HomeMy WebLinkAboutMINUTES - 01212014 - D.1RECOMMENDATION(S):
1. OPEN the public hearing and take testimony on the Phillips 66 Propane Recovery Project.
2. CLOSE the public hearing.
3. CERTIFY the Final Environmental Impact Report (FEIR) dated November 2013, finding it to be adequate and
complete, finding that it has been prepared in compliance with the California Environmental Quality Act (CEQA) and
the State and County CEQA Guidelines, and finding that it reflects the County’s independent judgment and analysis,
and specify that the Department of Conservation and Development, Community Development Division (30 Muir
Road, Martinez, CA) is the custodian of the documents and other material which constitute the record of proceedings
upon which this decision is based.
4. CERTIFY that the Board has considered the contents of the FEIR prior to making a decision on the project.
5. DENY the appeals from Communities For A Better Environment and Shute, Mihaly & Weinberger and UPHOLD
the County Planning Commission’s decision to APPROVE the Land Use Permit (County File #LP12-2073) with the
attached conditions of approval.
APPROVE OTHER
RECOMMENDATION OF CNTY ADMINISTRATOR RECOMMENDATION OF BOARD COMMITTEE
Action of Board On: 01/21/2014 APPROVED AS RECOMMENDED OTHER
Clerks Notes:Hearing continued
VOTE OF SUPERVISORS
AYE:John Gioia, District I Supervisor
Candace Andersen, District II
Supervisor
Mary N. Piepho, District III
Supervisor
Karen Mitchoff, District IV
Supervisor
Federal D. Glover, District V
Supervisor
Contact: 925-674-7786
I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board
of Supervisors on the date shown.
ATTESTED: January 21, 2014
David Twa, County Administrator and Clerk of the Board of Supervisors
By: June McHuen, Deputy
cc:
D.1
To:Board of Supervisors
From:Catherine Kutsuris, Conservation and Development Director
Date:January 21, 2014
Contra
Costa
County
Subject:Hearing to Consider Two Appeals on the Phillips 66 Propane Recovery Project (County File #LP12-2073)
RECOMMENDATION(S): (CONT'D)
6. ADOPT the findings contained in County Planning Commission Resolution No. 19-2013, which includes the
CEQA findings, Growth Management Standards, and additional language to Land Use Permit findings, shown as
underlined text, as the basis for the Board’s actions.
7. ADOPT the Mitigation Monitoring and Reporting Program.
8. DIRECT the Community Development Division to post a Notice of Determination with the County Clerk.
FISCAL IMPACT:
None. The applicant, Phillips 66, is obligated to pay any additional costs above the initial application deposit
associated with the processing of the application.
BACKGROUND:
1. Timeline
The following timeline illustrates the land use permit application’s progress from submittal to present:
June 22, 2012 – Phillips 66 Company applied for approval of a Land Use Permit for the Propane Recovery
Project.
July 24, 2012 – Notice of Preparation of an EIR distributed.
August 20, 2012 – Scoping session held in Martinez.
June 10, 2013 – Draft EIR (DEIR) distributed for public review.
July 15, 2013 – Public hearing held before the Zoning Administrator in Martinez to accept comments on
DEIR.
July 23, 2013 – End of public review period for DEIR extended from July 25, 2013 to August 9, 2013.
August 9, 2013 – End of public review period for DEIR.
November 6, 2013 – FEIR distributed.
November 18, 2013 – Closed hearing held before the Zoning Administrator to consider the adequacy of the
FEIR. The Zoning Administrator recommended certification of the FEIR by the Planning Commission.
November 19, 2013 – Public hearing held before the Planning Commission in Martinez regarding the Land
Use Permit and the adequacy of the FEIR. The Commission determined that the FEIR was adequate and
approved the Land Use Permit.
November 25, 2013 – Appeal from Shute, Mihaly & Weinberger on behalf of the Rodeo Citizens
Association received by the Clerk of the Board.
December 2, 2013 – Appeal from Communities for a Better Environment received by the Community
Development Division.
2. County Planning Commission Hearing
The County Planning Commission opened the public hearing on the project on November 19, 2013. Oral
testimony covered a wide variety of topics such as, but not limited to, the adequacy of the FEIR, types and quality
of crude oil, propane safety concerns, pollution, public health, greenhouse gas emissions, Refinery safety,
Refinery/community relations. There were also several speakers who testified in support of the project.
During the November 19, 2013 hearing, after evaluating the project in its entirety, including all public testimony
and evidence in the record, the Commission voted unanimously to certify the FEIR and approved the land use
permit with the conditions of approval as recommended by staff.
3. Appeal Discussion
Following the decision of the Planning Commission, two separate appeals were filed by Communities for a Better
Environment, and Shute, Mihaly & Weinberger (on behalf of the Rodeo Citizens Association).
Both appellants submitted similar points of appeal. Chiefly, they claim that the EIR fails to include an adequate
project description that links the proposed project to a future “larger project” by the Refinery to begin importing
and processing heavier lower-quality crude oil feedstocks, such as Canadian tar sands, and that the proposed
project is in preparation to implement this objective. Since this is a common point of appeal for both Shute,
Mihaly & Weinberger (SMW) and Communities for a Better Environment (CBE), it is being addressed first.
Appeal Points and Staff Responses:
A. Future Plans to Change Crude Oil Feedstocks to Lead Into a Larger Project:
The main point both appellants have raised is that Phillips 66 plans to change the crude oil feedstock and begin
processing lower-quality heavy crudes, and with the lower-quality crudes Refinery operations could be changed to
increase the production of propane and butane far beyond current levels. Phillips 66 states that the project
objective is to recover existing volumes of propane and butane already being produced at the Refinery and already
contained in the Refinery Fuel Gas (RFG) streams and not to increase the amount of propane and butane being
produced at the Refinery beyond current levels. On the contrary, instead of burning the propane and butane in
Refinery process heaters, the project will allow the applicant to capture and sell more of the propane and butane
that is already being produced at the Refinery, irrespective of the types of oil feedstock.
The applicant proposes to recover for sale approximately 4,200 barrels per day of propane and 9,300 barrels per
day of butane already existent in the RFG. This is a practice already performed by other Bay Area refineries, and
Phillips 66 is planning to catch up with similar practice. Refinery flow data provided in the Phillips 66 Response to
Appeals (Exhibit #7) shows that from January to November of 2013, the Refinery feedstock that was processed
during that time produced an average of 14,250 barrels per day of propane and butane combined. Additionally,
Master Response 2.2, on page 2-2, of the FEIR addresses all comments which asserted that a relationship between
the Propane Recovery Project and purported plans to change the type of crude oil to be processed at the Refinery.
The appellants further claim that the EIR fails to adequately define the project because importing and processing
heavier lower-quality crude oil feedstock, such as Canadian tar sands, was not mentioned in the project
description. A change in crude feedstock was not mentioned in the project description or analyzed in the DEIR
and FEIR since no changes in feedstock or a switch in crude quality are proposed as a part of the project, nor is the
project dependent on any such changes. Specifically, SMW asserts on page 7 of their 11/18/13 Letter (Exhibit
#3b) that the project description is inadequate since it did not include mention of Phillips 66’s Santa Maria
Refinery, claiming that the Rodeo Refinery will “…increase butane and propane production, once the proper
amounts of the right feedstocks arrive…” from the Santa Maria Refinery. As discussed above, implementation of
the proposed project is not dependent upon new feedstock from Santa Maria or anywhere else, nor does the
project plan to “increase” production of butane and propane, but rather it will recover butane and propane already
existent in the Refinery gas streams under current operations. With this project objective in mind, a discussion of
the Santa Maria Refinery was not considered germane; nevertheless, on page 2-4 of the FEIR in Master Response
2.2, a discussion of the Santa Maria Refinery and its association with the Rodeo Refinery was provided.
The additional appeal issues raised by the appellants are responded to in Sections B, C, and D below. It should be
noted that most of the issues raised by SMW and CBE have already been addressed in the DEIR and FEIR. Staff
has summarized the appeal points below, and in addition, a more comprehensive response has been provided
which is identified as (Exhibit #6). In further attempting to respond to the appeals, Phillips 66 submitted a
response letter to the Board of Supervisors dated January 6, 2014 (See Exhibit #7).
B. Appeal by Shute, Mihaly & Weinberger (SMW) on behalf of the Rodeo Citizens Association
The appeal by SMW comprises the following points based on their November 22, 2013 appeal letter (Exhibit
#3a). Their appeal is also supported by referencing their November 18, 2013 letter to the Planning Commission
and a technical report by Phyllis Fox, Ph.D. (Fox Report), dated November 15, 2013 (see Exhibit #3b for both
documents). The issues raised by both the Fox Report and SMW have already been addressed in the DEIR and
FEIR. The SMW appeal letter’s primary points are summarized and briefly addressed below.
Summary of Appeal Points Raised by Shute, Mihaly & Weinberger and Staff Responses:
The EIR fails to adequately evaluate the significant impacts of the project, including but not limited to its
air quality, biological, safety, health, and climate impacts.
The EIR fails to evaluate cumulative impacts.
The EIR fails to evaluate mitigation measures and alternatives and the County failed to adopt adequate
mitigation or feasible alternatives.
The County failed to adequately respond to comments on the EIR.
The County failed to recirculate the EIR.
The County’s findings, including its statement of overriding considerations, are not supported by substantial
evidence.
The County cannot make the findings for approval required by its code sections; in particular, the County
cannot find that the Project will not be a detriment to public health, safety, or welfare or that it will not
cause a nuisance in the surrounding community.
The EIR fails to adequately define the project (see previous Staff response in Section A above).
Staff Response
EIR Fails to Provide Adequate Analysis of Environmental Impacts: SMW suggests that project impacts to air
quality, biological resources, safety, health, and climate should have been considered as potentially significant
and mitigated as well. Air quality was analyzed as a potentially significant impact and mitigation measures were
established for the project to address air-quality impacts during the short-term construction phase of the project
and also to mitigate long-term emissions of criteria air pollutants after project implementation (See Mitigation
Monitoring and Reporting Program [MMRP]—Exhibit #5). Project impacts were not determined to be significant
for biological resources, safety, health, or greenhouse gases; on the contrary, the analysis of the EIR determined
how the proposal to capture the propane and butane from the RFG would be beneficial by promoting the reduction
in sulfur dioxide, reduction in flaring events, and reduction in on-site greenhouse gas emissions.
EIR Fails to Include Analysis of Cumulative Impacts: Chapter 5 of the DEIR (page 5-2) provided comprehensive
analysis of the potential cumulative impacts in terms of past, present, and future projects both at the Refinery and
in the near region. Other projects at the Refinery and at other existing refineries in the County are likely to cause
impacts that are similar to those anticipated to result from the project. Other non-Refinery projects could also
cause similar potentially overlapping impacts with those of the project. Thirteen projects within an approximately
16-mile radius were evaluated as potential projects that could have cumulative effects in conjunction with the
proposed project. The Draft EIR provided sufficient and adequate cumulative analysis of cumulative impacts and
determined them to be less than significant.
EIR Fails to Evaluate Mitigation Measures and Project Alternatives : SMW claimed in their appeal that the County
failed to adopt adequate mitigation or feasible alternatives. The EIR determined that the proposed project would
result in potentially significant environmental impacts to air quality, cultural resources, noise, and transportation
and traffic. These impacts were evaluated in the DEIR and mitigation measures were proposed as needed that
would reduce each of these impacts to a less-than-significant level (See MMRP—Exhibit #5).
Chapter 6 of the DEIR considered alternatives to all components of the project. The alternatives to the project were
duly evaluated, but were found to be infeasible in that they would be inferior in terms of meeting the project
objectives and require more energy consumption for their implementation, and therefore were not considered
feasible to the project as proposed.
A no-project alternative was discussed on page 6-6 of the Draft EIR which, when compared to the project, would
not result in a decrease in GHG and sulfur emissions from the Refinery, as well as missing the opportunity to
decrease the number of flaring events at the Refinery. Although, implementation of a reduced project alternative
was determined to be the marginally environmentally superior alternative in the Draft EIR, it would not meet all of
the project objectives.
County Failed to Adequately Respond to Comments on the DEIR: The County received 48 comment letters on
the DEIR for the proposed project. In addition, oral comments were made by individuals who attended the
publicly noticed public hearing before the Zoning Administrator on July 15, 2013. There were also several
speakers who spoke in support of the project. The County has made its best good-faith effort to respond each
comment in a professional and scientific manner.
County Failed to Recirculate EIR: CEQA Guidelines Section 15088.5 requires a lead agency to recirculate an EIR
for further review and comment when significant new information is added to the EIR after public notice is given
of the availability of the DEIR but before certification of the FEIR. New information or data that “merely
clarifies” an EIR is not significant unless the EIR is changed in a way that deprives the public of a meaningful
opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to
mitigate or avoid such an effect that the project proponent declines to implement. Various minor changes and
edits were made to the mitigation measures, text, tables and figures of the DEIR, as described in the FEIR. The
flow data (see Exhibit #7) that was subsequently provided by the applicant clarifies and confirms the conclusions
of the DEIR. This information simply confirms and provides additional support for the conclusions of the DEIR
and further confirms that impacts will remain less than significant. Therefore, recirculation is not required.
