARSON
PACIFIC COAST
7TH
OCEAN
PACIFIC COAST
ANAHEIM
223RD
WESTERN
4TH
LOMITA
SEPULVEDA
AVALON
ALAMEDAALAMEDAMAIN
FIGUEROA
MAGNOLIA
REDONDO
GAFFEY
LONG BEACH
PALOS VERDES
WILMINGTON
BROADWAY
PASEO DEL MAR
SHEPARD
HARBOR
OCEAN
SEPULVEDA
WILMINGTON
SANTA FE
ATLANTIC
WILLOW
AIRPORT
HARBOR SCENIC
SHORELINE
I 405
I 110
I 710
I 110
I 405
STATE HWY 47STATE HWY 47
DRAFT - ARB-PTSD-EIB/11-3-05
0 1,000 2,000500
Meters
Other
Schools
Hospitals
Airports
Parks
Intermodal Facilities (NTAD)
Major Railyards
Railroads
Roads
Wilmington Neighborhood Assessment Program (NAP) Facilities Wilmington NAP Facilities
PETROLEUM REFINING
PETROL PRODN, DISTRIBN
CHEMICAL RELATED
POWER PLANTS & RELATED
TRUCKING / WAREHOUSING
MARINE & RELATED
AUTO RELATED
WELDING RELATED
GOVT / MILITARY
MISC INDUSTR / COMMERC
MISC SERVICES
Figure 2. Various polluting sources in Wilmington 8
APPX_000534
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 5 H
ealth impacts of exposure to pollution from sources
discussed are well documented and include: asthma,
cancer, reproductive disorders, birth defects reduced lung capacity, and cardiovascular diseases. In addition, people in EJ areas suffer from the nuisance impacts of these
operations such as noise, foul odor and other irritants that significantly affect people’s quality of life. Because EJ communities host disproportionate numbers of pollution
sources, community members in areas such as SELA and
Wilmington suffer disproportionately from health and
nuisance impacts.
Another important aspect of cumulative and
disproportionate impact from pollution is the issue of
vulnerability. Members of communities such as SELA and
Wilmington have a lowered ability to cope and recover
from illnesses. In other words, low-income communities
of color are not only suffering from greater exposure to pollution, but they are also more susceptible because of their higher vulnerability to impacts. Reduced access to health care, pre-existing injuries, and psychosocial stressors are some of the factors that influence the extent of impact from environment stressors such
as air pollution.
9 Researchers have used a range of
social and economic information
to develop measures, or indices,
of social vulnerability. In a gen-
eral sense, vulnerability includes
concepts such as: socioeconomic
status, gender, ethnicity, age,
proximity to commercial and
industrial development, employ-
ment status, housing tenure,
occupation, family structure,
education, access to medi-
cal services, and special needs
populations. We have divided
these indicators into four broad
categories of vulnerability: (1)
household; (2) race/ethnicity;
(3) economic; and (4) mobility.
Based on these indicators, we
estimate and identify communi-
ties that are most vulnerable to impact as the map below shows (with orange and red areas showing communities
which are most vulnerable).
10 Most recently, a team of researchers from Occidental College, University of Southern California and UC
Berkeley have developed a more comprehensive and
detailed Cumulative Impacts scoring system. This system shows that communities of SELA, Wilmington, Boyle
Heights, and other similar communities score very high in Cumulative Impacts and are in need of the most attention in addressing environmental justice issues.
11 Health Impacts & Vulnerability
Low-income communities of color are
not only suffering from greater exposure
to pollution, but they are also more
susceptible to impacts because of their
higher vulnerability.
Figure 3. An estimate of Cumulative Vulnerability index by Census Block APPX_000535
6 Communities for a Better environment
W
arren E & P drilling
operation is located in the
community of Wilmington.
Warren E & P is an East
Coast-based resource extraction
company, which proposed
performing expanded lateral
drilling in Wilmington in 2005.
In early 2007, after Warren had
began its new and expanded
oil drilling operations in the
middle of a neighborhood
of small family homes and
apartment buildings, a number
of community members
contacted CBE. Community
members were extremely
irritated and concerned
about the terrible smell, loud noises at day and night, aggravating dust and many other problems resulting from this operation. The main permits for this operation were issued by the City of Los Angeles and the South Coast Air Quality Management District (AQMD).
Imagine living in a neighborhood already heavily impacted by pollution from the ports, refineries, and many other sources. Then, somebody starts a massive noisy and
polluting oil drilling operation in your neighborhood 24 hours a day, seven days a week. For anybody living in this neighborhood or visiting the area, there was no doubt
that this was a blatant example of environmental injustice afflicting this already vulnerable community. So, how
could the City of Los Angeles and AQMD fail to protect
residents? The answer lies in understanding the regulatory gaps within the City and regulatory agencies as well as poor enforcement and monitoring of existing regulations by responsible entities. Understanding the shortcomings of the AQMD and the City of Los Angeles to protect the
residents in the case of Warren E & P will demonstrate
the need for addressing the issue of environmental justice in a systemic way and the necessity of ratcheting up
enforcement.
As mentioned earlier, the
two agencies with primary
regulatory control over
such an operation are the
City of Los Angeles, which
regulates its land use and
the impacts that result from
these uses such as traffic,
noise, dust and odors;
and the AQMD, which
regulates specific equipment
that could impact local and
regional air quality. The
ten-acre lot where Warren
operates is zoned both as
a residential area and as a
special oil drilling area, and
the property had housed oil
drilling before. However, the previous operator had nine active wells. Warren planned to drill 24 hours a day, seven days a week, and to increase the number of wells to 540.
It also intended to continue to use the previous operator’s ancient air quality equipment continuously even though it had previously been permitted for emergency-use only.
On July 20, 2006, the City of Los Angeles issued a
special use permit to Warren E & P , allowing drilling.
The city did not require the company to perform a full
Environmental Impact Report, but instead decided
that a mitigated negative declaration would satisfy the California Environmental Quality Act requirements in
this case. From there on, the Zoning Administrator of
the City of Los Angeles issued a special use permit based on limited environmental review and limited public input and allowed the facility to start operations. AQMD, for its part, did not originally impose any significant restrictions on the operation of the facility, allowing it to burn its field gases in the existing ancient flare that did not protect the surrounding community. In other words, Warren’s quest to begin perpetual unfettered operations pretty much sailed through regulatory and permitting process—definitely a
success story from the point of view of the applicant.
CASE StudIES
Warren E & P
Warren e & p burning field gases continuously in the
residential neighborhood
APPX_000536
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 7 Of course the perspective of the community was quite
different. On the ground, the impacts were very real and very serious. People in the neighborhood were experiencing a wide range of health symptoms associated with the
operation of this facility. Polluting diesel trucks were either hauling dirt or oil out of the facility or idling in front of homes. A vacant lot in a residential neighborhood was
turned into a dumping ground for dirt which would blow
dust over people’s homes. People complained that since this operation started, they had to spend a big part of the day dusting inside their home. People with existing respiratory problems were finding it more difficult to breathe. People were also constantly irritated by foul smells after the operation started. Most residents in this area did not have air conditioning, but they had to keep their windows closed even during hot days.
Then there was the noise, extremely irritating during the day and unbearable at night. For months, community
members could not get a restful sleep at night. Many of the In a survey of 66 residents living within two blocks of the Warren E & P facility, community members expressed a great deal of frustration with the project:
Two-thirds of the participants said that noise from Warren operations keeps them awake most nights or at least once a week.
More than 90% of respondents stated that they were not informed that Warren operations would increase truck traffic or noise in their neighborhood.
