Saturday, July 19, 2014

My Comments of the EPA Report on Violations of the Clean Air Act by Savoy Energy on Witt Farm

On page 3, 2nd paragraph the EPA inspectors wrote: "Mr. Rokos [Savoy's Operations Manager] stated that the pilot light is checked two or three times per day to ensure that it remained lit."
I wonder why every home appliance needs to have a failure-proof pilot or a gas shutoff but industrial equipment used in oil processing does not - even if within a residential area.

Also on page 3 right below the above sentence it says: "Vapors from the tanks' headspace are piped to the flare at ambient pressure (no fan or pump is used to draw vapors from the tanks to the flare)."
Seems to me like cutting corners again just to make profit with the least investment / why is no such equipment used and why is this permittable?

Below the above sentence, still on page 3: "Since the system uses a common collection line, vapors from each individual tank can flow to the headspace of any other tank." Again, this sounds like a less than appropriate setup.

Also on page 3, paragraph 4, is stated that in contrary to earlier statements, the natural gas is NOT entirely used but only the propane portion, which is less than 20% by weight, and only 12% by molecular percent (Savoy's own gas analysis reported here). The report further states: "Methane and ethane are pulled off the propane tank and used as fuel gas for various pieces of equipment at
the facility."
Methane and ethane together contribute to 47% of the natural gas harvested in the 7 wells connected to the CPF. I doubt very much that all of this gas is put to good use and suspect that machinery is running to consume these gas components or they are still flared off if they are not gased off elsewhere. The report mentioned nonchalantly, that previous to April 8, 2014, all gas was flared off - which lasted for more than a year and was a scandalous waste and unnecessary air pollution just because Savoy could not make enough money from capturing the gas before the severe winter of 2013/14 raised the prices for natural gas and propane.

Before going to page 4, I want to state some principle shortcomings of all environmental inspections in Michigan and many (if not all) other states.
1.) Inspections have to be announced, giving the inspected companies more than enough time to fix shortcomings they are well aware of, thereby inspections show the best possible operation practices and are not representative to every day operations.
2.) Business owners have to permit access to their site. I suspect that the EPA could have applied for a court order to go in - thus adding additional time for companies to prepare unrealisticly good conditions before inspectors arrive.
3.) Compare 1.) and 2.) to unannounced inspections of small restaurants by the health departments. The difference in procedures make no sense!
4.) Findings during inspections can be held back by the companies declaring them as confidential business informations.
All these restrictions clearly undermine the public interest of immediate, unbiased inspections to prevent threats of human heath due to environmental pollution and threats to the environment and ecosystems.

Page 4, 1st paragraph: Savoy's operation's manager Jack Rokos was in charge to allow the EPA inspectors to use equipment solely used to detect leaks. I think the EPA should have the right to use this equipment even without permission!

Page 4, paragraph 2 states "a few small leaks at the compressor" shown in videos and photos. In paragraph 3, leaks in two of the four oil tanks were found. Again, remember that they are all connected - meaning that already one leak is sufficient to vent all 4 oil tanks into the "clean 100% pure Michigan air".

Page 4, paragraph 4 states leaks on 3 out of 4 water tanks, with massive venting of fumes that made the inspectors move out of the area.

To really value the significance of these leaks, I want to remind my readers that what you smell as bad odor is only a warning that with theses smelly fumes, odorless poisonous and cancerous volatile hydrocarbons are vented off into Michigan's Clean Air - and thus threaten the health of at least the closest neighbors. Refer to the legend of photo 1 on page 5: "Note the proximity of the house and public highway to the facility".

In paragraph 5 on page 4, the EPA inspectors state: "All leaking components at the compressor and
from the thief hatches and pressure relief device were pointed out to Savoy representatives."

The question now is: Did they do anything about it - or do they just continue to leak poisonous and cancerous compounds?

In the last paragraph of page 4 - under Closing Conference, the EPA inspector writes: "I expressed concern that the pressure relief valves and thief hatches were not properly weighted to ensure that
vapors are first directed to the flare, then to the Enardo pressure relief valves in the case of an overpressurization event, and then to the thief hatches, in that order."

Mr. Rokos of Savoy Energy stated that "he would have the thief hatch seals inspected and add additional weight to the hatches to ensure that they were not venting at pressures lower than necessary."
This does only seem to address some of the inspector's concerns - and what is meant by "not venting at pressures lower than necessary"? It seems to me that the system should direct any elevated pressure - and the causing gas and volatiles towards the flare and NOT vent them into the air. I hear some of the industry's typical arrogance - thinking that they can do whatever they want to do...

Even if Savoy does what Mr. Rokos indicated, how is this monitored or followed up with when the presented document is still a "internal report" and no official reporting was issued and passed on to Savoy Energy. For God's sake, this is 3 months after the inspection that objectively found VIOLATIONS. I wished I would have that much time to pay for a parking ticket or other MINOR issues compared to air pollution...

Even worse, when the EPA finally comes up with a fool-proof report (to avoid being sued by the wealthy oil and gas lobby given that the EPA is an almost bankrupt government institution) - the report will first go to Savoy before any fines or penalties are set. This sounds like Savoy is good to go and continue to improve Michigan's Clean Air for a long time to come. Maybe the City of Adrian should put a PURE MICHIGAN sign next to Savoy's Central Oil Processing Facility on Witt-Farm.

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