Inadequacy of Project Findings:
a. CEQA Findings: In response to the SMW point that the County’s findings, including its statement of overriding
considerations, are not supported by substantial evidence, staff would point out that the EIR identifies potentially
significant environmental impacts that would occur if the project were implemented, and requires feasible
mitigation measures that would reduce all of the potentially significant impacts to less-than-significant levels (See
MMRP—Exhibit #5). The DEIR provides a comprehensive analysis of the project’s impacts, and cumulative
impacts of the project. Furthermore, the County Planning Commission adopted the findings, analysis, and
conclusions of the EIR and based its decision to adopt the document upon the evidence referenced in the EIR and
its appendices.
b. Land Use Permit Findings: SMW further states that the County cannot make the findings for approval required
by its own code sections for Land Use Permits; in particular, they claim that the County cannot find that the
project will not be a detriment to public health, safety or welfare, or that it will not cause a nuisance in the
surrounding community. Master Response 2.3 and 2.5 of the FEIR addresses onsite hazards in response to
concerns about the risk of accidents associated with the storage of propane and butane, and Master Response 2.6
addresses railroad transportation of propane and butane. The EIR thoroughly analyzed and considered all potential
hazards that present risks to the community; therefore, as proposed and conditioned, the project will not create a
nuisance and/or enforcement problem within the neighborhood or be detrimental to the health, safety and welfare
of the community.
C. Appeal by Communities for a Better Environment (CBE):
The appeal by CBE cites a variety of issues (see Exhibit #4a). The CBE appeal is primarily based on an “expert”
report by Greg Karras (see Exhibit #4c), an employee of CBE. Comprehensive responses to the Karras report
have already been provided in the FEIR beginning on page 3.2-117. CBE also submitted two letters opposing the
project to the Planning Commission on the day of the November 19, 2013 hearing (see Exhibits #4b & #4c).
Summary of Appeal Points Raised by CBE and Staff Responses:
The FEIR fails to adequately analyze significant environmental impacts.
The FEIR fails to adequately discuss mitigation measures.
The FEIR provides an inadequate discussion of Project alternatives.
The County failed to adequately notify the community of this project.
The project description fails to disclose that this Project is part of a larger project to enable the Refinery to
process lower-quality oil feedstock (see previous Staff response in Section A).
Staff Response:
EIR Fails to Provide Adequate Analysis of Environmental Impacts: CBE asserted that the FEIR failed to properly
address potential environmental impacts, such as explosion/fire risks, air pollution, and greenhouse-gas emissions
(GHG) resulting from the refining of a heavier lower-quality oil feedstock. CBE further states that, the FEIR
avoids any discussion of any impact associated with a switch in crude quality. Indeed, the DEIR and FEIR did not
analyze any impacts associated with a switch in crude quality, since a switch in crude quality, or the refining of
heavier lower-quality oil feedstock, is not an aspect of the proposed project, nor is the project dependent on any
such switch. CBE also claimed that the proposed project will have significant impacts on biological resources as a
result of continued use of the OTC or “once-through” cooling system. As proposed, the project includes a 25%
increase of OTC volume; however, the proposed 25% increase will not require any modifications or expansions to
the existing OTC system, and does not go beyond the Regional Water Quality Control Board’s (RWQCB) current
permit requirements for the Refinery. CBE also states that the RWQCB ordered the applicant to study replacing
the OTC system and FEIR denies the existence of the study. The FEIR does acknowledge the study (see FEIR
page 3.2-122, last paragraph). The RWQCB has reviewed the DEIR and no comments or objections to the project
have been received regarding the OTC system. Finally, the FEIR responds on page 3.2-122 that no fundamental
change to the Refinery cooling system is proposed as part of the project; therefore, it is outside of the scope of this
project to include discussion on OTC systems alternatives.
EIR Fails to Provide Adequate Mitigation Measures: CBE’s appeal letter states that the FEIR fails to adequately
discuss mitigation measures relating to local and state regulations, the County Industrial Safety Ordinance, the
General Plan, and comments again in regards to the RWQCB requirements for the OTC system. The EIR
determined that the proposed project would result in potentially significant environmental impacts to air quality,
cultural resources, noise, and transportation and traffic. These impacts were identified and evaluated in the DEIR
and mitigation measures were proposed as needed that would reduce each of these impacts to a
less-than-significant level (See MMRP Exhibit #5). A more detailed response related to the Refinery's OTC
system and how it will be affected by the proposed project (including the response to the CBE's supplemental
letter, received on 1/7/2014) is found in the County response (See Exhibit #6).
County Failed to Provide Adequate Project Alternatives: As previously discussed in Section B, Chapter 6 of the
DEIR considered adequate alternatives to all components of the project as required under CEQA.
County Failed to Provide Adequate Notification: CBE also claims that the County failed to adequately notify the
community of this project . The project was noticed in compliance with the noticing requirements of CEQA and,
in addition, to the County’s noticing requirements in Section 26-2.2002 of the County Code. The notice of
completion and availability of the DEIR and the Planning Commission hearing were noticed to all property
owners and occupants within a 300-foot radius of the project parcels APN357-010-001 and APN357-300-005.
Copies of the DEIR and FEIR were available for public review at the Pleasant Hill and Rodeo public libraries and
at the District 5 supervisor’s office. Notices were also sent to all speakers and those who submitted comments at
the scoping session and the July 15, 2013 Zoning Administrator’s hearing on the DEIR. Notice was also given to
those individuals, agencies, and organizations that requested notice or expressed interest in the project. Notice of
the Commission hearing was published in the West County Times on November 8, 2013.
D. CBE December 12, 2013 Letter to Clerk of the Board: On December 12, 2013, CBE submitted a letter to the
Clerk of the Board (see Exhibit #4d) regarding the supposed change in crude oil feedstock. The letter references a
project being reviewed by the City of Pittsburg called the “WesPac Pittsburg Energy Infrastructure Project, Tar
Sands”. The letter describes WesPac as a crude oil transfer facility, and states that it may be a potential new
source of oil feedstock to the Rodeo Refinery. Staff has reviewed the letter and as stated above in Section A, the
Propane Recovery Project is not dependent on new feedstock from the WesPac facility or anywhere else because
it already produces enough propane and butane at the Refinery to achieve project objectives. Currently the WesPac
project is under CEQA review and a decision on this project has not been made. Since CBE’s assumption that the
proposed Propane Recovery Project and the WesPac are related was made out of speculation, and since the
County has determined that this matter is not germane to the proposed project, the County will refrain from further
commenting on this matter.
CONSEQUENCE OF NEGATIVE ACTION:
The Propane Recovery Project would not be constructed and the Refinery would not be able to recover and sell
The Propane Recovery Project would not be constructed and the Refinery would not be able to recover and sell
the existing propane and butane, and there would be a lost benefit to the community by missing an opportunity to
decrease the amount of GHG and sulfur emissions from the Refinery, as well as losing an opportunity to decrease
the number of flaring events at the Refinery.
CHILDREN'S IMPACT STATEMENT:
No Impact.
CLERK'S ADDENDUM
Speakers: Roger Lin, CBE (Appellant); Greg Karras, CBE (Appellant); Mark Hughes, Phillips 66 (Applicant);
Keith Howard, Phillips 66; Janet Pyegeorg, Rodeo Citizens Association (Appellant)(handout attached) ; Ethan
Buchner, Forest Ethics; Ed Tannenbaum, resident of Crockett (handout attached); Charlie Davidsen, resident
of Hercules; Dave King, resident of Concord; Dr. Henry Clark, West County Toxin Coalition; Joe Portoi,
resident of Vallejo; Richard Black, resident of Vacaville; John Spinola, resident of Crockett; Andres Soto,
CBE Richmond; George Smith, East Bay Leadership Council; Mira Sendan, resident of El Sobrante; Ernesto
Velasquez, resident of Oakland; Teagan Clive, resident of Rodeo (handouts attached); Nancy Rieser, resident
of Crockett (handout attached); Madelyn Morton, resident of Rodeo (handout attached); Carmen Gray,
resident of Rodeo (handout attached);Bill concannon, resident of Crockett; Bill Pinkham, resident of
Richmond;Nick Despota, resident of Richmond; J.C. Garrett, resident of Rodeo; Don Stock, resident of
Richmond; Jim Neu, resident of Martinez, Robert Bustos, resident of Pittsburg; Danielle Figere, resident of
Crockett;Chuck Cotton, resident of El Sobrante; Diane Bailey, Natural Resources Sefense Council; Jess
Dervin-Ackerman, Sierra Club; Ann Rikkelman, resident of Concord; Richard Roserts, resident of Pleasant
Hill; Marilyn Bardet, resident of Benicia; LaTasha Chillous, Phillips 66; David Sit, resident of Rodeo; Victor
Sanders, resident of Rodeo; Tim Carves, resident of Vacaville; Julian Harker, resident of Martinez; Mike
Miller, president of United Steel Workers Local 326. The Board CONTINUED the hearing to April 1, 2014 at
1:30 p.m.; and DIRECTED staff to report back with further information on issues and concerns raised today.
ATTACHMENTS
Exhibit #1 - CPC Resolution No. 19-2013
Exhibit #2 - Conditions of Approval Approved by CPC
Exhibit #3a - Appeal Letter 11/22/13 Shute Mihaley & Weinberger (SMW)
Exhibit #3b - SMW 11/18/13 Letter and Related Fox Report
Exhibit #4a - Appeal Letter 12/02/13 Communities for a Better Environment (CBE)
Exhibit #4b - CBE 11/19/13 Letter by Roger Lin
Exhibit #4c - CBE 11/19/13 Letter and Related Report by Greg Karras
Exhibit #4d - CBE 12/12/13 Letter Regarding WesPac Project
Exhibit #4e - CBE 01/07/14 Letter
Exhibit #5 - Mitigation Monitoring and Reporting Program
Exhibit #6 - County Response
Exhibit #7 - Phillips 66 Response to Appeals
Exhibit #8 - CPC 11/19/13 Staff Report
Exhibit #9 - Notification List
Exhibit #10 - Maps
Exhibit #11 - CBE 01/14/14 Letter
1
EXHIBIT # 6
DETAILED RESPONSE TO APPEAL POINTS RAISED BY
SHUTE MIHALY & WEINBERGER (SMW) AND COMMUNITIES FOR A BETTER
ENVIRONMENT (CBE)
Introduction:
As previously discussed, most of the appeal points raised by the appellants have already been
addressed in the Final EIR. Nonetheless, the County determined that some points raised in the
appeal letters required additional clarification. The new clarificat ion provided herein confirms
the analyses and conclusions performed in both Draft and Final EIR. The responses below are
the ones in which the County is providing additional clarification. See margins of Exhibits # 3
(SMW appeal documents) and Exhibit #4 (CBE appeal documents) for corresponding appeal
points.
SMW-8. The EIR is silent on carbon monoxide (CO) emissions from the entire Project.
Analysis of the Project-related CO emissions was not included in the EIR discussion of
impacts because the Bay Area Air Quality Management District (BAAQMD) CEQA
guidelines do not recommend the use of mass emission significance thresholds for
project-related CO emissions. This is the case because such emissions tend not to be a
concern in the Bay Area relative to regional air quality.
Nonetheless, emissions of CO estimated to be generated by the Project are disclosed in
Final EIR Appendix A, Air Quality and Greenhouse Gas Emissions Documentation. The
total Project-related CO emissions for the proposed boiler, increased locomotive trips,
and increased vehicle exhaust is estimated to be approximately 39 pounds per day (see
Final EIR Appendix A, Table 2, page 3). The potential for these Project -related emissions
to cause or contribute to a violation of a CO ambient air qu ality standard is extremely
low given that existing CO concentrations in the Project area, and the Bay Area Air Basin
as a whole, are many orders of magnitude lower than the State and federal ambient air
quality standards for CO (see DEIR Table 4.3-1).
It should be noted that the BAAQMD CEQA guidelines have identified screening levels to
identify potentially significant local CO emission concentrations at affected roadway
intersections. For the proposed Project, the applicable screening level for potential
significant local CO concentrations at affected intersections is an increase in trips at an
intersection that experiences more than 44,000 vehicles per hour. Existing traffic at
2
Project area intersections are less than 900 trips per hour and Project -related
construction and operational trips would total up to 384 trips per the peak hour and 8
trips per day, respectively (see DEIR Figure 4.17-2 and DEIR Section 4.17.5). Therefore,
there would be no potential for the Project to result in CO concentrations at affected
roadways that would result in a significant impact.
SMW-10. The EIR fails to include criteria pollutant emissions from burning propane/butane.
As a general rule, “[a] project applicant has traditionally been expected to only address
emissions that are closely related and within the capacity of the project to control
and/or influence.”1 With respect to the proposed Project, it is unclear where, how, or by
whom the propane/butane produced by the Project might be used. Butane may be used
as an additive in chemical manufacturing, which does not involve combustion. Further
uncertainty exists relative to the baseline concerning the locations, quantities, and types
of fuel that might be replaced by the propane/butane that would be sold by Phillips 66
and whether such production could have the potential to affect the overall consumption
of propane/butane or the use or non -use of another fuel for which butane or propane
may be substituted. These issues are not within the capacity or control of the Project or
of the County and are too speculative for inclusion in the EIR analysis.
SMW-12: The EIR’s Analysis of the Project’s Potential to Impact Public Health is Flawed.
Sections 4.3 and 4.9 of the DEIR, provide the general discussion of both air emissions
and hazards related to toxic air contaminates (TACs). Sensitive receptors are described
in Section 4.3.2.4 of the DEIR as follows:
“The Bayo Vista community contains the nearest sensitive receptors to the active area of the
Refinery (e.g., schools, day care centers, libraries). The closest such sensitive receptor is a day
care center, located approximately 2,000 feet south of the Refinery. The closest residences in the
Bayo Vista neighborhood to the south are approximately 2,300 feet away from the Refinery fuel
gas processing unit and approximately 4,000 feet from the proposed propane storage area and
propane/butane loading rack.”