When asked to characterize in their own words how Warren’s operations have affected their neighborhood, an overwhelming majority of survey participants expressed concern over air pollution, noise, contamination, sleep deprivation, traffic, and many other issues. Here are some direct quotes from the community members from the survey as they described living next to this operation:
A Living Hell•
Smell, noise, illness. Extreme breathing difficulties, Dr. visits• Evening noise—more dust, smells, extensive lung illness, constant coughing--less sleep• Lots of dust. Every morning lots of black film all over the cars• A lot of allergies, breathing problem, headaches, chronic problems, lack of sleep• Problems breathing. More dust in my home, headache•
Affected my health by asthma, community is dirt•
Headache, nausea, and difficulty breathing•
Noise, dust, and they don’t let us sleep•
We used to have a nice quiet, clean street•
A mess•
It’s been a living hell. We want them out•
Our health has gotten worst. Our allergies are stronger. The dust has damaged our furniture, my kids’ • throats. Everything has gone bad
It’s not a normal place to live•
Horrible•
Smoke in the air•
Neighborhood is not the same. Dirt, noise, bad odor, traffic• Changed evening tranquility and affects air quality•
Lots of dirt on pavement•
My wife had to be taken to the hospital from the fumes• Have to stay indoors•
APPX_000537
8 Communities for a Better environment
questions to various city departments went
unanswered.
While this operation in any residential
neighborhood should be unacceptable,
we generally find these scenarios in low-
income communities of color, which
host incompatible land uses. There are
two significant problems that one must
pay attention to. First, the bad land use
arrangements in EJ areas must prompt
regulators and issuers of permits to pay
special attention to conditions of the permits. Second, when an area is polluted by a disproportionately high
level of pollution, regulators need to take into account the cumulative impacts in their decision-making process.
CBE worked with the community to secure new
evidentiary hearings in front of the City of Los Angeles and the AQMD, neither of which was adequate, in form
or substance, to address the flagrant environmental justice violations the case presented.
First, CBE brought the matter to its representative on
the City Council, who worked with us to secure a zoning hearing challenging Warren’s compliance with its operating conditions and the adequacy of those conditions. When
the zoning administrator finally held the hearing in this predominantly Latino community, it provided inadequate
translation services, so many members were not able to
follow the proceeding properly, and the decision-makers were not able to understand their testimonies accurately.
Second, CBE and the community sought better regulation
of air pollution from Warren’s operations. Initially, CBE noticed that the AQMD intended to issue a new permit for a new flare with no CEQA review that would let Warren
vastly expand the amount of waste gas it burns. In the
course of researching the permit, our technical staff noticed that the record showed Warren was in serious violation
of its existing flare permit. We brought it to AQMD’s
attention, and the agency issued a Notice of Violation
(NOV), and terminated the permitting process for the
new flare.
While we attempted to engage our membership with
AQMD’s NOV adjudication (which resembles a court
hearing held by the AQMD’s Hearing Board), Warren and
the AQMD prosecutor negotiated a deal over the course
of several months and presented it to the Hearing Board as a solution to the violations. Our members, researchers and lawyers collected and submitted substantial evidence that showed the violations were very serious, and the proposed penalty was inadequate. We attempted to participate in
the entire trial, but the Hearing Board was unreceptive to the community input and perspective. CBE offered video
evidence of the flare violations, taken at a member’s home, which the Hearing Board refused to even consider. This
experience showed the total lack of respect by the Hearing Board for the community that was being impacted.
First, the bad land use arrangements in EJ areas
must prompt regulators and issuers of permits
to pay special attention to conditions of the
permits. Second, when an area is polluted by a
disproportionately high level of pollution, regulators
need to take into account the cumulative impacts in
their decision-making process.
aerial photo showing Warren e & p operation next to a
community baseball field and people’s homes
APPX_000538
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 9 Here are some of the main problems with the process and decisions made in this case by the City of LA and AQMD:
When a new, polluting operation is proposed in the •
middle of a residential area that is disproportionately impacted by many other sources of pollution, it should
never be allowed to secure land use permits without a
full public participation process and a complete EIR
process.
The substantive conditions imposed by the City of LA •
were far from adequate to protect the residents living at the fence-line of this polluting operation.
There was hardly any enforcement of the operating •
conditions. In fact, community members had to take
the matter into their own hands and work with CBE
to push for tougher monitoring of existing permit
conditions as well as reconsideration of the permit
conditions.
Even when the City finally held a hearing in •
Wilmington, as a result of vigorous community
demands, the City was not able to create an adequate
space for meaningful public participation for the
residents. The City did not provide adequate
translation equipment, was not able to provide
professional simultaneous translation services, and did not provide the meeting at a time that was feasible for community members to attend. This indicated that
the city is at its learning stages in recognizing issues of environmental justice and creating meaningful access to decision-making and public participation.
The City of Los Angeles does not have any explicit •
provisions that would allow its permitting staff
to protect its most polluted neighborhoods from
becoming more polluted. For example, the code that
provides for oil drilling zones does not account for
changes over time to the land use surrounding drilling
operations. Even where staff discretion is implicit, the city staff has not had adequate training, guidance or
experience around EJ issues to accommodate people’s
ability to effectively voice their opinion, let alone
impact the decision.
As far as enforcement, the City does not allocate •
sufficient resources to make permit conditions
meaningful, and polluting facilities do not take the
City enforcement very seriously. In addition, the
communication among City enforcement staff and the
City Attorney is not effective to prevent and discourage violations of permit conditions.
AQMD permitting processes also fail to take into •
account the need for increased community participation
and environmental analysis when permitting operations
in already overburdened communities. Despite intense
AQMD permitting processes fail
to take into account the need for
increased community participation and
environmental analysis when permitting
operations in already overburdened
communities.
CBe staff and community members meeting with
Councilmember Janice Hahn to discuss problems with Warren Frequent truck traffic related to the Warren operation in neighboring residential streets
APPX_000539
10 Communities for a Better environment
community involvement in the Hearing Board process
and CBE’s participation in the permitting attempt, the
District decided not to produce a full environmental
impact report for the latest Warren permits. AQMD’s
negative declaration did little to mitigate the air
impacts the community identified.
The AQMD enforcement process did not consider •
the full impact of the project. AQMD and the
polluter negotiated a deal for the Hearing Board
to rubber stamp their proposal without offering all
the available health protective mitigation measures
that the community deserved and asked for.
Although community pressure did result in AQMD
incorporating some of the community demands, the
result was far from adequate.
The AQMD Hearing Board did not act in an •
independent and professional manner. As is often the
case during the history of its operation, the Hearing
Board ruled for industry and against the community.
That the Hearing Board is biased in favor of industry
is a matter of concern. Of even greater concern,
however, is the attitude shown by the Chair and some
members of the Hearing Board, who showed very little
respect for the community input, and at times treated
community members and leaders with hostility and
disrespect. At the conclusion of the proceeding, the
community was even accused of having wasted the
Hearing Board’s time with its attempts to participate in the trial.
AQMD failed to protect the community by not •
upholding its own EJ principles, and it failed to offer monitoring and technical assistance to this community
in need, which could have gone a long way in securing
better operating conditions from the project operators, the City, and the AQMD.
Unfortunately, the Warren oil drilling scenario is not an isolated case. In fact, it is representative of how different municipal and regulatory agencies fail to account for
cumulative impacts in the way they issue permits, write their regulations, enforce their permits and allocate
resources to protect low-income communities of color.
Years of advocacy and recognition of environmental justice issues has moved agencies to acknowledge that CI and EJ are real issues, but we are yet to see significant attempts to address these issues in a systematic manner.
