BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ BREDL@skybest.com
March 4, 2003
Marion Deerhake,
Chair
EMC Air Quality
Committee
1617 Mail Service
Center
Raleigh, NC
27699-1617
Fax:
919-733-2496
Re:
1-hour average for hydrogen sulfide acceptable
ambient limit
Dear
Marion:
On
behalf of the Blue Ridge Environmental Defense
League, I am writing to add our support to the
establishment of new health protective standards
for hydrogen sulfide in NC. I believe the
proposal from NCDENR’s independent Science
Advisory Board for Toxic Air Pollutants is a
sound one scientifically if implemented with a
one-hour average.
As
we previously discussed, I first became
interested in the problems caused by hydrogen
sulfide emissions from Associated Asphalt’s
liquid asphalt binder storage facility and
APAC’s hot mix asphalt plant in Salisbury
while caring for my dying mother in an adjacent
neighborhood. When arriving at her house I would
immediately notice the overpowering hydrogen
sulfide odors that would at times permeate her
house. I witnessed children and adults who
visited my mother have asthma attacks requiring
treatment. I saw and heard her and her neighbors
wheeze and/or struggle for breath. An unexpected
number of her neighbors require or required
oxygen. I am aware of a resident in the hydrogen
sulfide impacted area that died form an acute
asthmatic episode. The City of Salisbury has
carefully documented and verified several hundred
resident complaints about poor air quality and
horrible odors near the Jake Alexander Road
asphalt facilities over the last several years.
Odor
complaints and some of the breathing problems
have significantly decreased since NCDENR
required Associated Asphalt to install carbon
filters on their storage tanks and truck load-out
last year. Additionally, I support the currently
unimplemented Agency for Toxic Disease Registry
suggestion of using carbon filtering to capture
toxic emissions during railcar unloading (See
attached letter from ATSDR). The recently
installed carbon filtering replaced a very
ineffective odor masking system called EcoSorb
that had been used by Associated Asphalt.
Associated’s exhaust fan was also removed,
which previously exhausted 1000 cubic feet per
minute of uncontrolled toxic storage tank vapors
into the air.
I am
also writing to point out a gross error that I
noticed and reported to both NCDENR and NCDHHS.
Attachment 1 NCDENR dated 2/6/03 lists hydrogen
sulfide releases at twenty sites in NC. The
NCDENR list shows Associated Asphalt as releasing
only 4 pounds of hydrogen sulfide per year as
based on their air permit application. Frankly, I
find this emission rate unbelievable. This permit
should never have been accepted by NCDENR, and
the myth of insignificant hydrogen sulfide
releases from the plant should not be
perpetuated. The plant handles 220 million pounds
of heated liquid asphalt a year which arrives in
approximately 1200 heated rail tank cars. Heated
to a temperature of 325 degrees F., this liquid
asphalt is pumped into million-gallon storage
tanks which displace toxic vapors including
hydrogen sulfide at concentrations measured by
the company at 2500 parts per million. It is well
known that levels of hydrogen sulfide above 100
ppm can be immediately dangerous to life and
health.
Associated
pumps the 220 million pounds of heated liquid
asphalt into approximately 3800 tanker trucks,
adding anti-strip additives that further increase
dangerous toxic air releases during displacement.
In addition, there have been significant
year-round toxic fugitive emissions from heated
storage tanks that for decades vented
uncontrolled asphalt fumes into the atmosphere;
the companies include Chevron Asphalt, Inman
Asphalt, and now Associated Asphalt . How was it
possible for the state to assume that only 4
pounds of hydrogen sulfide would be released
annually from this facility? Even worse is the
fact that some of the other NC asphalt companies
given permits by NCDENR estimated that they have
zero air emissions from their operations without
emission controls.
We
fully support NCDHHS’s request to NCDENR
dated 2/28/03 for updated and accurate computer
modeling of hydrogen sulfide for Associated
Asphalt’s Salisbury operation. The true
releases are closer to 4 pounds per hour than the
4 pounds per year reflected in the earlier report
submitted to the EMC. The new NCDENR modeling
should include best estimates of both worst case
uncontrolled hydrogen sulfide emissions and
current charcoal filter controlled emissions from
the same plant. Ideally, the new modeling would
also include the significant hydrogen sulfide
emissions from the adjacent APAC hot mix asphalt
plant, which affects the same residential area,
and the significant fugitive emissions from both
facilities. Without accurate modeling, NCDHHS
cannot correctly estimate true health impacts
from hydrogen sulfide in the surrounding area.
The
required installation of relatively inexpensive
charcoal filters has significantly reduced
hydrogen sulfide emissions and improved quality
of life in the neighborhood of Milford Hills.
Property values and the tax base, which were also
significantly reduced by hydrogen sulfide
emissions and other toxic releases, hopefully
will rebound. These same relatively inexpensive
charcoal filters are also better controlling of
other carcinogens in the asphalt fumes (See
California’s Prop 65 and International
Agency for Research on Cancer). The nominal cost
of proper control of hydrogen sulfide is a
bargain for the citizens of the state. The costs
of controlling hydrogen sulfide pale in
comparison to the enormous health and property
costs borne by the nearby citizens and
governments. How many more NC residents and
workers need to struggle for breath, have asthma
attacks, get depressed, have cognitive problems,
suffer decreased quality of life, and at times
die from our outdated hydrogen sulfide air
standard?
We
will also ask Secretary Ross, Secretary Odom,
legislators, and Governor Easley to do everything
necessary to eliminate whatever roadblocks have
stopped the implementation of new air standards
for NC over the last twelve years. Twenty-six
pending new or revised health protective
Acceptable Ambient Level’s (AAL) developed
by NCDENR’s truly outstanding Scientific
Advisory Board await passage by the EMC. The EMC
passed only six of the recommended new health
protective AAL standards in twelve years.
Residents and workers across the state near
industrial sites like those in Salisbury eagerly
await passage by the EMC of the new significantly
reduced AAL for hydrogen sulfide, which offers
much greater protection for human health and
welfare than the present outdated standard that
is nearly 100 times higher.
Respectfully,
Richard Weisler
Richard
Weisler MD
Blue Ridge
Environmental Defense League
more info: Hydrogen sulfide
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