This information was summarized from information contained in the Public He alth
Supplement (December, 2012) available as part of the cited public administrative record
for the EIR. Figure 3 of that supplement provided a figure showing the exact locations of
sensitive receptors considered for the Health Risk Assessment for the pro ject. For the
purposes of the EIR analysis, summaries of information contained this supplement
provide more than adequate disclosure of the underling analysis in the EIR.
1 California Air Pollution Control Officers Association, "CEQA & Climate Change – Evaluating and Addressing
Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act,” pg. 50 (January
2008).
3
Furthermore, there is no need to provide any discussion on the condition of these
nearby sensitive receptors for the purposes of the CEQA analysis as this is part of the
existing baseline conditions present in the area. The EIR does describe the impact of the
proposed Project on these receptors as is required by CEQA.
The appellants imply that the area surrounding the Refinery is already considered an
‘impacted community’ per BAAQMD guidelines. Examination of the documents that the
appellants cite reveals that this is not the case for the Rodeo area. The BAAQMD
guidelines cited by the appellants indicated that the Richmond/San Pablo area is an
impacted community and the Rodeo (Selby and Crockett) area is not listed nor mapped
as impacted.
In a letter dated January 6, 2014, from Phillips, TAC data from stations nearby the
Project area is presented in response to the appellants concerns (See Table 1 and 2 in
Phillips66 Exhibit B). These data provides no new significant information and reveal no
new environmental impact from the proposed Project. Impact 4.3-3, DEIR page 4.3-22
incudes analysis of how the project will have a less than significant impact on TAC
emissions.
Additionally, as discussed in the DEIR, the proposed project will remove sulfur from the
RFG, which will result in decreased SO2 emission from combustion of the RFG in refinery
heaters and boilers. In regards to the Steam Power Plant, this plant is equipped with
selected catalytic reduction (SCR) for nitrogen oxide (NOX) control. The NOX emission
estimates reported to the BAAQMD are accurate and the emissions from this plant are
less than those of a new boiler. See discussion in DEIR, page 4.3-18 Impact 4.3-2.
SMW-13. The EIR provides no explanation as to why the Project would not result in any odorous
emissions.
The Project would add no new sources of odorous emissions, nor would it result in an
increase in any odor-causing compounds to the atmosphere, such as H2S, SO2, or
ammonia relative to baseline conditions. Therefore, there would be no change from
existing conditions at the Refinery relative to odors. As stated in the DEIR, Section 4.3.4,
the proposed Project represents an odor improvement over current conditions, since
sulfur compounds would be removed from the RFG stream. Therefore, there would be
no odor impacts associated with the Project.
SMW-19: The EIR Fails to Adequately Analyze the Project’s Impacts Related to Geologic Hazards.
As described in Section 4.7.2.3 of the DEIR and Section 2.5 of the FEIR, the mere
presence of liquefiable soils and/or seismic hazards does not preclude safe construction
4
of critical improvements. These adverse site conditions can easily be overcome by
appropriate engineering design, correct site preparation, and proper construction. The
DEIR states that each of the proposed Project components will receive a site -specific
geotechnical investigation as required by Law. The investigations and resultant
recommendations made by a state licensed geotechnical engineer would include design
parameters to mitigate potential effects of liquefaction, which would be approved by
the County Department of Conservation and Development, Building Inspection Division
in accordance with the most recent version of the California Building Code.
Construction would be in accordance with objective standards and performance criteria
embodied in the regulatory codes.
SMW-22: The EIR Contains an Inadequate Description of the Project Area’s Existing Biological
Resources.
The appellant asserts that the EIR fails to accurately portray the site’s underlying
environmental conditions, despite also providing page references from the EIR
indicating where these conditions are described. The appellant continues that the
Project site and vicinity contain several types of wetlands, including northern coastal salt
marsh, coastal brackish marsh, and coastal and valley freshwater marsh; that a number
of species depend on these habitats, including salt marsh harvest mouse, California
clapper rail, and black rail; the Project site drains into San Pablo Bay, which supports
diverse marine biota including several federally threatened species. As the appellant
admits with page references included in the comment, t he EIR does identify and
describe all of these habitats types and special-status species in Section 4.4, Biological
Resources pages 4.4-2 through 4.4-18.
The appellant asserts that the EIR relies on insufficient biological surveys that are
outdated or entirely absent, that a review of high-resolution satellite imagery in 2013 to
augment surveys performed in 1993, 2003, and 2006 is insufficient to identify species
occurrences, and the United State Fish and Wildlife Service (USFWS) list of species
clearly indicates that surveys should be performed for the species and habitats within
the project area. Beginning on page 4.4-2, the EIR identifies the habitats present in the
Refinery Complex Vicinity (RCV), the Refinery Complex (RC), and the Proposed Project
Area (PA), and the species potentially present in these habitats. The EIR appropriately
reduces the scope of the discussion to the habitats and species that could be directly
and indirectly impacted by the Project. With all terrestrial impacts occurring within
developed areas of the Refinery, the EIR adequately relies on a variety of information
including past surveys, a review of the California Natural Diversity Database (CNDDB)
and high-resolution satellite imagery, to confirm the habitats present and infer the
5
potential for encountering any particular species. Additional terrestrial surveys would
not contribute to an improved understanding of the biological resources present and/or
the project’s potential impacts on these resources because the project area (PA) is
already developed by industrial facilities and secondary (e.g., noise and visual
disturbance impacts) would not significantly increase baseline disturbance levels and
may not extend beyond the industrial area. A Phase II aquatic study further evaluating
the impact of the thermal plume on aquatic life was underway at the time of the EIR and
was not available for review or discussion during the EIR process. The 2006 Tenera
Environmental Study demonstrated that the submerged c ylindrical wedgewire screens
installed on the once-through cooling water intake structure complied with
requirements to reduce impingement and entrainment of aquatic organisms and
estimated that the configuration significantly reduced entrainment of larval fishes and
virtually eliminated impingement of adult fishes. The increase in intake volume under
the proposed project is within the operating parameters of the once-through cooling
system that was sufficiently proven in the 2006 study; thus, no additional study on the
wedgewire system was necessary.
The appellant misapplies the language provided by the USFWS in their species list (DEIR
Appendix B); all species on the list were considered in the EIR analysis, and those with
potential to occur in the Project area are described in Table 4.4 -1 and, where
appropriate, discussed in the Impacts section of the DEIR.
SMW-23: The EIR Fails to Adequately Analyze the Project’s Impacts on Biological Resources.
The appellant asserts that the EIR fails to analyze impacts to sensitive species that it
acknowledges may be present in habitat areas described in the EIR (specifically salt
marsh harvest mouse, California clapper rail, and black rail), and further states that the
EIR erroneously dismisses impacts to these species based on the Refinery’s baseline
disturbance levels. The EIR correctly measures impacts against the Refinery’s baseline
disturbance levels consistent with CEQA Guidelines Section 15125, which states that the
physical environmental conditions in the vicinity of the project, as they exist at the time
the notice of preparation is published, will normally constitute the baseline physical
conditions by which a lead agency determines whether an impact is significant. As
stated in the response to SMW-22, above, the DEIR in Section 4.4, Biological Resources,
pages 4.4-2 through 4.4-18, identifies the habitats present in the Refinery Complex
Vicinity (RCV), the Refinery Complex (RC), and the proposed Project Area (PA); identifies
the species potentially present in these habitats; and appropriately reduces the scope of
the impact discussion to the habitats and species that could be directly and indirectly
impacted by the Project. In the impact discussion s beginning on page 4.4-25, the DEIR
6
analyzes potential impacts to salt marsh harvest mouse, California clapper rail, and black
rail, among other species, and finds that impacts would be less than significant based on
the environmental baseline and distance from potentially sensitive habitats : the Project
would not significantly increase the Refinery’s baseline disturbance levels, and
potentially sensitive habitats are spatially separated from the PA by existing Refinery
operational structures and features.
The appellant erroneously asserts that the EIR does not analyze impacts to sensitive fish
species. Species are identified in Section 4.4, Biological Resources, in Table 4.4-1, and
potential impacts are discussed on page 4.4-27 in Impact 4.4-2: Special-status fishes
could be adversely impacted by an increase in once-through intake water piped in from
San Pablo Bay to use as coolant in the Refinery processes and Impact 4.4-3: Special-
status fishes could be adversely impacted by an increase in effluent temperature. The
DEIR in Section 4.4, Biological Resources, pages 4.4-27 through 4.4-28, and the FEIR in
Section 3.2, Response to Organization Comments, pages 3.2-121 through 3.2-123,
discuss the baseline and future Project conditions relative to once-through cooling and
effluent temperatures and, while referring to maximum thresholds allowed in the
Project-specific National Pollutant Discharge Elimination System (NPDES) permit,
identify that thresholds in the NPDES permit are based on several plans and scientific
studies including the Water Quality Control Plan for Control of Temperature in the
Coastal and Interstate Water and Enclosed Bays and Estuaries of California; Policy for
Implementation of Toxics Standards for Inland Surface Waters, Enclosed Bays, and
Estuaries of California; Policy for Compliance Schedules in National Pollutant Discharge
Elimination System Permits; and the project-specific studies Cooling Water Discharge
Thermal Plume Study (Tenera Environmental, 2007) and Technology Installation and
Operation Plan (Tenera Environmental, 2006 in RWQCB, 2011). These plans serve to
guide activities in San Francisco Bay and protect aquatic species from unsafe
temperatures and other environmental conditions; the project-specific studies do the
same for the Refinery environment. The finding of no significant impact to special-status
fishes (page 4.4-27) incorporates the existing baseline intake volumes and effluent
temperatures relative to the changes under the proposed project and relative to
thresholds identified in the plans and studies upon which the project-specific NPDES
thresholds are based (e.g., upon the Tenera 2007 Cooling Water Discharge Thermal
Plume Study, which concluded that thermal plume effects would be of a minor nature
due to their being a surface phenomena that dissipates rapidly in the nearshore area of
the discharge and the study’s documentation of natural solar heating of nearby tidal
flats that produce natural thermal plumes that significant ly exceed temperatures of the
ConocoPhillips thermal plume). The finding is further based on existing or proposed
design features that avoid and minimize impacts, such as use of a wedgewire screen
7
configuration and low through-screen velocity that virtually eliminates impingement of
adult and juvenile fishes and significantly reduces the entrainment of larval fishes and
use of sufficient cooling water to lower effluent temperatures.
The appellant states that CEQA mandates a finding of significance for any impacts that
“restrict[s] the range of an endangered, rare, or threatened species” and continues to
reference various case law and CEQA guidelines. Nowhere does the appellant suggest
how the proposed Project would restrict the range of an endangered, rare, or
threatened species or what species is/are being referred to. The EIR does not make
findings regarding whether the proposed Project would restrict the range of an
endangered, rare, or threatened species because this is not a potential outcome of the
Project.
SMW-23: The EIR Fails to Analyze Cumulative Impacts to Biological Resources.
The appellant states that the EIR fails to disclose the extent and quality of biological
resources that historically occurred in the Project area, or the amount of resources
already lost in the region, and fails to evaluate the cumulative impacts of this Project
and other projects on this habitat and the listed species that use it. As described in the
response to SMW-22, the EIR identifies the habitats present in the Refinery Complex
Vicinity (RCV), the Refinery Complex (RC), and the proposed Project Area (PA), and the
species potentially present in these habitats. The EIR appropriately reduces the scope of
the discussion to the habitats and species that could be directly and indirectly impacted
by the Project. The impact discussion is thus limited to a discussion of pot ential indirect
impacts (e.g. noise and visual disturbances) on marsh birds and nesting birds, and
potential direct impacts on fishes.
The cumulative impact discussion considers the Project’s potential for “cumulatively
considerable” impacts on fishes in San Pablo Bay and, following the guidance of CEQA
Section 15130 (b) to follow standards of practicality and reasonableness in the
cumulative analysis, finds the Project’s incremental contribution to once-through
cooling volume and thermal plume temperature is not cumulatively considerable. This is
because the project’s anticipated increases in thermal plume temperature and once -
through cooling volume are within the operational parameters of the existing Refinery,
very localized, and considered less than significant (DEIR at pages 4.4-23, 4.4-27, 4.4-28,
and 5-9; FEIR at pages 3.2-137 and 3.2-138). The Bay is a highly regulated environment
where individual and cumulative project impacts on water quality are carefully
monitored, as described on Page 5-9 of the DEIR. The San Francisco Bay Basin (Region 2)
Water Quality Control Plan (Basin Plan) is the Regional Water Board’s master water
quality control planning document, designating beneficial uses and water quality
8
objectives for the Bay and providing a definit ive program of actions designed to
preserve and enhance water quality and to protect beneficial uses for the maximum
benefit to the people of California. These water quality objectives are, in fact, controls
on cumulative effects to water quality from all sources, natural and man-made.
Industrial wastewater point source discharges are regulated through the NPDES
program, and the management approach includes a Strategic Plan and Watershed
Management Initiative that finds integrated solutions through the expertise and
authority of multiple agencies and organizations, and measures success through
monitoring and other data collection. The NPDES program includes project oversight by
agencies such as the National Marine Fisheries Service and California Department of Fish
and Wildlife with specific interest in protecting fisheries resources and direct input into
NPDES permit conditions. As stated on Page 5-10 of the DEIR, permit maximums are
based on scientific studies and data collected by the RWQCB and other re gulatory and
research agencies. As long as the individual permit maximums of projects in the Bay,
which themselves take into account the potential cumulative effects of each point
source discharge, are not breached, it follows that cumulatively considerable impacts
are not likely to occur.