The City of Los Angeles does not have
any explicit provisions that would allow
its permitting staff to protect its most
polluted neighborhoods from becoming
more polluted.
shana lazerow, CBe staff attorney, challenging Warren’s compliance with and adequacy of the permit conditions at the zoning administrator hearing
APPX_000540
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 11 South Coast Air Quality Management district . AQMD adopted its environmental justice principles in October of 1997 due to increasing community awareness about environmental justice problems in the South Coast Air Basin. In September of 2002, and as a result of growing pressure from the environmental justice community, AQMD’s Governing Board adopted 23 environmental justice enhancement measures. The Board asked the staff to evaluate a feasibility plan to reduce cumulative impacts from toxic emitting sources. Under its Cumulative Impact workplan and white paper, AQMD committed to a number of measures in assessing and reducing health impacts in disproportionately impacted communities but failed to approach cumulative impacts from the framework suggested by the environmental justice community. 12 AQMD needs to pursue the task
of pollution prevention and reduction in EJ communities under a comprehensive CI framework.
California Air Resources Board (CARB) has Jurisdiction over the AQMd . In December 13th of 2001 the agency’s Board unanimously approved Environmental Justice Policies and Actions, which were created through an extensive period of stakeholder negotiations.13 This process produced a number of important documents including the Complaint Resolution Protocol, Public Participation Manual and the Air Quality and Land Use Handbook. However, CARB still has not fulfilled its promise of providing a cumulative impact framework (document) to guide rulemaking, permitting and enforcement for the day-to-day operation of air districts. It is important to note that creating this cumulative impact framework by CARB is both required by CARB’s EJ Policies and based on recommendations of the California Environmental Justice Advisory Committee. united States Environmental Protection Agency has jurisdiction over all state entities enforcing the federal environmental laws such as the Clean Air Act. EPA charged the National Environmental Justice Advisory Committee (NEJAC) with the task of proposing solutions to addressing EJ and CI from a regulatory perspective. NEJAC created the Cumulative Risks / Impacts Work Group, which produced a comprehensive report on this topic.
14 EPA should implement the recommendations of
this working group and fully utilize its existing statutory authority to reduce cumulative exposure in disproportionately impacted communities. According to the NEJAC report and a comprehensive report by the Environmental Law Review, the Clean Air Act provides several opportunities for EPA and air agencies, which enforce the Clean Air Act, to promulgate cumulative impact regulations. 15 APPX_000541
12 Communities for a Better environment
i
ndustrial Services Oil Company, Inc. (ISOCI) presents
another example of how the agencies in charge have
failed to protect the residents most impacted by pollution.
ISOCI is a hazardous waste facility located in a working class Latino neighborhood of Los Angeles, called Boyle
Heights. The Cal/EPA Department of Toxic Substances
Control (DTSC) issued a hazardous waste facility permit that authorizes ISOCI to radically expand its operations to accept hundreds of additional ignitable, carcinogenic, and extremely toxic wastes. These chemicals include
hydrofluoric acid, which can kill on contact, and phosphine, which is highly toxic and deadly even at low concentrations.
The permit also allows ISOCI to store an unprecedented
250,000 gallons of hazardous waste in rail cars (for up to a year at a time) without adequately evaluating the risks and impacts associated with a catastrophic release of hazardous waste during an earthquake or accident. In addition to
this greatly increased risk in times of crisis, the proposed expansion of this operation would subject the Boyle
Heights community to other significant health impacts.
CASE StudIES
Industrial Services Oil Company, Inc .
Figure 4. Some of the schools within 1 and 2 miles of industrial Service Oil Company APPX_000542
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 13 California Environmental Protection Agency is the umbrella agency for dtSC and other state regulatory agencies . In California, there have been a number of significant environmental justice legislation, which have been the result of a growing movement and awareness about environmental justice issues in the state.
16 Among these, SB 89 (Escutia) required the Secretary of Cal-EPA to establish the California Environmental Justice Advisory Committee (CEJAC). CEJAC has provided recommendations to the agency about steps that Boards, Department and Offices need to take to operationalize environmental justice and specifically cumulative impacts into their program. 17 DTSC issued the permit without following the Tanner
Act hazardous waste permitting process. Among other
things, the Tanner Act of 1981 requires the establishment of a committee composed of community stakeholders
to offer guidance concerning any proposal to permit a
hazardous waste facility and provides an expert to answer that committee’s questions. The Tanner Act was specifically designed to require a coordinated process in permitting hazardous waste facilities and to provide a more strenuous and involved public participation process than that offered by other statutes, such as the California Environmental Quality Act. DTSC ignored this process and allowed
ISOCI to circumvent it altogether.
On behalf of the CBE members in the impacted
community, CBE challenged DTSC’s decision through
its administrative process, but the agency refused to take corrective health protective measures, provide an adequate environmental document, respond to expert comments,
or coordinate permitting for this facility. CBE then filed a case to the superior court, where a decision is pending.
Regardless of the outcome, one thing is clear: DTSC failed to protect this EJ community by refusing to offer them
adequate access to the decision-making process. Clearly the decision-making process at DTSC did not take into
account that this facility is near an EJ community that deserves to be given every opportunity to participate in an important permitting decision. Not only was DTSC not
proactive in affording maximum access and protection, it exercised poor judgment and violated a well established law based on a very questionable interpretation of what the agency is required to do.
In ISOCI we see the same patterns we saw in the case of Warren and many other regulatory decisions that affect
the lives of our community members. First, the structural gaps and deficiencies within our regulatory agencies allow expansion of polluting operations in neighborhoods already suffering disproportionately from exposure to pollution.
Second, when a facility is in clear violation of even existing codes, entities in charge are not aggressive in enforcing existing mandates. In this case, the regulatory agency
in charge was violating the law itself and failed to take corrective action (even when reminded of this wrongdoing) without any regard for policy guidelines at the state level that have highlighted the significance of EJ issues.
DTSC failed to protect this EJ community
by refusing to offer them adequate access
to the decision-making process.
APPX_000543
14 Communities for a Better environment
a
nother important and developing case is the proposed
expansion of the Long Beach Freeway (I-710), which
would expand an 18-mile stretch of the I-710 from the
ports to the Pomona Freeway. This expansion plans to
accommodate more truck traffic from a projected doubling of cargo through the Los Angeles and the Long Beach port complex by 2030. Diesel trucks make up 20% of vehicles on the I-710 as compared to 6-13% on other freeways in LA
County. There is a high concentration of hazardous diesel emissions in this transportation corridor. I-710 freeway averages about 1,100 diesel trucks per hour with peaks as high as 2,600 heavy-duty diesel trucks per hour.
18 From an environmental justice and a
public health standpoint, there is a strong
need to reduce the already high levels of
pollution along the I-710 corridor, and
any plan that will increase the pollution
burden of the corridor residents needs to
be stopped.
The immediate
impact zone of
the I-710 project
has a greater
ratio of people of
color and low-
income residents
than the Los
Angeles County
average. In
addition to the mobile sources, this area hosts many other sources of pollution creating an area where again cumulative sources of pollution are disproportionately impacting a vulnerable subpopulation. From an environmental justice and a public health standpoint, there is a strong need to reduce the already high levels of pollution along the I-710 corridor, and any plan that will increase the pollution burden of the corridor residents needs to be stopped.
In addition to the health of the people living along this corridor being at stake, the I-710 expansion project is one of the most significant transportation projects in the state. The final project will have a permanent impact on the landscape of Southern California. The project design, the manner in which it is constructed, and the proposed mitigation measures will have a significant impact on the local and regional residents of this air shed. If, for example, a clean rail alternative is chosen as a preferred element, among the alternatives being considered, instead of adding only multiple truck lanes, the future of logistics planning will permanently change in the region. The effects are
not just in the area of emissions, but in all the ancillary aspects related to creating a cleaner project such as creating green jobs and promoting and establishing alternative
technologies in the region.
In this case, the agency which exercises the most power over the outcome is the California Department of
Transportation (Caltrans). While other funding partners of this project such as the Los Angeles County Metropolitan Transportation Authority (Metro), Port of Long Beach,
Port of Los Angeles, and others have influence on the
process and the project, Caltrans is the lead agency and has the resources to decide the methodology of impacts.
