By Nancy Hiser, LNA Environmental Committee
The Critical Energy Infrastructure (CEI) Hub industries, the cluster of tank farms along the Willamette River in Linnton, are required to report their toxic air emissions to the state Department of Environmental Quality (DEQ) like all other emitting industries.
Linnton Neighborhood Association (LNA) has recently written a letter of complaint to DEQ about accepting inaccurate reporting (Emissions Inventories) from the CEI Hub. Also, they have not acted on a report in March of 2021 which was sent to DEQ by Cascadia Action, on our behalf.
It has been reported to DEQ that four VOCs — benzene, ethylbenzene, toluene, xylene(s) – are being emitted by internal floating roof gasoline tanks (IFRTs) and asphalt tanks at the CEI Hub and are likely thirty times (30x) higher than what these industries report. This is because the tank farm owners are reporting to Cleaner Air Oregon using AP-42, a formula for estimating emissions written by the
oil industry.
EPA investigated heated asphalt and IFRT fuel oil tanks, identical to some at the CEI Hub, in 5 New England states beginning in 2007 and then measured emissions. All of those investigations found violations of the Clean Air Act which resulted in fines. Two states, Maine and Massachusetts,
have successfully legislated against using AP-42.
EPA’s documentation of AP-42 cites a “limited availability of actual tank test data” for IFRTs but includes a study that tested a 926,310-gallon IFRT gasoline tank and the AP-42 model underpredicted this tank’s actual emissions by as much as 59%.
Other Oregon industries with Title V, Standard, or Simple ACDPs are required to submit more accurate Emission Inventories to DEQ’s Cleaner Air Oregon than the CEI Hub industries. Since these reports by industries are used to identify and prioritize industries that are probably posing the greatest risk to human health, it is unacceptable that less accurate reporting is accepted from these CEI industries.
In our recent letter, LNA asks DEQ to measure emissions from heated asphalt and heated residual oil tanks with EPA Method 204, as is currently done in Maine and Massachusetts, and to conduct fence line monitoring of IFRT tank emissions of benzene, ethylbenzene, toluene, and xylene with EPA Method 325 so we get accurate measures of these harmful pollutants.
If LNA does not get a prompt and adequate response from DEQ, a media and social media campaign is planned.