SMW-24: 2. The EIR Fails to Adequately Analyze the Project’s Cumulative Environmental Impacts From
Other Refining-Related Projects.
The appellants assert that the EIR fails to analyze adequately cumulative impacts. Section
5.4.2 of the DEIR provides Table 5-1 which states all cumulative Bay Area refinery projects
known to the authors of the DEIR prior to publication in June of 2013. Since that time, a
number of other projects involving refineries and rail have been announced. Given that
the baseline date for the proposed Project as defined by the publication of the Notice of
Preparation for the EIR (July 2012) was well before this, the DEIR authors conducted their
cumulative analysis according to CEQA (as further discussed in response B4 -22 in the FEIR)
requirements with the best list then available of potential cumulative projects.
The appellants assert that this analysis should have considered cumulative rail traffic
within California. This was not possible as the destination of the project’s rail ca rs is not
knowable and could be anywhere. It would have been speculative to have done so and
contrary to CEQA section 15145.
The thread that appellants are following is indicated by the statement that “Each of the
Bay Area refineries have either recently permitted projects or have pending permits that
will facilitate transporting and refining tar sands crude.” This expands on their claim of a
“larger project” for the Propane Recovery Project, in order to link all projects and
refineries in an overall action that requires a cumulative analysis, regardless of whether it
9
is warranted under CEQA. The appellants then assert that comments by another
organization (NRDC) about another refinery project, a proposed project at the Valero
Benicia Refinery, support the appellants unsupportable claims and conclusions about a
“larger project”. Since the appellants’ only physical evidence in support of their “larger
project” claim is not true, their claim for the “larger project” is also unsupportable. The
County cannot provide a response to these general and unsupportable assertions.
Finally, as is discussed in detail in Section 5.4.3 of the DEIR, the proposed Project was
analyzed for its potential to have a cumulative considerable impact on all appropriate
CEQA categorical areas. In many cases the proposed Project had no project-related
impacts and when considered with other projects described in Section 5.4.2, after
analysis, no cumulative considerable impacts were found as well. The appellants do not
suggest otherwise but simply assert that the analysis was inadequate.
CBE-11: Significant Biological Resource Impacts due to OTC system.
The appellant states that the Regional Water Quality Control Board (RWQCB) has ordered
the Project proponent to study replacing the once through cooling (OTC) system, that the
study is referenced and attached to Citizens for a Better Environment’s (CBE’s) comments
on the DEIR, and that the FEIR denies the existence of the study. As a condition in the
NPDES permit for existing Refinery operations, the RWQCB required that ConocoPhillips
conduct a study evaluating the feasibility of replacing the existing OTC technology. The
FEIR does not deny the existence of the study (page 3.2-122, last paragraph). On pages
3.2-137 and 3.2-138, the FEIR responds to Karras Comments 31, 32, and 33, by informing
that the Cooling Tower Replacement Feasibility Evaluation required under the current
NPDES permit was not finalized at the time of the FEIR and therefore the findings were
not available for review; as such, any discussion or analysis of the feasibility evaluation
would be speculative and thus outside the scope of the DEIR. Additionally, the FEIR
responds on page 3.2-122 that no fundamental change to the Refinery cooling system,
such as conversion from the existing OTC system to a closed-loop cooling system, is
proposed as part of the Project; therefore, it is beyond the scope of the DEIR to explore
the advantages and disadvantages of alternate cooling systems.
CBE-17: The County Failed to Adequately Notify the Community of this Project.
In advance of the November 19, 2013 Public Hearing on certification of the proposed
Projects’ EIR, the County on November 6, 2013, performed the following steps to
properly notice the hearing in accordance with CEQA gu idelines:
1) The project noticed all property owners and occupants within 300 feet of the project
parcels (357-010-001 and 357-300-005).
10
2) The project noticed all speakers from the scoping session.
3) The project noticed all required public agencies and those that requested to be noticed
(e.g. City of Martinez).
4) The project noticed all people and organizations who expressed interest in the project
and requested to be noticed.
5) The project was noticed in the West County Times.
6) Hard copies of the FEIR were sent to those people, organizations, and agencies who
commented on the DEIR. A hard copy was also available for public review at the district
supervisor’s office and the Rodeo and Pleasant Hill public libraries.
7) Copies of the staff report were also mailed to various people, agencies, and
organizations.
Furthermore, there is no known CEQA requirement to notice parties who might be
subject to ‘taking’ or decreased property values as suggested by the appellant. In fact
such action might be considered speculative as well. The County properly noticed the
public hearing per CEQA requirements.
F-21. The EIR did not include criteria pollutant and GHG emissions relative to electricity use .
Electrical power would be supplied to the proposed Project from Pacific Gas and El ectric
Company (PG&E)’s existing regional power grid. It is generally not possible to determine
the exact generation source(s) of electricity on the power grid that would supply the
proposed project, or whether or not the electricity would even be generate d within the
Bay Area Air Basin. Since analysis of criteria pollutants is dependent on the air basin of
the Project-related sources, indirect emissions of criteria pollutants associated with
electricity use from the regional power grid are not addressed in the air quality analysis.
GHG emissions associated with use of electricity from the existing power grid are
generally addressed independent of air basin due to the global nature of the effects of
GHG emissions. Refer to the Indirect Emissions from Increased Electrical Demand on
DEIR page 4.8-17 for a discussion of electricity-related GHG emissions and emission
factors that would be associated with the proposed Project.
F-25: Cumulative Air Quality Impact Analysis is Inadequate
As mentioned in response SMW-24, the baseline date (July 2012) for the proposed
Project predates both the projects mentioned by the appellant (Santa Maria and
Ferndale Refineries). The Santa Maria Refinery’s relationship to the proposed Project was
discussed in detail in Section 2.2 of the FEIR as was a discussion of the relationship of
refinery feedstocks to the proposed Project. The Ferndale Refinery project is in another
state (Washington) and its status is outside what would be considered by CEQA. Whether
11
the Phillips refinery could or could not receive crude oils or other feedstocks from the
Ferndale refinery by marine vessel merely represents an existing, baseline condition that
would not be altered by the proposed project.
Response to CBE Supplemental Evidence- Letter received January 7, 2014
The appellant claims the EIR’s baseline level for once-through, non-contact saltwater
flow volume is erroneous and underestimates the percent increase of the proposed
project, and as a result underestimates the severity of potential project impacts related
to the discharge of this water. It should be noted that the appellant’s Chart S-1 is not Phillips
66’s submission to the Regional Water Quality Control Board (RWQCB). Rather, it is appellant’s
depiction of the data. With respect to plates B, C and D in particular, the comparisons will vary
considerably depending upon the factors selected, including, for example, the averaging period.
The data submitted by Phillips 66 for 2013 are consistent with the range of flow volumes in
recent years, and confirm that the baseline used in the EIR is reasonable.
Once-through, non-contact flow at the refinery is affected by many factors, including process
rates, turnaround cycle, and maintenance activities, among others. The EIR used average daily
flow volumes for one year (second half of 2011 and first half of 2012) to best represent
current conditions of operations at the facility in order to analyze potential impacts from
the proposed changes with the project. In accordance with CEQA requirements, “an EIR
must include a description of the physical environmental conditions in the vicinity of the
project, as they exist at the time the notice of preparation is published.” (Article 9
Section 15125). Reviewing the data provided by the appellant which includes data from
2013 that was not available at the time of preparation of the DEIR, shows relatively
similar average flow volumes compared to 2012 (44.76 for 2012 and 43.26 for 2013)
further supporting the appropriate use of the 2012 data as baseline conditions. Further,
in reviewing the data from the years 2010 through 2013 provided by the appellant, there
is no clear correlation between average flow volumes and temperature of discharge.
Comparing 2010 data to 2012 shows an approximate increase of 20% in flow and yet the
highest recorded monthly average temperature2 for the year only increases by 1.2%
while the average for the year actually decreases by 0.6%. Regardless, despite
fluctuations in flow volumes of once-through, non-contact saltwater for process cooling,
the Refinery has a history of compliance with the effluent permit limitations including
temperature.
The EIR has disclosed on page 3-27 and on page 4.4-27 of the DEIR that the Project would
result in an increase of once-through cooling volume to approximately 40,000 gallons per
minute from an existing 31,500 gallons per minute. A flow of 31,500 gallons per minute is
the equivalent of 45.4 million gallons per day which compares well with the data
provided by the appellant showing an average daily flow of 44.6 million gallons per day.
2 The NPDES effluent permit limitation for temperature is based on the monthly average of daily measure d
temperatures.
12
The magnitude of the flow increase has been conveyed to the reader in anot her
meaningful way by describing the change as a 25% increase in flow volume from an
existing baseline level of 31,500 gallons per minute. However, it should be noted that the
analysis does not rely solely on this percent increase. The increase in flow vol ume by
8,500 gallons per minute as proposed by the Project would be accommodated by the
existing five pumps and would continue to operate within the National Pollutant
Discharge Elimination System (NPDES) permit thresholds determined by the Regional
Water Quality Control Board (RWQCB). As described in the DEIR (page 4.4-27) and in the
County’s Response to Appeal Comment SMW-23, permit thresholds are based on various
studies including the project-specific study by Tenera (2006) regarding use of wedgewire
screens and maximum intake flows. The appellant provides no information to support
the claim that the proposed Project’s increase in once-through cooling volume to 40,000
gallons per minute would result in significant impacts on special-status fishes.
Therefore, based on the appropriate use of 2012 monitoring data as representative of
existing baseline conditions for the Refinery for the EIR and the lack of data supporting a
direct correlation between increases in flow volumes and an inability to meet water
quality permit requirements which are protective of receiving waters and habitat, the EIR
has adequately characterized the potential impacts of the proposed Project.
1904 Franklin Street, Suite 600 • Oakland, CA 94612 • T (510) 302-0430 • F (510) 302-0437
In Southern California: 6325 Pacific Blvd., Suite 300 • Huntington Park, CA 90255 • (323) 826-9771
BY ELECTRONIC MAIL(Please confirm receipt to roger@cbecal.org)
14 January 2014
Clerk of the BoardContra Costa County Board of Supervisors651 Pine Street, Room 106Martinez, CA 94553
Attention: Tiffany Lennear (Tiffany.Lennear@cob.cccounty.us)
Appeal of Environmental Impact Report and Land Use Permit Filed 2 Dec 2013:
Phillips 66 Company Propane Recovery Project, Environmental Impact Report (EIR) and Land Use Permit, EIR SCH #2012072046, County File LP12-2073;
Communities for a Better Environment (CBE) Supplemental Evidence–C
Dear Clerk of the Board,
In support of our appeal, CBE respectfully submits Rodeo facility fuel gas propane and butane (LPG) content and fuel gas flow data. This evidence is appended hereto as Attachment 4.
The proposed project would recover propane and additional butane produced from crude oil in amounts that could boost this refinery’s LPG yield to exceed 11 volume % on its crude oil feed.1 Average monthly West Coast refinery LPG yields reported since 1993 never exceeded 4.1 vol. % on crude.2 Feedstock and products are key process variables that are fundamentally interrelated. Thus, changing LPG production changes oil feedstock processing. CBE and the Rodeo Citizens Association (RCA) showed that the project would require increased LPG production, requiring a change in feedstock, and related proposals would enable such new, and likely lower quality, oil feeds, such as tar sands oils.1 Refining lower quality oil can worsen pollution and safety hazards substantially.1 The Governor’s Office of Planning and Research (OPR),3 and the Refinery Action Collaborative, which includes, among others, the Labor Occupational Health Program at U.C. Berkeley and the refinery workers’ union United Steelworkers,4 have joined CBE and RCA in asking that the EIR disclose and analyze potential changes in oil feedstock and resultant impacts.
1 See CBE and RCA expert reports: Karras Report dated 4 Sep 2013; Fox Report dated 15 Nov 2013.
2 PADD 5 Refinery Yield; www.eia.gov/dnav/pet/pet_pnp_pct_dc_r50_pct_m.htm. Download 13 Jan 2013. This 4.1% maximum may be an overestimate: it may include other liquefied gases (e.g., ethane, ethylene).
3 See CBE Supplemental Evidence–A, submitted on 12 Dec 2013.
4 Refinery Action Collaborative letter of 18 Dec 2013, appended hereto as Attachment 5.
14 January 2014CBE Appeal Supplemental Evidence–C (SCH#2012072046; LP12-2073)Page Two
The EIR admits it “did not address changes in crude oil use”5 and argues against this disclosure, asserting that the proposed change in LPG has no relationship to any change in oil feedstock. Specifically, the EIR asserts that the project “would not change, enlarge, or otherwise impact”
the refinery’s oil feedstock5 because, it asserts:
(1) “the actual amount of propane and butane available for recovery (determined using mea-sured flow data and lab analysis of propane and butane content) is approximately 4,200 bpd [barrels per day, or b/d] of propane and 9,300 bpd of butane”5 so that;
(2) the 4,200 b/d of propane6 and 3,800 b/d of additional butane6 the project design would re-cover from refinery fuel gas “do not represent any anticipated increase in LPG production.”5
Despite its explicit reliance on “measured flow data and lab analysis of propane and butane content” for this claimed amount of LPG recoverable in the baseline, no such data is included anywhere in the EIR.7 Therefore, the data in Attachment 4 are relevant to environmental review of this project.