CASE StudIES
I-710 Expansion
action and march by community members before the i-710
project committee meeting
APPX_000544
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 15 Figure 5. i-710 Corridor Project
source: metro
CASE StudIES
I-710 Expansion
APPX_000545
16 Communities for a Better environment
Interestingly enough, Metro has worked closely with the environmental justice community in the past few years
to create an elaborate public participation framework,
but not all the decision-makers, especially Caltrans
are happy with the results.
19 In fact, Caltrans has been
resistant to taking into account many of the community
recommendations including investigating the full health impacts of the proposed project alternatives. While the public health experts and the EJ community have joined
forces to highlight the deficiencies in Caltrans’ approach to performing this impact assessment, the agency’s entrenched bureaucracy has been slow to respond to community and
public health concerns. Caltrans, to a large extent, has been evasive and dismissive of suggestions to take into account even the most basic elements of public health analysis. 20 While Caltrans acknowledges this project will have a disproportionate impact in EJ communities along the I-710 corridor, it is reluctant to take any meaningful steps in fully analyzing these impacts. This approach will ultimately
influence the proposed mitigations and the analyses of
alternatives. It appears that without more pressure from the community and responsible elected officials, Caltrans plans to push through a project that to a large extent
will ignore the true cumulative impacts of this project’s construction and operation. Caltrans has the legal and
ethical responsibility to be responsive to community health demands and to perform thorough Cumulative Impacts and
Health Impact Analyses.
California department of transportation (Caltrans) is the lead agency for highway projects throughout the state . Among other legal mandates, Caltrans must implement the California Environmental Quality Act (CEQA) when it approves a project. CEQA provides explicit language and opportunities for the lead agencies and the responsible agencies to incorporate cumulative impacts into their analysis of new projects. In CEQA, the impact of a project is considered significant if “the project has possible environmental effects which are individually limited but cumulatively considerable.” Cumulatively considerable means “that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, … other current projects, and ... probable future projects.”
21 This analysis has been put forward and affirmed by a number of legal experts and court cases.22 In CBE v California Resources Agency, California Court of Appeal upheld the already-established CEQA principle that an agency must consider and address impacts that may be cumulatively significant.
23 While CEQA’s definition of cumulative impacts is far narrower than what would actually protect the community from added impacts, it is a floor below which Caltrans’s cumulative impacts analysis should never sink.
Community testimony at an i-710 hearing
mark lopez, CBe youth organizer, testifying at the i-710 project Committee hearing
APPX_000546
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 17 ALLOW fOR MEAnIngfuL PuBLIC PARtICIPAtIOn
Offer public hearings and workshops for the impacted community • Provide adequate information to communities on the issues and decisions under consideration• Offer technical resources to the community to enhance their capacity to participate in the decision-• making process
Offer workshops in venues and times that are most convenient to the impacted community• Provide adequate and professional translation services during public workshops and hearings • Partner with community-based organizations to engage members of the community more effectively• Establish community-based monitoring programs•
Show respect and full consideration for the community members’ point of view • Educate staff and decision-makers on issues of environmental justice and cumulative impacts• Create written guidelines and staff trainings for best practices in community engagement and • public participation
Require staff to attend tours of the impacted communities • Assist communities with receiving data and information about the cumulative impacts of pollution • in their neighborhood
Conclusion / Recommendations
t
he problems of environmental injustice and cumulative impacts are well documented and have serious consequences for many communities. Decision-making entities, such as Caltrans, Cal/EPA’s DTSC, AQMD and the City of LA (which represent a wide spectrum of regulatory entities in California) have been slow to recognize the problems and in large part have failed to address the issues in any effective manner. While it took many years of advocacy, research, and community participation to highlight the issues of EJ and CI in California, we still have a long way to go to make the necessary changes to fix the problems. Municipalities and regulatory entities are growing increasingly familiar with the historical contexts, trends and main issues that EJ communities have raised. They now need to move to the next level, which is solving these environmental justice problems by making community central to the decision-making processes and pursuing aggressive health protective decisions.
APPX_000547
18 Communities for a Better environment
REQuIRE POLLutIOn PREVEntIOn And REduCtIOn
Prevent additional pollution in EJ communities by promulgating regulations that take into account • cumulative impacts and by revising source specific rules, umbrella rules, and permitting guidelines Mandate comprehensive Environmental Impact Reports and Health Impact Assessments for • polluting projects in EJ communities
Promulgate new ordinances and/or regulations that will operationalize CI analysis for new and • expanding projects in EJ communities
Require Best Available Control Technologies and Lowest Achievable Emissions Rate for existing • operations in EJ communities
Allocate more substantial resources into enforcing permit conditions in EJ areas by pursuing more • aggressive monitoring, inspections, and prosecution of violators Establish and improve communication and coordination between municipalities and environmental • regulatory agencies in regards to dealing with violations especially in cases of serious violations and frequent violators
PROVIdE InCEntIVES fOR MItIgAtIOn, REduCtIOn And CLEAn gROWtH Provide financial incentives for clean operations to site in EJ communities• Create permitting incentives for companies that plan to reduce their pollution or companies that • plan to convert to cleanest technologies
Prioritize funding for retrofitting polluting operations in disproportionately impacted areas• Invest resources in investigating opportunities and attracting industrial and business infrastructures • to EJ communities that have a smaller environmental footprint
In AddItIOn MunICIPALItIES SHOuLd
Adopt an Environmental Justice element into their general plan • Enact ordinances that address cumulative impacts of pollution in the EJ areas by preventing • additional sources of pollution and reducing pollution from existing sources Allocate financial resources for revitalization of EJ areas to attract clean operating businesses and • create sustainable neighborhoods
Allow meaningful community input into creating community plans and implement the community • vision layout in these plans
APPX_000548
Cumulative impaCts: Changing Regulatory Culture to address environmental injustice & environmental Racism 19 1 Sadd JL, Pastor M, Boer T , Snyder LD. ‘Every breath
you take… The demographics of toxic air releases in
Southern California. Economic Development Quarterly
13:107-123, 1999.
2 Boer T.J., Pastor M, Sadd J., Snyder L. 1997. Is
There Environmental Racism? The demographics of
Hazardous Waste in the Los Angeles County. Social
Science Quarterly 78: 793-810.
3 Pastor, Manuel Jr., James Sadd, and Rachel Morello-
Frosch. Waiting to Inhale? The Demographics of Toxic
Air Release Facilities in 21st Century California: Social Science Quarterly, Volume 85, Number 2, June, 2004
& Rachel Morello-Frosch & Jim Sadd. Breathless:
Pollution, Schools, and Environmental Justice in
California. Policy Studies Journal, vol. 34, no. 3, 2006 4 Multiple Air Toxic Exposure Study in the South Coast Air Basin—MATES III. Final Report. South Coast Air
Quality Management District. September 2008.
5 Bansal, Shipra et al. Holding Our Breath: Environmental Injustice Exposed in Southeast Los Angeles. Communities for a Better Environment. July 1998.
6 http://www.rtknet.org/db/tri as viewed on September
21, 2009.
7 May, Julia. The Increasing Burden of Oil Refineries and Fossil Fuels in Wilmington, California. Communities for a Better Environment. April 2009.
8 California Air Resources Board produced this map
as a part of its Neighborhood Assessment Program
for Wilmington. http://www.arb.ca.gov/ch/Draft_
WilmingtonNAP_ChERRP_11_05.pdf as viewed on
October 27, 2009.
9 Sexton, Ken. 1997. Sociodemographic aspects of
human susceptibitility to toxic chemicals: Do Class and race matter for realistic risk assessment. Environmental Toxicology and Pharmacology 4 (1997) 261-269.
