Proposed Mitigations for the Propane Recovery Project

The County Planning Commission has approved the EIR unanimously for the Propane recovery project.  That decision was partly (or mostly, or completely?) based on the recommendation from the Department of conservation and DEVELOPMENT.  That report is below.

Some citizens have found a couple of ridiculous claims made in the document.  I take the liberty to copy their comments below.

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Dave Black writes:

1.       The following obtuse-in-the-extreme statement:  “Airborne emissions of certain gasses do have the ability to produce odors, which can result in public nuisances and complaints from residential communities. As discussed within the Final Environmental Impact Report (FEIR) in Chapter 2-Master Responses on page 2-10, the refinery and the communities continue to work on a fenceline monitoring system, as required as part of a previous land use permit. The Propane Recovery Project appears unlikely to result in an increase of odorous emissions, as certain equipment and technology are anticipated to be installed and/ or used as part of the fenceline monitoring system.”  The last sentence is completely meaningless/illogical to any reasonable observer (“It stinks around here but we have these killer new FLMS features.  Ergo, it doesn’t stink.”).

Marilyn Bardet from Benecia adds:

From a CEQA perspective the statement quoted in #1 is ridiculous.  The Propane Recovery Project appears unlikely to result in an increase of odorous emissions, as certain equipment and technology are anticipated to be installed and/ or used as part of the fenceline monitoring system.”  First, CEQA doesn’t allow the conjecture of probability in the words “appears unlikely to result in an increase of odorous emissions….”. “Appearing unlikely” is not the same thing as fact-based evidence. The Second ERROR is obvious and hilarious: increases in odors cannot be mitigated or reduced by a fenceline monitoring system, no matter how technologically sophisticated the system! A monitoring system only reads the gases’ chemical signatures; the monitors cannot dissipate or eliminate them!
ALSO:
If there is a case to be made that there will be a significant potential (and cumulative!) increase in odors, then a mitigation measure must be drawn up and submitted as an actual plan that would reduce or eliminate that potentially significant impact, e.g., delivered to decision makers at the time the EIR is presented for final approval. The public must be able to review those planned mitigation measures to assess their potential effectiveness in eliminating environmental impacts and risks to public health and safety. Under CEQA, a mitigation measure cannot be “promised” to be submitted at a later date. Also, for emergency planning, a mitigation measure must address specificprocedures pertinent to the particular type of potentially significant incident, accident or release envisioned to be made possible by the proposed project.
The use of the Selby superfund site for a “backup construction laydown area” is potentially an OSHA issue, if nothing else. The Selby site was once used for smelting lead, tons of it over many years. There must be lead dust everywhere (some of which was detected in elevated lead levels in surface soils in Benicia’s northern hills which were slated for residential housing development in the 90’s. The final EIR for the development required a mitigation of removing up to 2′ of surface soils, to remove the lead – and other detected military explosive hazards! – before homes could be built.) The subject of serious health hazard needs to be addressed with construction workers who would be assigned, (according to the EIR statement cited) to activities at the Selby site.

The passage of the EIR is based on a fiction perpetrated by the authors of the EIR document.  Now, of course, they need more money from the county ($45,000 paid for by the refinery) to further their claims and defend their positions to the community.  See the following…

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Happy New Year from this side of the fence.

 

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