The Rodeo Fuel Gas LPG Data
Phillips 66 submitted a “Refinery Fuel Gas Speciation Profile” and “Daily U233 Fuel Gas Data” in attachments A-4 and A-7 to its air permits application for this project.8 These data are given in Attachment 4. The Speciation Profile reports the propane and butane9 content, mass fractions, and molecular weight (MW) of fuel gas from analysis of samples taken at the Unit 233 fuel gas mix drum, described as the mix drum for the fuel gas system. Propane and butane concentrations ranged by 10% and 17%, respectively, in three samples taken during August 2011. Phillips’ At-tachment A-7 reports daily Unit 233 fuel gas flow from Jan 2009–Nov 2012. In the most recent three-year baseline period reported (Dec 2009–Nov 2012) this fuel gas flow averaged ≈29.83 million standard cubic feet per day (MMSCFD) with a 90th Percentile flow of 35.21 MMSCFD.
Phillips asserted that these data are representative of the refinery baseline for project review.10 Table S-1 summarizes these baseline data.
5 FEIR at 3.2-130 [explanation added]: As used in the EIR, “bpd” refers to barrels per day (b/d).
6 Project design reported by the EIR. See DEIR at 3-23; see also DEIR at 3-21 (Table 3-2).
7 The EIR’s failure to disclose these purported baseline data is improper. See also Fox Report at 5.
8 Rodeo Propane Recovery Project BAAQMD Authority to Construct and Significant Revision to Major Facility Review Permit Application, February 2013. Previously submitted attached to Karras Report.
9 Butane, herein, is the sum of n-butane and isobutane, each of which is reported in Attachment A-4.
10 Indeed, this refinery baseline is asserted explicitly (“Refinery fuel gas [RFG] volume and total sulfur content for the baseline period were provided in the original permit application”) (emphasis added) on page 3 of Phillips’ 28 June 2013 response to the Air Quality Management District’s 21 May 2013 Incom-plete Letter (included in the Karras Report “Air Permit Correspondence” Attachment). Phillips’ statement must refer to air permit app. attachments A-4 and A-7 as no other refinery fuel gas data were included in the application or its attachments. Thus, these are the only data available at this time that represent the “measured flow data and lab analysis of propane and butane content” the EIR purports to rely upon, and Phillips asserted that these data are representative of the project baseline. CBE submits these data on this basis, however, more data are required for full environmental review. For example, other, undisclosed, and new streams containing LPG could be routed to recovery, such as streams from the refinery’s Santa Maria Facility (see Fox Report), and Phillips reports analysis of only three samples for LPG in fuel gas.
14 January 2014CBE Appeal Supplemental Evidence–C (SCH#2012072046; LP12-2073)Page Three
LPG Baseline Errors
As estimated from Phillips’ data, the baseline Rodeo facility fuel gas contains an average of ≈2,290 b/d of propane and ≈1,880 b/d of butane. See Table S-1. Even at the 90th Percentile (conditions existing only 10% of the time) it contains only ≈2,700 b/d of propane and 2,220 b/d of butane. These amounts are smaller than the “4,200 bpd of propane and 9,300 bpd of butane” baseline asserted by the EIR. Thus, Phillips’ data show that the EIR overestimates the project LPG baseline. Therefore, the EIR’s unsupported LPG baseline is contradicted by available data that the EIR has failed to disclose.
LPG Production and Feedstock Errors
Phillips data show that baseline refinery fuel gas does not contain enough LPG to implement the project goals. See Table S-1. Instead, LPG available from existing crude stocks would meet about half of the project’s goals—54% of projected propane production and 49% of projected butane production. Therefore, the EIR’s unsupported assertion that the project goals “do not represent any anticipated increase in LPG production” is contradicted by available data that the EIR has failed to disclose.
At roughly half of project design (see Table S-1), LPG production would roughly double—on average—in order to implement the project as proposed. This substantial increase in production would require a change in the amount or composition of the feedstock or processing methods. Thus, the EIR’s unsupported claim that the project “would not change, enlarge, or otherwise impact” refinery oil feedstock is contradicted by Phillips’ own data, which the EIR has failed to disclose. Changing refinery oil feedstock has known potential to worsen air pollution and safety
Table S-1. Baseline LPG in Rodeo Facility Fuel Gas, December 2009–November 2012a
Units Average 90th Percentile
U233 fuel gas flow (MMSCFD)29.83 35.21
(million lbs/day)1.71 2.02
Propane in fuel gas (lb/lb fuel gas)0.2381 0.2381
(million lbs/day)0.407 0.481
(barrels/day)2,290 2,700
(% of project design)54%64%
Butane in fuel gas (lb/lb fuel gas)0.2230 0.2230
(million lbs/day)0.381 0.450
(barrels/day)1,880 2,220
(% of project design)49%58%
(a) Project design: 4,200 b/d propane and 3,800 b/d butane; data from DEIR at 3-23. Compressed liquid
densities at 60 ºF: 178 lb/barrel propane and 203 lb/b butane; data from EPA’s AP 42 Appendix A. All other
data from Phillips 66 Air Permit Application attachments provided in Attachment 4 hereto. Conversions from
MMSCFD (1 atm., 60 ºF) to lbs/d based on fuel gas MW (21.75 lb/lb-mol), and on propane and butane mass
fractions (lb/lb fuel gas shown in table), from Attachment 4. Butane shown includes n-Butane and Isobutane.
14 January 2014CBE Appeal Supplemental Evidence–C (SCH#2012072046; LP12-2073)Page Four
hazards substantially. Therefore, the EIR’s admission that it “did not address changes in crude oil use” indicates a serious deficiency in the environmental review of this project.
Conclusion
CBE seeks an adequate environmental review that, among other things, resolves the EIR’s failure to include information on the sources, types, or quality of this refinery’s oil feedstock. Failing to include this information, the EIR fails to answer even the most straightforward ques-tions about whether tar sands oils could be a new feedstock, what changes in oil feedstock are anticipated, potential impacts of those changes, and how those impacts will be addressed. The EIR argues against this necessary environmental disclosure, inappropriately, and erroneously. Its claim that LPG production and oil feed changes are unrelated suffers from the logical fallacy that products are unrelated to feedstock, relies on unsupported conclusory statements, ignores related wharf, rail, and processing expansions that enable new feedstock, and—as documented further herein—is contradicted by substantial evidence that the project requires new feedstock. This new evidence further strongly supports CBE’s appeal.
Respectfully Submitted,
Roger Lin Greg KarrasStaff Attorney Senior Scientist
Attachments: CBE Supp. Attachment 4. Refinery Fuel Gas Speciation Profile and Daily U233 Fuel Gas Data, as submitted by Phillips 66 in attachments to its air permit application for the project
CBE Supp. Attachment 5. Refinery Action Collaborative letter of 18 Dec. 2013
Copy: Lashun Cross, Principal Planner, Department of Conservation and Development
Laurel L. Impett, AICP, Urban Planner, Shute, Mihaly & Weinberger LLP
Ken Alex, Director, Governor’s Office of Planning and Research
Jean Roggenkamp, Deputy Air Pollution Control Officer, BAAQMD
Refinery Action Collaborative, San Francisco Bay Area
Interested Organizations and Individuals
CBE Supplemental Attachment 4
Refinery Fuel Gas Speciation Profile and
Daily U233 Fuel Gas Data, as submitted
by Phillips 66 in attachments to its Air
Permit Application for the Project*
Contents
Part 1: Refinery Fuel Gas Speciation Profile
Permit App. Attachment A-4 excerpt
(5 pages)
Part 2: Daily U233 Fuel Gas Data
Permit App. Attachment A-7
(22 pages)
* Rodeo Propane Recovery Project BAAQMD Authority to
Construct and Significant Revision to Major Facility Review
Permit Application, February 2013.
Previously submitted attached to 4 Sep 2013 Karras Report.
Refinery Fuel Gas Speciation Profile
Fuel Gas Data
Instruction:
General source
description, e.g., mix
drum for X,Y,Z units; mix
drum for fuel gas system
1; etc.
Assign a
unique ID for
each test
report
Enter start date
Field:Process Throughput or Production Rate
Facility ID
Number
Fuel gas mix
drum ID General Description Test Report
ID
Test Date
(mm/dd/yyyy)Run Number
Actual
Fuel Gas Flow Rate
(acfm)
Standard
Fuel Gas Flow
Rate
(scfm)
Dry Standard
Fuel Gas Flow
Rate
(dscfm)
Production
comment
CA5A0280 Unit 233 mix drum for fuel gas
system 11045.2 08/15/2011 Run 1 3,826.83 20,011.19 19,811.08
CA5A0280 Unit 233 mix drum for fuel gas
system 11045.2 08/17/2011 Run 2 3,747.39 20,394.04 20,210.49
CA5A0280 Unit 233 mix drum for fuel gas
system 11045.2 08/17/2011 Run 3 4,036.96 21,014.92 20,783.76
Molecular Wt 21.75 (per Brent's email)
Mass Fraction
Molecular Weight of RFG
Form Approved 03/28/2011
OMB Control No. 2060-0657
Approval Expires 03/31/2014
Enter the fuel gas flow rate or usage rates from measurement data,
company records, or engineering analyses. Use 1 atm and 60°F as
standard conditions.
Refinery Fuel Gas Speciation Profil
Fuel Gas Data
Instruction:
Field:
Facility ID
Number
CA5A0280
CA5A0280
CA5A0280
Molecular Wt
Mass Fraction
Molecular W
Form Approved 03/28/2011
OMB Control No. 2060-0657
Approval Expires 03/31/2014