10 In this methodology, the notion of household
vulnerability combines rather traditional concepts
of family (percentage married) and neighborhood
stability (percentage single-family dwellings; percentage owner-occupied housing units; percentage occupied
housing units), which may influence one’s ability to
respond appropriately to emergency events. Race/
ethnic vulnerability combines variables that may
relate to one’s ability to access the political system
(percentage native born; percentage not linguistically
isolated; percentage White, non-Latino). The economic
vulnerability index attempts to capture how people
perform economically, which likely has profound social
and political ramifications (percentage employed in
professional or managerial occupations; percentage
of households with incomes exceeding 1.5 times the
poverty level; percentage of persons 25 years and older with a college degree. The final dimension, relating
to mobility, expresses how households may be able
to respond (e.g., evacuate) in case of an emergency
(percentage of households with a vehicle available;
percentage of workers who commute by auto/truck/van;
percentage of workers with private vehicle; percentage
of the population with no physical disability). The
comprehensive or cumulative vulnerability index
incorporates all four of the above dimensions such
that neighborhoods with lower scores (represented in
orange and red) are likely more vulnerable to pollution exposure and risk events than neighborhoods with
higher performance scores.
This is based on the analysis of C. Scott Smith and
Professor Raul Lejano (UC Irvine) for CBE in the
Regional Geographic Initiative: Community Air Toxics
Project. Final Grant Report to US EPA. Communities
for a Better Environment. October 2006.
11 See Professor Pastor’s presentation to AQMD
at: http://www.aqmd.gov/pubinfo/events/
communityhealthairqualityconf/PDF/Pastor_
AQMDJuly2009.pdf Slide 36.
Endnotes
APPX_000549
20 Communities for a Better environment
12 For more on this see: http://www.aqmd.gov/rules/
CIWG/index.html as viewed on October 2, 2009.
13 For more on this see: http://www.arb.ca.gov/ch/
programs/ej/ej.htm as viewed on October 2, 2006.
14 NEJAC. Ensuring Risk Reduction In Communities
With Multiple Stressors: Environmental Justice And
Cumulative Risks/Impacts. December 2004
15 Environmental Law Institute. Opportunities for
Advancing Environmental Justice: An Analysis of
US EPA Statutory Authorities. Environmental Law
Institute. November 2001.
16 SB 115 (Solis), AB 1553( Keely), AB 2312 (Chu), SB
1390 (Firebaugh), among others
17 Recommendations of California Environmental Protection Agency (Cal/EPA) Advisory Committee on Environmental
Justice to Cal/EPA Interagency Working Group on
Environmental Justice. Final Report. September 30,
2003
18 See various studies documenting levels of emissions and exposure from I-710:
Kathleen H. Kozawa, Scott A. Fruin, Arthur M. Winer.
Near-road air pollution impacts of goods movement
in communities adjacent to the Ports of Los Angeles
and Long Beach. Atmospheric Environment 43 (2009)
2960–2970
California Department of Transportation, Traffic Data
Branch, 2006. Annual Average. Daily Truck Traffic.
http://traffic-counts.dot.ca.gov/truck2006final.pdf.
Zhu, Y., Hinds, W.C., Kim, S., Shen, S., Sioutas, C.,
2002. Study of ultrafine particles near a major highway with heavy-duty diesel traffic. Atmospheric Environment 36, 4323–4335.
19 For the flowchart of the public participation framework see: http://www.metro.net/projects_studies/I710/
images/710_fact_sheet_cpf.pdf
20 See Environmental Subject Working Group
meeting notes from June 4, 2009: http://www.metro.
net/projects_studies/I710/community/images/
Environment%20SWG%2006-04-09.pdf
21 Public Resources Code (PRC) section 21083
22 Internal memo from Leslie M. Krinsk, Senior Staff
Counsel to Michael P . Kenny, Executive Officer at
California Air Resources Board titled CEQA and
Environmental Justice. March 8, 2002.
23 103 Cal.App.4
th 98 (2002).
APPX_000550
Cumulative Impacts
Changing Regulatory Culture to Address
Environmental Injustice & Environmental Racism
Case Studies and Recommendations
Author:
Bahram Fazeli, Research & Policy Analyst
With Contributions and Review From:
Jesus Torres, Julia May, Adrienne Bloch, Guillermo Jaimes, Juan Ramirez, Strela Cervas, and with special thanks to Shana Lazerow for her extensive comments.
Photography:
Yuki Kidokoro, Jennifer Ganata, Jesus Torres, Darryl Molina, Bertalina Chavac, Jesse Marquez, Rember Sosa
We thank the James Irvine Foundation for supporting CBE’s Environmental Health and Democracy Project and making this report possible.
Design and Layout: Design Action Collective, Oakland, CA Printing: Inkworks Press, Berkeley, CA. Printed on recycled paper.
October 2009
Communities for a Better Environment
5610 Pacific Blvd. Suite 203, Huntington Park, CA 90255 www.cbecal.org
CBE
APPX_000551
LONG BEACHLONG BEACH
SAN PEDROSAN PEDRO
CARSONCARSON
WILMINGTONWILMINGTON
TORRANCETORRANCE
LOMITALOMITA
SIGNAL
HILL
SIGNAL
HILL
RANCHO
PALOS
VERDES
RANCHO
PALOS
VERDES
WEST
CARSON
WEST
CARSON
PACIFIC COAST
7TH
OCEAN
PACIFIC COAST
ANAHEIM
223RD
WESTERN
4TH
LOMITA
SEPULVEDA
AVALON
ALAMEDAALAMEDAMAIN
FIGUEROA
MAGNOLIA
REDONDO
GAFFEY
LONG BEACH
PALOS VERDES
WILMINGTON
BROADWAY
PASEO DEL MAR
SHEPARD
HARBOR
OCEAN
SEPULVEDA
WILMINGTON
SANTA FE
ATLANTIC
WILLOW
AIRPORT
HARBOR SCENIC
SHORELINE
I 405
I 110
I 710
I 110
I 405
STATE HWY 47STATE HWY 47
DRAFT - ARB-PTSD-EIB/11-3-05
0 1,000 2,000500
Meters
Other
Schools
Hospitals
Airports
Parks
Intermodal Facilities (NTAD)
Major Railyards
Railroads
Roads
Wilmington Neighborhood Assessment Program (NAP) Facilities Wilmington NAP Facilities
PETROLEUM REFINING
PETROL PRODN, DISTRIBN
CHEMICAL RELATED
POWER PLANTS & RELATED
TRUCKING / WAREHOUSING
MARINE & RELATED
AUTO RELATED
WELDING RELATED
GOVT / MILITARY
MISC INDUSTR / COMMERC
MISC SERVICES
Changing Regulatory Culture to Address
Environmental Injustice & Environmental Racism
CAsE studIEs And RECommEndAtIons
october 2009
CumulAtIvE
ImpACts:
CBE Communities for a Better Environment
CBE
Communities for a Better Environment
5610 pacific Blvd., suite 203
Huntington park, CA 90255
phone (323) 826-9771
Fax (323) 588-7079
www.cbecal.org
APPX_000552
APP
ENDIX I
APPX_000553
ENVIRONMENTAL JUSTICE
WORKING GROUP CASE STUDIES
Appendix To The Recommendations For
The California State Lands Commission
Environmental Justice Policy Update
November 2018
APPX_000554
TABLE OF CONTENTS
Case Studies .............................................................................................................. 3
1. California Native American Tribes and Indigenous Peoples: Ancestral Land Return to Kashia Pomo Heals Lands and Communities .................................... 3
2. Oil and Gas Operations: Tesoro Oil Terminal Expansion Project Review Ignored Impacts to EJ Community ................................................................. 5
3. Oil and Gas Operations: State Lands Commission Rejects LNG Terminal on Oxnard Coast ...................................................................................... 7
4. Ports and Transportation: Harbor Community Benefit Foundation’s Off-Port Mitigation Projects Help EJ Communities in Los Angeles. ................................. 8
5. Ports and Transportation: Port of Long Beach Community Grants Program – A Lesson in Improving Funding for EJ Projects ................................................ 9
6. Public Access and Conservation: Popular Newport Beach Fire Rings Pollution Concern Has Race and Class Implications for Public Access. ......................... 11
7. Water & Pollution: Costly and Environmentally Damaging Desalination Project Tries to Buy Its Way into Huntington Beach. ................................................ 12 APPX_000555
3 CASE STUDIES
The following case studies are drawn from the experience of California Native American Tribes and environmental justice (EJ) communities to illustrate the need for a strong Environmental Justice Policy at the California State Lands Commission (SLC). Perspectives of low-income Latino, African American, Asian Pacific American and Native American communities are often different from those of more affluent European American communities with respect to recreational activities, ports, and fossil fuel operations because of the ways the distinct communities experience environmental, economic, and cultural impacts of those activities.