CAS No. >>1333-74-0 630-08-0 124-38-9 7727-37-9 7782-44-7
HHV (Btu/scf)Moisture Content
(vol%)
Hydrogen
(vol%, dry basis)
Carbon monoxide
(vol%, dry basis)
Carbon dioxide
(vol%, dry basis)
Nitrogen
(vol%, dry basis)
Oxygen
(vol%, dry basis)
1323.33 1.00 29.44 0.43 0.11 2.03 0.43
1335.42 0.90 29.49 0.44 0.11 2.39 0.44
1320.85 1.10 29.44 0.43 0.11 2.03 0.43
18.0153 2.014 28.01 44.01 28.0134 32
0.008282897 0.027274137 0.005531228 0.002225793 0.027678106 0.006319147
Enter the fuel gas higher heating value (HHV) content and general composition data
Refinery Fuel Gas Speciation Profil
Fuel Gas Data
Instruction:
Field:
Facility ID
Number
CA5A0280
CA5A0280
CA5A0280
Molecular Wt
Mass Fraction
Molecular W
Form Approved 03/28/2011
OMB Control No. 2060-0657
Approval Expires 03/31/2014
Assume all TRS is H2S
CAS No. >>7783-06-4 463-58-1 75-15-0 74-82-8 74-84-0 74-85-1 74-86-2 74-98-6 115-07-1 463-49-0 106-97-8 75-28-5
TRS
(ppmvd)
Hydrogen
sulfide
(ppmvd)
Carbonyl
sulfide
(ppmvd)
Carbon
disulfide
(ppmvd)
Methane
(ppmvd)Ethane (ppmvd)Ethylene
(ppmvd)
Acetylene
(ppmvd)
Propane
(ppmvd)
Propylene
(ppmvd)
Propadiene
(ppmvd)
n-Butane
(ppmvd)
Isobutane
(ppmvd)
505.56 8.370 29.50 0.344 285,832.00 115,500.66 6,783.18 0.53 113,270.53 13,323.18 0.53 50,774.64 35,532.76
571.99 12.300 30.60 0.459 275,316.91 113,347.86 6,775.19 0.54 114,580.81 13,684.23 0.54 54,365.84 34,297.09
551.55 18.300 32.70 0.359 278,916.27 123,708.52 6,628.30 0.54 124,396.66 12,803.23 0.54 47,143.31 28,321.31
34.0809 34.0809 60.07 76.139 16.04 30.07 28.05 26.04 44.1 42.08 40.065 58.12 58.12
0.0009 0.0000 0.0001 0.00000136 0.2065 0.1625 0.0087 0.0000 0.2381 0.0257 0.0000 0.1356 0.0874
Enter the sulfur compound composition data
Refinery Fuel Gas Speciation Profil
Fuel Gas Data
Instruction:
Field:
Facility ID
Number
CA5A0280
CA5A0280
CA5A0280
Molecular Wt
Mass Fraction
Molecular W
Form Approved 03/28/2011
OMB Control No. 2060-0657
Approval Expires 03/31/2014
106-98-9 107-01-7 115-11-7 590-19-2 106-99-0 109-66-0 78-78-4 287-92-3 109-67-1 627-20-3 646-04-8 563-46-2 563-45-1 513-35-9
1-Butene
(ppmvd)
2-Butene
(ppmvd)
Isobutene
(ppmvd)
1,2-Butadiene
(ppmvd)
1,3-Butadiene
(ppmvd)
n-Pentane
(ppmvd)
2-
Methylbutane
(ppmvd)
Cyclopentane
(ppmvd)
1-Pentene
(ppmvd)
Cis-2-pentene
(ppmvd)
Trans-2-
pentene
(ppmvd)
2-Methyl-1-
butene
(ppmvd)
3-Methyl-1-
butene
(ppmvd)
2-Methyl-2-
butene
(ppmvd)
3,845.93 3,281.74 4,959.40 0.53 90.87 6,159.25 8,323.26 603.66 840.43 239.12 487.41 603.66 364.76 700.72
4,218.99 3,561.71 4,991.62 0.54 92.39 7,002.63 9,746.00 685.57 958.71 277.82 562.60 694.28 414.61 810.72
3,651.76 3,012.08 3,904.83 0.54 88.31 5,850.78 7,771.96 579.37 813.06 253.07 479.22 581.52 358.61 685.98
56.106 56.106 56.106 54.091 54.091 72.15 72.15 70.1 70.13 70.13 70.13 70.13 70.13 70.13
0.0101 0.0085 0.0119 0.0000 0.0002 0.0210 0.0286 0.0020 0.0028 0.0008 0.0016 0.0020 0.0012 0.0024
Enter the organic compound composition data
Refinery Fuel Gas Speciation Profil
Fuel Gas Data
Instruction:
Field:
Facility ID
Number
CA5A0280
CA5A0280
CA5A0280
Molecular Wt
Mass Fraction
Molecular W
Form Approved 03/28/2011
OMB Control No. 2060-0657
Approval Expires 03/31/2014
Assume n-Hexane
142-29-0 591-95-7 1574-41-0 2004-70-8 591-93-5 591-96-8 598-25-4 78-79-5 542-92-7 71-43-2 110-54-3
Cylcopentene
(ppmvd)
1,2-
Pentadiene
(ppmvd)
1-cis-3-
Pentadiene
(ppmvd)
1-trans-3-
Pentadiene
(ppmvd)
1,4-
Pentadiene
(ppmvd)
2,3-Pentadiene
(ppmvd)
3-Methyl-1,2-
butadiene
(ppmvd)
2-Methyl-1,3-
butadiene
(ppmvd)
Cyclopentadie
ne (ppmvd)
Benzene
(ppmvd)
other C6+
(ppmvd)
121.48 19.09 159.13 40.64 6.29 N/A 10.24 26.66 N/A 257.25 12,947.76
138.75 23.61 170.52 46.90 7.73 N/A 11.64 31.45 N/A 292.29 14,456.86
130.41 21.54 178.12 43.18 6.57 N/A 11.42 28.32 N/A 283.22 13,355.67
68.12 68.12 68.12 68.12 68.12 68.12 68.12 68.12 66.10114 78.11 86.18
0.0004 0.0001 0.0005 0.0001 0.0000 0.0000 0.0000 0.0001 0.0000 0.000997 0.0538
Attachment A-7
Daily U233 Fuel Gas Data
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
1/1/2009 36,424 272.3 1,648
1/2/2009 35,533 270.2 1,595
1/3/2009 36,013 313.1 1,873
1/4/2009 35,013 324.2 1,885
1/5/2009 35,133 310.4 1,811
1/6/2009 35,162 302.3 1,766
1/7/2009 36,438 282.3 1,708
1/8/2009 36,114 305.3 1,831
1/9/2009 35,737 283.6 1,684
1/10/2009 35,381 321.8 1,891
1/11/2009 34,445 302.8 1,733
1/12/2009 33,907 304.3 1,714
1/13/2009 34,348 306.1 1,747
1/14/2009 35,624 317.0 1,876
1/15/2009 36,061 283.7 1,700
1/16/2009 36,715 261.2 1,593
1/17/2009 36,823 272.5 1,667
1/18/2009 32,963 380.5 2,083
1/19/2009 32,132 370.0 1,975
1/20/2009 33,395 296.5 1,645
1/21/2009 32,368 304.8 1,639
1/22/2009 32,765 309.8 1,686
1/23/2009 33,833 327.0 1,838
1/24/2009 35,622 280.8 1,662
1/25/2009 36,994 256.1 1,574
1/26/2009 35,268 284.0 1,664
1/27/2009 34,667 340.9 1,963
1/28/2009 34,025 326.5 1,846
1/29/2009 33,793 313.0 1,757
1/30/2009 33,527 321.3 1,789
1/31/2009 33,817 335.6 1,885
2/1/2009 33,276 333.8 1,845
2/2/2009 32,918 352.5 1,928
2/3/2009 31,799 386.6 2,042
2/4/2009 30,532 428.0 2,171
2/5/2009 31,341 383.3 1,996
2/6/2009 31,541 298.4 1,563
2/7/2009 32,050 308.2 1,641
2/8/2009 32,440 304.5 1,641
2/9/2009 32,521 359.9 1,944
2/10/2009 32,485 320.8 1,731
2/11/2009 31,750 342.8 1,808
2/12/2009 33,553 358.9 2,000
2/13/2009 34,433 313.9 1,795
2/14/2009 33,545 355.5 1,981
2/15/2009 33,810 333.3 1,872
2/16/2009 34,462 324.9 1,860
2/17/2009 35,806 283.9 1,688
2/18/2009 35,297 260.9 1,530
2/19/2009 36,933 284.1 1,743
2/20/2009 37,503 335.7 2,091
2/21/2009 38,282 359.3 2,285
2/22/2009 39,774 297.3 1,964
2/23/2009 39,470 269.6 1,768
2/24/2009 36,443 276.8 1,675
2/25/2009 33,406 287.0 1,592
2/26/2009 33,616 278.4 1,554
2/27/2009 36,151 197.1 1,184
2/28/2009 33,562 280.2 1,562
3/1/2009 36,386 277.3 1,676
3/2/2009 33,550 277.4 1,546
3/3/2009 32,106 249.6 1,331
3/4/2009 32,612 246.1 1,333
3/5/2009 32,071 317.9 1,693
3/6/2009 29,664 301.0 1,483
3/7/2009 28,452 296.3 1,400
3/8/2009 28,035 258.3 1,203
3/9/2009 28,322 258.0 1,214
DATE
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
3/10/2009 29,279 310.8 1,511
3/11/2009 28,637 325.5 1,548
3/12/2009 28,622 287.9 1,369
3/13/2009 27,867 265.8 1,230
3/14/2009 27,652 291.3 1,338
3/15/2009 26,924 344.9 1,543
3/16/2009 25,347 380.1 1,600
3/17/2009 25,090 350.1 1,459
3/18/2009 26,214 365.7 1,592
3/19/2009 26,574 378.6 1,671
3/20/2009 25,970 403.9 1,742
3/21/2009 25,400 334.0 1,409
3/22/2009 26,028 305.1 1,319
3/23/2009 25,555 365.7 1,552
3/24/2009 25,896 327.2 1,408
3/25/2009 24,863 344.3 1,422
3/26/2009 25,724 352.6 1,506
3/27/2009 25,650 351.8 1,499
3/28/2009 25,654 347.8 1,482
3/29/2009 25,181 371.0 1,552
3/30/2009 24,548 409.9 1,671
3/31/2009 25,261 389.1 1,633
4/1/2009 24,889 408.6 1,689
4/2/2009 24,239 418.7 1,686
4/3/2009 23,935 380.7 1,514
4/4/2009 22,849 373.0 1,416
4/5/2009 23,040 404.5 1,548
4/6/2009 22,314 447.3 1,658
4/7/2009 23,849 432.7 1,714
4/8/2009 25,886 321.9 1,384
4/9/2009 26,817 329.8 1,469
4/10/2009 27,214 337.0 1,523
4/11/2009 27,201 344.3 1,556
4/12/2009 26,937 322.8 1,444
4/13/2009 27,465 329.9 1,505
4/14/2009 29,098 332.9 1,609
4/15/2009 30,389 317.2 1,601
4/16/2009 30,427 332.5 1,680
4/17/2009 30,920 325.0 1,669
4/18/2009 31,696 320.6 1,688
4/19/2009 34,618 308.2 1,772
4/20/2009 30,953 239.8 1,233
4/21/2009 25,738 25.1 107
4/22/2009 26,210 31.3 136
4/23/2009 27,990 24.5 114
4/24/2009 28,929 23.0 111
4/25/2009 28,605 23.4 111
4/26/2009 28,615 23.0 109
4/27/2009 28,963 22.1 107
4/28/2009 29,078 23.4 113
4/29/2009 28,169 20.4 95
4/30/2009 26,032 24.9 108
5/1/2009 26,005 26.9 116
5/2/2009 26,146 25.0 108
5/3/2009 27,733 102.5 472
5/4/2009 29,291 419.0 2,039
5/5/2009 30,456 547.3 2,769
5/6/2009 29,237 548.1 2,662
5/7/2009 29,067 538.0 2,598
5/8/2009 28,600 448.5 2,131
5/9/2009 30,062 463.3 2,314
5/10/2009 25,634 490.8 2,090
5/11/2009 27,591 481.5 2,207
5/12/2009 26,859 562.7 2,510
5/13/2009 26,997 566.7 2,541
5/14/2009 27,631 543.0 2,492
5/15/2009 28,233 563.9 2,645
5/16/2009 28,660 556.5 2,649
5/17/2009 28,370 561.3 2,645
5/18/2009 29,479 545.0 2,669
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
5/19/2009 28,778 522.0 2,495
5/20/2009 27,056 559.4 2,514
5/21/2009 27,554 529.5 2,424
5/22/2009 28,606 514.3 2,444
5/23/2009 27,414 527.2 2,401
5/24/2009 30,695 499.3 2,546
5/25/2009 32,257 488.2 2,616
5/26/2009 34,029 474.1 2,680
5/27/2009 33,326 477.2 2,641
5/28/2009 33,917 417.4 2,352
5/29/2009 33,488 437.3 2,432
5/30/2009 33,606 458.2 2,557
5/31/2009 33,958 446.9 2,521
6/1/2009 33,970 515.4 2,908
6/2/2009 34,419 444.8 2,543
6/3/2009 33,144 451.6 2,486
6/4/2009 31,957 434.0 2,304
6/5/2009 32,053 445.8 2,374
6/6/2009 31,981 447.1 2,375
6/7/2009 32,338 469.7 2,523
6/8/2009 32,311 486.6 2,611
6/9/2009 32,663 479.4 2,601
6/10/2009 32,185 498.1 2,663
6/11/2009 31,583 516.2 2,708
6/12/2009 31,758 484.1 2,553
6/13/2009 30,058 420.2 2,098
6/14/2009 30,315 474.9 2,391
6/15/2009 30,711 495.9 2,530
6/16/2009 31,386 506.3 2,640
6/17/2009 31,745 451.0 2,378
6/18/2009 31,702 492.8 2,595
6/19/2009 31,487 453.5 2,372
6/20/2009 32,321 478.6 2,569
6/21/2009 31,827 443.1 2,343
6/22/2009 31,517 535.4 2,803
6/23/2009 31,485 501.4 2,622
6/24/2009 32,223 486.7 2,605
6/25/2009 32,568 378.9 2,050
6/26/2009 32,315 394.5 2,117
6/27/2009 31,861 461.9 2,445
6/28/2009 32,386 402.1 2,163
6/29/2009 32,855 401.0 2,188
6/30/2009 32,476 441.2 2,380
7/1/2009 31,446 473.2 2,472
7/2/2009 31,976 465.6 2,473
7/3/2009 33,195 448.4 2,472
7/4/2009 33,548 355.9 1,983
7/5/2009 34,016 430.0 2,429
7/6/2009 33,448 386.8 2,149
7/7/2009 33,007 415.9 2,280
7/8/2009 33,215 392.2 2,164
7/9/2009 32,826 466.3 2,543
7/10/2009 32,683 420.2 2,281
7/11/2009 32,666 459.1 2,491
7/12/2009 31,153 354.5 1,835
7/13/2009 31,633 337.4 1,773
7/14/2009 31,668 489.4 2,574
7/15/2009 32,957 469.9 2,572
7/16/2009 33,305 429.6 2,377
7/17/2009 32,920 396.0 2,165
7/18/2009 32,771 410.9 2,237
7/19/2009 32,815 428.4 2,335
7/20/2009 33,403 406.5 2,255
7/21/2009 33,458 418.1 2,324
7/22/2009 33,279 372.0 2,056
7/23/2009 33,703 402.7 2,254
7/24/2009 33,484 422.1 2,348
7/25/2009 33,204 422.0 2,327
7/26/2009 32,967 452.0 2,475
7/27/2009 33,032 434.0 2,381
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
7/28/2009 32,942 471.8 2,582
7/29/2009 33,234 446.5 2,465
7/30/2009 32,999 464.2 2,544
7/31/2009 33,131 462.7 2,546
8/1/2009 33,199 484.7 2,673
8/2/2009 33,572 495.3 2,762
8/3/2009 33,847 476.2 2,677
8/4/2009 33,676 464.7 2,599
8/5/2009 33,495 488.4 2,717
8/6/2009 32,588 493.4 2,671
8/7/2009 31,314 522.1 2,716
8/8/2009 31,954 470.9 2,499
8/9/2009 32,187 510.6 2,730
8/10/2009 31,452 520.4 2,719
8/11/2009 32,112 407.7 2,174
8/12/2009 31,111 536.6 2,773
8/13/2009 31,689 495.8 2,610
8/14/2009 32,452 424.3 2,287
8/15/2009 31,919 453.6 2,405
8/16/2009 31,823 470.1 2,485
8/17/2009 31,443 471.0 2,460
8/18/2009 31,928 431.6 2,289
8/19/2009 32,200 389.6 2,084
8/20/2009 32,267 412.1 2,209
8/21/2009 32,380 461.9 2,484
8/22/2009 33,915 473.7 2,669
8/23/2009 33,003 443.2 2,430
8/24/2009 33,471 451.9 2,512
8/25/2009 33,255 431.9 2,386
8/26/2009 33,468 458.5 2,549
8/27/2009 33,597 469.5 2,620
8/28/2009 32,898 486.0 2,656
8/29/2009 32,129 463.3 2,472
8/30/2009 33,061 445.3 2,445
8/31/2009 32,987 394.9 2,164
9/1/2009 33,036 467.6 2,566
9/2/2009 32,533 509.9 2,755
9/3/2009 33,174 484.7 2,671
9/4/2009 33,515 435.9 2,427
9/5/2009 33,484 476.1 2,648
9/6/2009 33,284 490.1 2,710
9/7/2009 33,175 457.5 2,521
9/8/2009 33,047 454.0 2,492
9/9/2009 34,239 398.8 2,268
9/10/2009 33,071 422.8 2,323
9/11/2009 34,130 465.6 2,640
9/12/2009 34,070 431.3 2,441
9/13/2009 33,824 352.8 1,982
9/14/2009 33,501 405.6 2,257
9/15/2009 33,158 349.3 1,924
9/16/2009 30,697 449.2 2,290
9/17/2009 29,823 441.0 2,185
9/18/2009 30,155 473.9 2,374
9/19/2009 30,843 432.8 2,217
9/20/2009 30,442 450.4 2,277
9/21/2009 31,131 446.9 2,311
9/22/2009 29,473 416.0 2,037
9/23/2009 31,038 379.1 1,955
9/24/2009 31,735 303.4 1,599
9/25/2009 30,369 322.0 1,624
9/26/2009 32,828 341.6 1,863
9/27/2009 32,196 216.6 1,158
9/28/2009 30,296 180.9 911
9/29/2009 30,946 178.7 918
9/30/2009 33,470 176.0 978
10/1/2009 30,715 220.3 1,124
10/2/2009 31,648 198.4 1,043
10/3/2009 28,276 226.9 1,066
10/4/2009 27,083 257.7 1,159
10/5/2009 26,405 276.3 1,212
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
10/6/2009 25,487 293.8 1,244
10/7/2009 25,154 324.0 1,354
10/8/2009 25,468 288.8 1,222
10/9/2009 26,672 337.1 1,493
10/10/2009 29,994 396.8 1,977
10/11/2009 32,823 386.5 2,107
10/12/2009 35,289 352.2 2,065
10/13/2009 39,336 337.3 2,204
10/14/2009 33,275 421.6 2,330
10/15/2009 33,069 412.6 2,267
10/16/2009 31,624 431.5 2,266
10/17/2009 32,299 460.6 2,471
10/18/2009 32,665 445.8 2,419
10/19/2009 31,912 371.4 1,969
10/20/2009 31,662 410.8 2,161
10/21/2009 32,380 389.8 2,097
10/22/2009 31,272 329.3 1,711
10/23/2009 30,108 393.4 1,967
10/24/2009 29,825 440.2 2,181
10/25/2009 31,214 447.9 2,322
10/26/2009 33,290 440.0 2,433
10/27/2009 33,726 361.5 2,025
10/28/2009 32,080 256.1 1,365
10/29/2009 32,920 356.9 1,952
10/30/2009 32,553 345.4 1,868
10/31/2009 32,702 329.2 1,788
11/1/2009 32,666 335.2 1,819
11/2/2009 32,667 340.0 1,845
11/3/2009 32,678 330.7 1,795
11/4/2009 32,480 325.5 1,756
11/5/2009 30,808 380.7 1,948
11/6/2009 30,508 382.7 1,939
11/7/2009 31,993 324.9 1,726
11/8/2009 32,559 341.8 1,849
11/9/2009 30,490 341.1 1,728
11/10/2009 31,270 349.6 1,816
11/11/2009 30,780 401.8 2,054
11/12/2009 30,241 421.4 2,117
11/13/2009 31,799 384.9 2,033
11/14/2009 31,750 378.6 1,996
11/15/2009 33,049 427.4 2,346
11/16/2009 37,205 332.4 2,054
11/17/2009 37,601 327.1 2,043
11/18/2009 37,957 323.2 2,038
11/19/2009 35,313 384.5 2,255
11/20/2009 37,038 366.5 2,255
11/21/2009 37,910 316.7 1,994
11/22/2009 37,458 340.2 2,117
11/23/2009 37,229 355.0 2,195
11/24/2009 36,782 359.8 2,198
11/25/2009 36,605 372.4 2,265
11/26/2009 36,202 361.5 2,174
11/27/2009 35,433 345.8 2,035
11/28/2009 35,411 347.9 2,046
11/29/2009 35,150 386.4 2,256
11/30/2009 35,182 395.1 2,309
12/1/2009 34,616 404.9 2,328
12/2/2009 35,065 382.5 2,228
12/3/2009 34,519 406.1 2,328
12/4/2009 34,618 395.1 2,272
12/5/2009 33,858 389.8 2,192
12/6/2009 35,588 346.3 2,047
12/7/2009 34,831 347.3 2,009
12/8/2009 29,690 41.3 203
12/9/2009 27,149 20.3 92
12/10/2009 27,278 15.7 71
12/11/2009 29,776 121.5 601
12/12/2009 31,754 330.5 1,743
12/13/2009 32,746 357.6 1,945
12/14/2009 32,219 356.9 1,910
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
12/15/2009 33,455 380.6 2,115
12/16/2009 31,960 398.8 2,117
12/17/2009 32,435 413.3 2,226
12/18/2009 33,637 374.6 2,093
12/19/2009 32,468 377.7 2,037
12/20/2009 32,270 372.4 1,996
12/21/2009 31,934 361.0 1,915
12/22/2009 32,744 393.1 2,138
12/23/2009 31,613 423.6 2,224
12/24/2009 31,238 430.2 2,232
12/25/2009 31,890 408.9 2,166
12/26/2009 31,439 386.3 2,017
12/27/2009 32,049 393.5 2,095
12/28/2009 31,554 431.5 2,261
12/29/2009 33,780 387.8 2,176
12/30/2009 36,698 375.7 2,290
12/31/2009 37,763 363.8 2,282
1/1/2010 36,887 414.9 2,542
1/2/2010 37,113 419.8 2,588
1/3/2010 38,316 381.5 2,428
1/4/2010 40,225 348.6 2,329
1/5/2010 39,453 369.0 2,418
1/6/2010 34,638 403.0 2,318
1/7/2010 33,459 379.5 2,109
1/8/2010 34,474 397.6 2,277
1/9/2010 31,163 407.3 2,108
1/10/2010 35,750 409.7 2,433
1/11/2010 36,557 408.6 2,481
1/12/2010 33,343 435.9 2,414
1/13/2010 33,316 374.2 2,071
1/14/2010 33,300 414.0 2,290
1/15/2010 32,374 453.8 2,440
1/16/2010 33,445 410.8 2,282
1/17/2010 32,050 409.5 2,180
1/18/2010 33,587 412.2 2,299
1/19/2010 36,122 386.6 2,319
1/20/2010 36,892 341.7 2,094
1/21/2010 31,429 409.9 2,140
1/22/2010 29,782 419.5 2,075
1/23/2010 31,180 420.5 2,178
1/24/2010 31,421 442.4 2,309
1/25/2010 32,400 372.0 2,002
1/26/2010 35,667 347.2 2,057
1/27/2010 35,146 400.8 2,340
1/28/2010 32,510 397.8 2,148
1/29/2010 34,802 418.2 2,417
1/30/2010 36,862 389.8 2,387
1/31/2010 37,542 407.6 2,542
2/1/2010 36,951 410.3 2,518
2/2/2010 36,742 318.5 1,944
2/3/2010 36,741 320.9 1,958
2/4/2010 37,005 373.2 2,294
2/5/2010 36,717 372.8 2,274
2/6/2010 35,910 400.0 2,386
2/7/2010 35,445 368.4 2,169
2/8/2010 33,620 396.2 2,212
2/9/2010 32,640 354.5 1,922
2/10/2010 33,886 424.8 2,391
2/11/2010 33,836 403.6 2,268
2/12/2010 33,682 472.5 2,644
2/13/2010 32,035 483.1 2,571
2/14/2010 29,406 471.8 2,304
2/15/2010 33,756 463.7 2,600
2/16/2010 36,494 408.3 2,475
2/17/2010 35,735 404.6 2,402
2/18/2010 35,018 387.5 2,254
2/19/2010 33,977 405.0 2,286
2/20/2010 34,058 405.2 2,292
2/21/2010 34,436 336.8 1,927
2/22/2010 34,915 392.7 2,277
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
2/23/2010 36,740 348.8 2,129
2/24/2010 32,389 412.5 2,219
2/25/2010 33,592 360.4 2,011
2/26/2010 33,601 347.3 1,938
2/27/2010 34,773 386.3 2,231
2/28/2010 35,176 363.8 2,125
3/1/2010 34,192 418.2 2,375
3/2/2010 35,124 407.8 2,379
3/3/2010 35,965 256.7 1,533
3/4/2010 35,912 386.9 2,308
3/5/2010 35,515 390.4 2,303
3/6/2010 35,548 362.9 2,143
3/7/2010 35,284 369.5 2,165
3/8/2010 30,401 337.4 1,704
3/9/2010 29,429 352.5 1,723
3/10/2010 28,342 374.7 1,764
3/11/2010 31,064 361.8 1,867
3/12/2010 36,289 248.1 1,495
3/13/2010 38,198 269.6 1,710
3/14/2010 35,845 267.3 1,592
3/15/2010 31,116 318.7 1,647
3/16/2010 32,475 405.1 2,185
3/17/2010 31,198 432.0 2,239
3/18/2010 32,916 416.3 2,276
3/19/2010 30,368 412.5 2,081
3/20/2010 32,857 394.7 2,154
3/21/2010 32,880 372.6 2,035
3/22/2010 30,875 396.6 2,034
3/23/2010 31,347 408.6 2,127
3/24/2010 33,551 370.4 2,064
3/25/2010 33,965 380.9 2,149
3/26/2010 33,947 407.1 2,295
3/27/2010 33,539 429.4 2,392
3/28/2010 33,433 381.3 2,117
3/29/2010 34,959 393.6 2,286
3/30/2010 36,188 330.3 1,985
3/31/2010 36,101 349.6 2,096
4/1/2010 36,028 392.9 2,352
4/2/2010 37,397 364.4 2,263
4/3/2010 38,113 352.5 2,232
4/4/2010 38,378 330.2 2,105
4/5/2010 36,590 327.7 1,992
4/6/2010 32,062 413.9 2,205
4/7/2010 31,369 450.7 2,348
4/8/2010 31,123 368.5 1,905
4/9/2010 31,089 482.3 2,491
4/10/2010 30,439 420.6 2,127
4/11/2010 31,050 381.3 1,967
4/12/2010 29,711 413.2 2,039
4/13/2010 30,979 434.5 2,236
4/14/2010 32,966 375.7 2,057
4/15/2010 31,723 432.5 2,279
4/16/2010 31,865 267.8 1,418
4/17/2010 33,258 498.2 2,752
4/18/2010 32,791 533.5 2,906
4/19/2010 32,571 460.9 2,494
4/20/2010 31,485 435.4 2,277
4/21/2010 31,940 421.2 2,235
4/22/2010 31,438 491.6 2,567
4/23/2010 31,989 486.0 2,583
4/24/2010 31,457 451.5 2,359
4/25/2010 31,702 453.1 2,386
4/26/2010 31,974 465.2 2,471
4/27/2010 31,093 427.5 2,208
4/28/2010 28,295 427.8 2,011
4/29/2010 27,683 452.8 2,082
4/30/2010 28,745 541.0 2,583
5/1/2010 29,604 514.9 2,532
5/2/2010 33,958 466.5 2,631
5/3/2010 33,255 467.7 2,584
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
5/4/2010 32,786 443.4 2,415
5/5/2010 31,936 398.8 2,115
5/6/2010 29,912 449.6 2,234
5/7/2010 31,785 437.8 2,311
5/8/2010 30,381 539.0 2,720
5/9/2010 31,585 521.3 2,735
5/10/2010 34,315 434.5 2,476
5/11/2010 36,256 447.3 2,694
5/12/2010 38,217 488.5 3,101
5/13/2010 37,482 446.4 2,779
5/14/2010 36,739 453.0 2,765
5/15/2010 36,426 519.0 3,140
5/16/2010 36,508 545.3 3,306
5/17/2010 35,446 501.9 2,955
5/18/2010 34,448 505.0 2,889
5/19/2010 36,805 458.8 2,805
5/20/2010 36,988 380.8 2,339