Together, these stories serve to illustrate the recommendations developed by the Environmental Justice Working Group. Each case study that follows provides references to specific recommendations for those readers who are interested.
1. ANCESTRAL LAND RETURN TO KASHIA POMO HEALS LANDS
AND COMMUNITIES
By: Angela Mooney D’Arcy, Executive Director at Sacred Places Institute for Indigenous Peoples
Relevant EJ Working Group Recommendations:
• V.1. California Native American Tribes and Indigenous Peoples, d) Support California Native American Tribes around land returns and tribal management and/or co-management of restored lands as part of a just transition.
• V.5. Public Access and Conservation, a) Support Native people’s ability to engage in cultural activities on their homelands and engage with traditional cultural practitioners in development of conservation and invasive species control plans; b) Conserve coasts, oceans, and inland waterways, including using expanded cultural perspectives of how Native Americans and communities of color traditionally use or enjoy these natural resources. Challenge narrow racial views of acceptable uses of these areas.
In 2015, 688 acres of ancestral
coastal homelands were returned
to the Kashia Pomo people who
have called what is now known as
northern Sonoma County home for
at least 12,000 years. A coalition
of organizations and agencies,
including the Trust for Public Land,
worked with the Kashia Pomo Tribe to
purchase the property from a family
that had title to the land from which
the Kashia were forcibly removed
over 150 years ago.
Terray Sylvester, courtesy of The Trust for Public Land APPX_000556
4 The issue of ancestral land return is important for Indigenous Nations, EJ communities, and the public because restoring tribal access to ancestral lands supports healing landscapes and communities.
For thousands of years the Kashia lived in balance with these coastal lands and waters. The first acts of environmental racism in California occurred when settler colonists landed on the coasts of California shores. At the time of contact 150 years ago, the Kashia Pomo were violently displaced from their coastal ancestral homelands. All but 40 acres of their ancestral territory, including all coastal lands, were lost when the Tribe was moved to an inland reservation with no access to water. Indigenous people were often forcibly removed from their ancestral homelands and traditional ways of living sustainably in relationship with local ecosystems, and then discouraged or outright prohibited from returning home.
The more than 150 Native Nations in this state have been fighting since those first acts of violent displacement to protect the lands and waters within their ancestral territories and undo the environmental damage caused by the introduction of new species and systems of agriculture that did not consider local ecologies or long-term principles of sustainability.
The Kashia Pomo land return is an example of how public agencies like SLC can support environmental justice for Indigenous Nations today. The nearly 700-acre Kashia Coastal Reserve located in northern Sonoma County includes coastal prairie and redwood forests and offers the promise of coastal access for Kashia people and the public. As part of the agreement, the Kashia will utilize traditional management practices to guide forest restoration efforts. In addition to supporting the Tribe’s access, the Kashia have agreed to allow the California Coastal Trail to extend across their newly reacquired lands, thus facilitating the first public access to this area in generations. The Kashia Coastal Reserve now serves as a place where tribal members can engage in traditional cultural practices such as medicine-and food-gathering and ceremony. The Reserve will also serve as a gateway to educate the public about historic and contemporary Kashia culture.
This case study highlights why it is so important for state agencies like SLC, the largest land holder in the state, to articulate a commitment to land return when possible. Too often the project of ancestral homeland return to Indigenous Nations is characterized as a zero sum game with the Indigenous Nations “winning” at the expense of existing recognized land holders and/or the public. The story of the Kashia land return demonstrates how such policies benefit everyone and contribute to long-term healing of lands and peoples.
Resources:
• Dancing in the Balance, Plus M Productions, Bay Area Open Space Council. • Home at Last, Mary Catherine O’Connor, Lands & People, Fall/Winter, 2016. • The Trust for Public Land, Kashia Coastal Reserve.
APPX_000557
5 2. TESORO OIL TERMINAL EXPANSION PROJECT REVIEW IGNORED IMPACTS
TO EJ COMMUNITY
By: Roger Lin, Clinical Supervising Attorney, Environmental Law Clinic, UC Berkeley School of Law; Shana Lazerow, Legal Director, Communities for a Better Environment; Bahram Fazeli, Director of Research and Policy, Communities for a Better Environment.
Relevant EJ Working Group Recommendations:
• IV.2. Community Engagement, c) Notices for projects and meetings. • IV.3. EJ Analysis, b) EJ Assessment and transparency; c) Quality EJ analysis; g) Equitable legal practices • V.3. Oil and Gas Operations, d) Prevent the expansion and renewal of marine and coastal oil terminals and pipelines.
In January 2015, SLC issued a notice of availability and intent to certify a final environmental impact report (EIR) for a new 30-year lease to allow Tesoro Petroleum Company to expand the Avon Marine Oil Terminal in Martinez, Contra Costa County. The EIR stated that the purpose of the project was to “continue operations at, and maintain the level of refined petroleum product exported through, the existing Avon Terminal, thereby maintaining the operation and viability of Tesoro’s associated Golden Eagle Refinery.” 1 This project was slated to enable lower quality oil feedstocks to be refined in California, which would result in increased health impacts to frontline communities already overburdened with refinery pollution.
Communities for a Better Environment (CBE), which for decades has worked with EJ communities impacted by the oil industry, learned about this oil terminal expansion proposal late in the process. Neither CBE, nor affected community residents in Martinez, received sufficient notice of this proposal as indicated by the few public comments submitted into the record. The potential health impacts of this project raised concerns for CBE given its extensive research on increased fuel imports to California of lower quality oil feedstocks.
Lower quality crude presents significant worker and public health, and safety issues at and around oil refineries including at the Golden Eagle Refinery.
2 CBE and its community members were concerned that
the EIR did not comment on the quality of crude being imported through state lands in this project.
Considering the lack of public process, CBE
was forced to litigate the approval of the
project with a limited record. The project EIR
that the SLC certified disclosed neither the
quality of crude to be imported, associated
potential worker and public health impacts,
impacts on sensitive and protected species, nor
that the project expanded the marine terminal
to enable the use of massive oil tankers at least
twice the size of those that used the terminal
prior to the project approval.
1 http://www.slc.ca.gov/info/Reports/Avon/NOA.pdf
2 http://www.cbecal.org/wp-content/uploads/2013/03/Widespread-Corrosion-at-the-Richmond-Refinery-022113.pdf APPX_000558
6 Throughout the litigation, CBE uncovered documents confirming the latter expansion. However, the court ruled that CBE’s claims “were not exhausted” at the administrative level, before the SLC, and that CBE should have raised those comments earlier. That was impossible as CBE and affected community residents neither received adequate notice nor engagement regarding the approval of this oil refinery expansion.
Further, the SLC threatened CBE with massive costs for the record, suggesting CBE would be liable for more than $120,000 if it chose to pursue its members’ concerns in court. CBE reached out directly to State Lands Commissioners seeking relief but the threat was never retracted. SLC’s problematic demand was extremely detrimental to public engagement and should serve as a lesson for future engagement on projects that affect EJ communities. Here is what SLC should have done differently:
• Undertake a good faith effort in early and extensive outreach, and meaningful engagement, to inform environmental justice groups, community groups, public health organizations, sensitive receptors, environmental groups, community leaders and residents of the scope of the project, and potential impacts, and seek input proactively.
• Allow sufficient time for residents and activists to review the project proposal and potential health/ environmental impacts, and to engage with SLC staff regarding various aspects of the project. T ime
also should be allowed for impacted community and EJ groups to provide comments throughout the environmental review process.
• Fully analyze all the potential health impacts of the project by performing a Health Impact Assessment and a comprehensive Cumulative Impacts Assessment.
• Genuinely and comprehensively explore all alternatives and mitigation measures. • Avoid threatening EJ communities and organizations with financial penalties and show appreciation for EJ organizations that step up to identify gaps in SLC’s analysis and are using their limited nonprofit
resources to engage the community.
• Provide resources for EJ organizations working on behalf of members and residents to explore safer alter
natives to this fossil fuel expansion project.
Resources
• Lawsuit Targets 30-Year Plan For Bay Area Marine Ter
minal Receiving Ships Full Of Dangerous
Crude Oil.
• Tesoro Refinery Expansion Poses Risk To Community.
APPX_000559
7 3. STATE LANDS COMMISSION REJECTS LNG TERMINAL ON OXNARD COAST By: Lucas Zucker, Policy and Communications Director, Central Coast Alliance for a Sustainable Economy (CAUSE)
Relevant EJ Working Group Recommendations:
• IV.2. Community Engagement, a) Public participation; c) Notices for projects and meetings. • IV.3. EJ Analysis, b) EJ Assessment and transparency; c) Quality EJ analysis. • V.3. Oil and Gas Operations, e) Stop new fossil fuel power plants, liquefied natural gas, and other fossil fuel export terminals from being built in EJ communities and elsewhere within Commission jurisdiction.
From 2003 to 2007, community members in Oxnard fought the proposal by BHP Billiton to build a liquefied natural gas (LNG) terminal off the city’s coast. BHP Billiton is the world’s largest mining company and Oxnard is a predominantly Latino working-class immigrant community. BHP Billiton’s proposed LNG terminal would have been the largest source of air pollution in Ventura County, with gas pipelines running beneath densely populated residential neighborhoods, schools, and hospitals. The LNG proposal threatened the health and safety of this community and SLC had the opportunity to reject the project in order to protect public health.
A large public relations campaign by BHP Billiton argued that the project was necessary to maintain a reliable supply of power, a claim which later proved untrue. Oxnard has long been seen as a sacrifice zone for polluting projects that are unwanted in nearby affluent communities. The community had limited resources to fight a well-funded project that had political support from Governor Schwarzenegger.
Local EJ advocates argued that Oxnard was targeted for a dangerous and polluting project because of the linguistic, educational, economic, and social disadvantages of its people and that clean energy alternatives had not been considered, an approach that would not have been viable elsewhere on the California coast. Ultimately, the SLC voted 2-1 to reject the project after nearly 3,000 local residents mobilized to attend an SLC hearing on the issue in Oxnard.
This is an important example of SLC Commissioners
taking a stand for EJ and is the kind of outcome
a successful Environmental Justice policy would
hopefully encourage and support. However, there
are lessons to be learned from this project for
future decisions with major EJ implications. For
example, key advocates involved in the issue said
they had little interaction with SLC staff, don’t
remember significant translated information for this
majority Spanish-speaking community, nor official
acknowledgement or analysis of the project as an
EJ issue.
APPX_000560
8 If a strong Environmental Justice policy had been in place, staff would have devoted additional resources to proactive outreach and accessibility for this community that historically has major barriers to engagement. Official staff analysis would have identified EJ concerns for a project proposed for an EJ community, and required a more thorough examination of possible alternatives and potential impacts. In the end, accessibility measures employed by SLC, like holding a large public hearing in Oxnard, and the understanding of SLC Commissioners helped the community achieve environmental justice in this case.
Resources:
• CAUSE: Environmental Justice and Health Equity.
• Proposed LNG Terminal Off Oxnard Terminated By State Commission. • Residents Speak Out About Proposed Coastal Gas Plant. • California Rejects Natural Gas Terminal For BHP Billiton.
4. HARBOR COMMUNITY BENEFIT FOUNDATION’S OFF-PORT MITIGATION
PROJECTS HELP EJ COMMUNITIES IN LOS ANGELES
By: Taylor Thomas, Research and Policy Analyst, East Yard Communities for Environmental Justice.
Relevant EJ Working Group Recommendations:
• IV.1. Staff and Commission, c) Agency program reforms. • IV.2. Community Engagement, d) Account for benefits.
• V.4. Ports and Transportation, a) Push for the clean-up of ports and freight, given the incompatible land uses with residential communities; b) Promote clean transportation and zero emission vehicle adoption to reduce pollution at ports.
The Harbor Community Benefit Foundation
(HBCF), in partnership with the Los Angeles Board
of Harbor Commissioners, administers the Port
Community Mitigation Trust Fund (PCMTF). The
PCMTF was established to mitigate the off-port
impacts of port operations in Wilmington and San
Pedro, which are EJ communities overburdened by
multiple sources of pollution. This was a landmark
process that underwent approval through the State
Lands Commission – a port had to establish through
a study that there was a direct connection
between its operations and health impacts in
adjacent communities.
APPX_000561
9 The ports of Long Beach and Los Angeles are the single-largest fixed sources of pollution in the Greater Los Angeles region. The communities adjacent to the ports and the facilities that support their operations experience elevated exposure to pollution and cumulative health impacts. However, these negatively impacted communities are often excluded from decision-making processes, and their concerns are rarely heard and prioritized when assessing port-related projects. HBCF seeks to mitigate impacts from such projects by providing grants to address quality-of-life issues in these communities.
HBCF has funded many projects and technologies that have contributed to better air quality in the region. Notably, HBCF commissioned an Off-Port Land Use Impact Study that highlighted how port adjacent communities experience many of the negative impacts of goods movement but receive little- to-no economic benefits because the vast majority of port and port-related jobs and workers do not live in the adjacent communities. Given the SLC’s oversight of California ports, it is important to understand that on-port pollution travels to off-port communities and that mitigation funds are valuable in helping address historic transportation emission burdens on impacted communities. Without groundswell advocacy from surrounding communities, this program would not have materialized. We emphasize that this case shows how critical it is for EJ communities to not only be included in decision-making processes, but have decision-making power in projects that will affect their communities.
Resources:
• Who Benefits from the POLA?
• Harbor Community Benefit Foundation
5. PORT OF LONG BEACH COMMUNITY GRANTS PROGRAM – A LESSON IN
IMPROVING FUNDING FOR EJ PROJECTS
By: Taylor Thomas, Research and Policy Analyst, East Yard Communities for Environmental Justice
Relevant EJ Working Group Recommendations:
• IV.1. Staff and Commission,
c) Agency program refor
ms.
• IV.2. Community Engagement,
d) Account for benefits.
• V.4. Ports and Transpor
tation, a) Push for
the clean-up of ports and freight, given
the incompatible land uses with residential
communities; b) Promote clean transportation
and zero emission vehicle adoption to reduce
pollution at ports.
APPX_000562
10 The ports of Long Beach and Los Angeles are the single-largest fixed sources of pollution in the Greater Los Angeles region. The communities adjacent to the ports and the facilities that support their operations experience elevated exposure to pollution and cumulative health impacts. These communities are often not included in the decision-making processes concerning port-related projects. Finding and deploying resources to alleviate these transportation impacts to EJ communities is important. The Community Grants Program, managed by an advisory council selected by the Mayor of Long Beach, funds projects and programs in the communities adjacent to the Port of Long Beach to mitigate negative impacts from port operations. Initially, the Port of Long Beach attempted to avoid funding off-port projects by stating that it needed approval from the State Lands Commission before considering a program, asserting that the Commission would be hesitant to establish a precedent for ports providing continuous funding streams to mitigate off-port impacts. Following the results of a “CEQA-like” review, the Commission found that there was a nexus between off-port impacts and on-port operations and allowed the Port to move forward with crafting this grants program.
The Community Grants Program has since been able to fund numerous groups and projects in Long Beach, such as asthma education programs and air filtration systems. The road to getting effective projects fully funded has been somewhat difficult, and suggesting the need for program improvements. Before the grants program existed, mitigation projects were sometimes funded on a case-by-case basis through a CEQA process. This was an ineffective process that allowed port projects to move forward while only covering a portion instead of the full mitigation costs of a project’s lifetime. Community advocates raised concern about this this discrepancy over many years and, to avoid litigation, in 2015 the Port of Long Beach set out to address it through continuous funding for mitigation projects. Funding pollution reduction programs for EJ communities should not face so many hurdles. SLC should glean lessons from this case in easing barriers to environmental, economic, and health benefits that are due EJ communities. Specifically, we call on the Commission to use its authority to fully mitigate impacts on port-adjacent communities, and ensure that municipal managers of granted lands accommodate EJ communities’ participation needs in project decisions.
Resources:
• POLB Community Grants Program
• Community Impact Study
APPX_000563
11 6. POPULAR NEWPORT BEACH FIRE RINGS POLLUTION CONCERN HAS RACE
AND CLASS IMPLICATIONS FOR PUBLIC ACCESS
By: Marce Gutiérrez-Graudiņ š, Director, Azul
Relevant EJ Working Group Recommendations:
• IV.2. Community Engagement, a) Public participation.
• a) V.5. Public Access and Conservation, b) Conserve coasts, oceans, and inland waterways, including using expanded cultural perspectives of how Native Americans and communities of color traditionally use or enjoy these natural resources. Challenge narrow racial views of acceptable uses of these areas; d) Actively encourage public access to the state’s natural areas especially for disadvantaged communities that live nearby but haven’t traditionally been able to enjoy them.
Newport Beach is a recreation destination with popular fire rings that local people and visitors have enjoyed for decades. However, in March 2012, the Newport Beach City Council voted unanimously to remove 60 fire rings on the basis of alleged pollution concerns. This posed a problem to non-coastal residents who had enjoyed the rings as an affordable and easily accessible gathering place for beach bonfires and other recreational activities in a locality known for its expensive real estate and amenities.
Newport Beach has a median property value of $1.58 million. In short, this fire ring ban would effectively curtail recreational access to the beach for anybody not lucky enough to own coastal property. The chain of events following the ban could have been averted if the California Coastal Commission had an EJ policy that required an analysis of the EJ implications of such action.
In May 2012, the Newport Beach City Council applied to the Coastal Commission to remove the rings.
The Coastal Commission waited for the South Coast Air Quality Management District (AQMD) to weigh in. In June of that year, AQMD staff made a proposal based on Rule 444 (beach burning) that would eliminate fire rings located within 700 feet of homes. All of Newport Beach’s fire rings were located within this distance, making the application for removal an effective ban. This led to a larger problem, as other cities realized the AQMD’s ruling could potentially affect them and lead to a district-wide or, worse yet, state wide beach bonfire ban. What followed included partial ring operation, legislative proposals and interagency discussions until the rings were reinstated in 2015.
Unfortunately, EJ was never seriously considered
as a factor even though racially-coded
discriminatory language was used in many
residents’ correspondence calling for ring
removal. Additionally, Newport Beach City
Council already had a shameful racist history of
curtailing beach facility access to ethnic groups.
In 2003, Councilman Richard Nichols declared
in a local paper his aversion to expanding a
grassy picnic area in Corona del Mar because
“with grass we usually get Mexicans coming in
there early in the morning and they claim it as
theirs, and it becomes their personal, private
grounds all day."
APPX_000564
12 He followed this comment to the Los Angeles Times with “To get this [meeting] rip-roaring ... they [council members] contacted everybody in the Mexican community, including many of those who are for Mexico, including those that feel this is their country.” He continued by saying that "They are trying to activate many of the pro-Mexican organizations. In general, most of those organizations want to see California turned over to Mexico."
This was a public controversy driven by local authorities and affluent property owners who felt entitled to determine which people deserved to enjoy local beaches. In the issue of the Newport Beach fire rings, the Coastal Commission was able to challenge the local power structure and defend beach access by invoking the Coastal Act. In contrast, the South Coast AQMD seemingly acted without consideration for public use and endangered recreational access statewide. Had a stronger EJ policy been in place, use of the rings would have never been banned, and more importantly, it should serve as a cautionary tale to those that seek to exclude whomever they deem unlikeable from public resources in the vicinity of their properties.
Resources:
• About Newport Beach's Fire Rings
• Newport Beach Council Debates Nichols Flap
• Fire-Pits Controversy Timeline
• Fire Pits Approved In Newport Beach, But Not At Corona Del Mar
7. COSTLY AND ENVIRONMENTALLY DAMAGING DESALINATION PROJECT
TRIES TO BUY ITS WAY INTO HUNTINGTON BEACH
By: Marce Gutiérrez-Graudiņ š, Director, Azul
Relevant EJ Working Group Recommendations:
• IV.1. Staff and Commission, a) SLC staff consideration of EJ. • IV.2. Community Engagement, b) Identification of EJ communities. • V.7. Water & Pollution, f) Analyze the impacts of desalination projects and promote transparency.
For nearly two decades, Poseidon has tried to
get permits to operate a $1 billion desalination
plant in Huntington Beach, Orange County.
Community members and EJ advocates
understand that the desalination plant would
pollute coastal waters and kill marine life.
Additionally, desalinated water is some of the
most energy intensive and expensive water to
produce.
APPX_000565
13 The Poseidon case shows how a company can exploit drought and water supply fears to sell a costly project that the public will be stuck paying for decades. Poseidon wants local ratepayers to subsidize its project with a 30-year contract that forces the water district to buy desalinated water even if it doesn’t need it, which will raise water rates.
The permitting process for this project was highly problematic, particularly in choosing whose opinions were elevated, mischaracterizing advocates, and minimizing EJ concerns. For example, in an SLC staff report produced ahead of an important Commission vote in October 2017, staff incorrectly equated local Orange County grassroots groups with Los Angeles-based chambers of commerce and non-related commercial associations as equally valid voices on EJ; staff even individually listed names of pro-project, outside organizations and only footnoted local grassroots groups that were opposed to the project. As a result of these choices about who to listen to and how to characterize their perspectives, the staff report did not adequately present EJ concerns for commissioners’ consideration.
The Poseidon project dragged on for two decades at the expense of needed focus on the conservation and preservation of water resources that already exist. If a good EJ policy had been in place, the public would have been made more aware of the risks and costs desalination posed both to people and the environment. And the staff report would have properly identified EJ communities and their concerns, and addressed those concerns.
Resources:
• Poseidon Desalination Plant: What To Know About Its Pros And Cons For Southern California Water • Bone And Brown: Poseidon Desalination Is A Bad Deal For Orange County Business And Consumers • Desalination Leading To Deadly Lack Of Magnesium
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APPENDIX 4
California Coastal Commission Comments on
Final IS/ND for the World Oil Tank Installation Project October 26, 2021
STATE OF CALIFORNIA - NATURAL RESOURCES AGENCY GAVIN NEWSOM, Governor
CALIFORNIA COASTAL COMMISSION
South Coast Area Office
301 E Ocean Blvd, Suite 300
Long Beach, CA 90802
(562) 590-5071