5/21/2010 36,589 407.5 2,477
5/22/2010 36,351 406.5 2,454
5/23/2010 35,767 400.4 2,379
5/24/2010 35,583 389.9 2,304
5/25/2010 34,983 430.4 2,501
5/26/2010 35,345 463.7 2,722
5/27/2010 36,378 416.0 2,514
5/28/2010 35,527 468.4 2,764
5/29/2010 34,545 524.2 3,008
5/30/2010 35,211 546.6 3,197
5/31/2010 35,637 541.6 3,206
6/1/2010 35,366 495.6 2,911
6/2/2010 35,226 424.8 2,486
6/3/2010 33,842 400.5 2,251
6/4/2010 33,305 409.6 2,266
6/5/2010 34,104 458.8 2,599
6/6/2010 34,493 524.6 3,005
6/7/2010 34,415 543.8 3,108
6/8/2010 34,429 487.4 2,787
6/9/2010 33,489 478.1 2,659
6/10/2010 33,605 498.4 2,782
6/11/2010 34,073 521.9 2,954
6/12/2010 33,784 561.9 3,153
6/13/2010 33,281 565.2 3,124
6/14/2010 33,093 484.3 2,662
6/15/2010 33,883 458.4 2,580
6/16/2010 32,592 463.8 2,511
6/17/2010 34,323 439.5 2,505
6/18/2010 35,575 382.5 2,260
6/19/2010 35,371 269.9 1,586
6/20/2010 35,836 433.3 2,579
6/21/2010 36,147 462.7 2,778
6/22/2010 34,559 457.4 2,626
6/23/2010 34,702 486.8 2,806
6/24/2010 35,249 483.8 2,832
6/25/2010 34,883 477.1 2,764
6/26/2010 34,480 429.7 2,461
6/27/2010 34,106 401.5 2,275
6/28/2010 33,062 273.3 1,501
6/29/2010 32,157 231.8 1,238
6/30/2010 27,206 249.9 1,129
7/1/2010 23,717 308.0 1,213
7/2/2010 27,067 291.4 1,310
7/3/2010 34,369 408.5 2,332
7/4/2010 35,103 469.2 2,736
7/5/2010 33,758 465.5 2,610
7/6/2010 34,412 464.2 2,653
7/7/2010 36,702 429.9 2,621
7/8/2010 35,451 449.2 2,645
7/9/2010 34,710 506.8 2,922
7/10/2010 37,634 508.6 3,179
7/11/2010 38,242 453.8 2,883
7/12/2010 38,524 434.6 2,781
7/13/2010 37,105 449.7 2,771
7/14/2010 36,010 422.0 2,524
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
7/15/2010 35,444 397.1 2,338
7/16/2010 36,168 493.9 2,967
7/17/2010 35,353 554.4 3,256
7/18/2010 36,236 388.9 2,341
7/19/2010 36,916 431.8 2,648
7/20/2010 33,646 396.5 2,216
7/21/2010 32,115 398.8 2,127
7/22/2010 36,843 438.7 2,685
7/23/2010 35,548 454.6 2,685
7/24/2010 34,454 442.3 2,531
7/25/2010 32,324 430.0 2,309
7/26/2010 34,412 456.0 2,606
7/27/2010 34,546 407.8 2,340
7/28/2010 32,921 505.4 2,764
7/29/2010 30,741 551.5 2,816
7/30/2010 30,378 578.9 2,921
7/31/2010 30,875 499.4 2,561
8/1/2010 31,421 512.8 2,677
8/2/2010 32,666 565.7 3,069
8/3/2010 33,373 579.7 3,213
8/4/2010 33,684 550.0 3,077
8/5/2010 35,529 526.2 3,106
8/6/2010 36,907 460.4 2,823
8/7/2010 36,855 391.1 2,394
8/8/2010 35,759 412.0 2,447
8/9/2010 35,988 448.0 2,678
8/10/2010 36,285 438.7 2,644
8/11/2010 35,117 461.6 2,692
8/12/2010 34,669 472.6 2,721
8/13/2010 34,865 437.1 2,532
8/14/2010 34,822 403.6 2,334
8/15/2010 34,678 417.7 2,406
8/16/2010 34,897 442.8 2,567
8/17/2010 35,627 359.9 2,130
8/18/2010 35,294 425.6 2,495
8/19/2010 34,871 460.8 2,669
8/20/2010 35,636 427.2 2,529
8/21/2010 35,601 414.6 2,452
8/22/2010 35,484 441.4 2,602
8/23/2010 33,761 436.5 2,448
8/24/2010 32,021 477.2 2,538
8/25/2010 31,853 518.4 2,743
8/26/2010 33,051 448.6 2,463
8/27/2010 32,144 432.8 2,311
8/28/2010 32,203 449.0 2,402
8/29/2010 31,718 456.8 2,407
8/30/2010 32,554 494.5 2,674
8/31/2010 34,563 498.2 2,860
9/1/2010 35,157 450.7 2,632
9/2/2010 35,124 486.6 2,839
9/3/2010 36,082 363.5 2,179
9/4/2010 36,093 395.5 2,371
9/5/2010 35,636 420.4 2,488
9/6/2010 34,926 401.6 2,330
9/7/2010 35,203 281.7 1,647
9/8/2010 37,427 365.8 2,274
9/9/2010 38,586 338.4 2,169
9/10/2010 36,181 365.5 2,197
9/11/2010 34,683 410.1 2,363
9/12/2010 35,766 405.7 2,410
9/13/2010 33,939 388.0 2,188
9/14/2010 31,847 427.9 2,264
9/15/2010 32,304 405.9 2,178
9/16/2010 32,576 425.7 2,304
9/17/2010 32,809 479.0 2,611
9/18/2010 32,809 481.6 2,625
9/19/2010 33,414 451.1 2,504
9/20/2010 34,479 413.9 2,370
9/21/2010 33,949 376.8 2,125
9/22/2010 32,292 398.9 2,140
9/23/2010 32,040 443.2 2,359
9/24/2010 33,125 434.5 2,391
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
9/25/2010 32,672 432.0 2,344
9/26/2010 31,018 472.7 2,435
9/27/2010 31,366 491.0 2,558
9/28/2010 30,403 517.2 2,612
9/29/2010 30,588 434.9 2,210
9/30/2010 33,051 395.7 2,172
10/1/2010 32,720 418.5 2,274
10/2/2010 32,287 466.1 2,499
10/3/2010 31,483 419.4 2,193
10/4/2010 31,261 393.6 2,044
10/5/2010 30,368 469.9 2,370
10/6/2010 30,451 435.6 2,203
10/7/2010 28,546 400.5 1,899
10/8/2010 27,746 384.1 1,770
10/9/2010 31,114 308.2 1,593
10/10/2010 29,770 447.4 2,212
10/11/2010 29,272 457.0 2,222
10/12/2010 29,318 515.7 2,512
10/13/2010 30,307 421.1 2,120
10/14/2010 29,652 475.0 2,340
10/15/2010 30,179 417.1 2,091
10/16/2010 30,009 389.4 1,941
10/17/2010 30,756 388.3 1,984
10/18/2010 31,111 368.0 1,901
10/19/2010 31,142 391.4 2,025
10/20/2010 31,815 364.2 1,925
10/21/2010 32,220 339.4 1,816
10/22/2010 12,785 190.2 404
10/23/2010 9,082 43.8 66
10/24/2010 16,917 54.5 153
10/25/2010 22,740 115.5 436
10/26/2010 24,632 389.3 1,593
10/27/2010 22,132 452.1 1,662
10/28/2010 24,311 464.3 1,875
10/29/2010 26,682 363.9 1,613
10/30/2010 29,166 355.6 1,723
10/31/2010 27,253 431.8 1,954
11/1/2010 26,477 405.9 1,785
11/2/2010 25,935 395.2 1,703
11/3/2010 25,503 375.7 1,592
11/4/2010 24,985 373.9 1,552
11/5/2010 25,714 323.1 1,380
11/6/2010 28,460 309.0 1,461
11/7/2010 29,745 340.3 1,681
11/8/2010 30,151 349.6 1,751
11/9/2010 30,609 333.1 1,694
11/10/2010 31,075 263.6 1,360
11/11/2010 30,586 367.2 1,865
11/12/2010 30,035 341.1 1,702
11/13/2010 30,818 353.0 1,807
11/14/2010 30,465 397.3 2,010
11/15/2010 29,380 356.6 1,740
11/16/2010 29,690 397.2 1,959
11/17/2010 31,578 329.3 1,727
11/18/2010 32,986 269.9 1,479
11/19/2010 32,582 272.8 1,476
11/20/2010 31,174 300.5 1,556
11/21/2010 28,322 301.4 1,418
11/22/2010 29,334 271.7 1,324
11/23/2010 33,640 269.9 1,508
11/24/2010 34,882 347.2 2,012
11/25/2010 32,870 324.9 1,774
11/26/2010 32,201 325.4 1,741
11/27/2010 31,755 330.8 1,745
11/28/2010 32,096 307.2 1,638
11/29/2010 32,139 308.4 1,646
11/30/2010 30,773 304.5 1,557
12/1/2010 31,353 327.3 1,705
12/2/2010 32,247 316.8 1,697
12/3/2010 33,523 321.1 1,788
12/4/2010 33,503 353.6 1,968
12/5/2010 33,382 385.2 2,136
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
12/6/2010 32,733 375.9 2,044
12/7/2010 32,030 366.2 1,949
12/8/2010 31,364 366.1 1,907
12/9/2010 32,728 367.6 1,999
12/10/2010 33,413 397.4 2,206
12/11/2010 33,901 366.9 2,066
12/12/2010 33,095 360.1 1,979
12/13/2010 30,780 345.0 1,764
12/14/2010 31,267 264.0 1,371
12/15/2010 33,459 362.1 2,013
12/16/2010 32,773 379.6 2,067
12/17/2010 31,632 290.0 1,524
12/18/2010 30,176 203.5 1,020
12/19/2010 30,485 272.2 1,378
12/20/2010 30,595 290.5 1,476
12/21/2010 31,456 326.3 1,705
12/22/2010 30,843 378.3 1,938
12/23/2010 30,723 295.6 1,508
12/24/2010 31,130 385.0 1,991
12/25/2010 31,555 363.0 1,903
12/26/2010 31,316 324.3 1,687
12/27/2010 31,603 378.9 1,989
12/28/2010 31,687 339.8 1,789
12/29/2010 31,922 364.8 1,934
12/30/2010 31,872 349.3 1,849
12/31/2010 31,660 353.2 1,857
1/1/2011 32,152 326.7 1,745
1/2/2011 31,589 361.9 1,899
1/3/2011 31,494 361.0 1,889
1/4/2011 31,360 282.9 1,474
1/5/2011 31,563 348.8 1,829
1/6/2011 32,050 361.7 1,926
1/7/2011 32,011 371.6 1,976
1/8/2011 30,895 311.2 1,597
1/9/2011 30,838 377.1 1,932
1/10/2011 31,043 365.5 1,885
1/11/2011 31,072 386.9 1,997
1/12/2011 30,336 411.5 2,073
1/13/2011 28,579 427.3 2,028
1/14/2011 28,145 415.1 1,941
1/15/2011 27,507 430.0 1,965
1/16/2011 29,125 407.6 1,972
1/17/2011 28,648 400.1 1,904
1/18/2011 28,028 218.5 1,017
1/19/2011 28,526 199.9 947
1/20/2011 27,054 216.8 974
1/21/2011 27,836 256.6 1,186
1/22/2011 26,010 374.1 1,616
1/23/2011 24,720 362.2 1,487
1/24/2011 22,709 365.5 1,379
1/25/2011 21,157 426.4 1,499
1/26/2011 22,128 421.4 1,549
1/27/2011 22,917 370.4 1,410
1/28/2011 24,704 387.8 1,591
1/29/2011 25,447 406.9 1,720
1/30/2011 22,489 315.8 1,180
1/31/2011 19,350 19.4 62
2/1/2011 18,344 20.1 61
2/2/2011 20,365 12.3 41
2/3/2011 20,100 14.0 47
2/4/2011 21,449 23.4 83
2/5/2011 21,573 36.5 131
2/6/2011 20,448 23.8 81
2/7/2011 23,378 133.2 517
2/8/2011 28,162 304.6 1,425
2/9/2011 27,436 306.6 1,397
2/10/2011 28,365 392.2 1,848
2/11/2011 28,909 419.1 2,012
2/12/2011 29,226 447.0 2,170
2/13/2011 29,655 399.7 1,969
2/14/2011 29,444 438.5 2,145
2/15/2011 29,588 456.5 2,244
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
2/16/2011 29,098 362.5 1,752
2/17/2011 28,926 304.2 1,462
2/18/2011 29,174 338.0 1,638
2/19/2011 29,306 364.3 1,774
2/20/2011 29,673 416.8 2,054
2/21/2011 25,001 376.0 1,561
2/22/2011 19,875 345.3 1,140
2/23/2011 24,574 301.9 1,232
2/24/2011 26,411 308.9 1,355
2/25/2011 26,765 333.5 1,483
2/26/2011 27,498 369.1 1,686
2/27/2011 27,833 393.6 1,820
2/28/2011 29,285 386.4 1,880
3/1/2011 30,104 387.5 1,938
3/2/2011 31,618 387.6 2,036
3/3/2011 32,135 369.1 1,970
3/4/2011 33,162 461.5 2,542
3/5/2011 35,886 403.1 2,403
3/6/2011 32,913 386.6 2,113
3/7/2011 31,951 381.7 2,026
3/8/2011 32,517 406.4 2,195
3/9/2011 32,866 436.7 2,384
3/10/2011 32,758 425.0 2,313
3/11/2011 32,838 410.7 2,240
3/12/2011 32,113 460.6 2,457
3/13/2011 32,307 446.7 2,397
3/14/2011 31,017 513.0 2,643
3/15/2011 31,681 448.8 2,362
3/16/2011 32,758 471.8 2,567
3/17/2011 34,560 448.3 2,573
3/18/2011 35,367 412.8 2,425
3/19/2011 35,848 471.2 2,806
3/20/2011 35,251 414.4 2,426
3/21/2011 35,871 414.3 2,469
3/22/2011 36,399 368.3 2,227
3/23/2011 36,681 381.8 2,326
3/24/2011 35,653 341.8 2,024
3/25/2011 33,478 425.7 2,367
3/26/2011 33,696 474.6 2,656
3/27/2011 32,503 475.5 2,567
3/28/2011 30,971 532.9 2,742
3/29/2011 32,425 495.5 2,669
3/30/2011 33,451 513.5 2,853
3/31/2011 33,721 488.5 2,736
4/1/2011 33,081 488.3 2,683
4/2/2011 31,826 484.2 2,560
4/3/2011 33,422 524.5 2,912
4/4/2011 31,571 438.0 2,297
4/5/2011 32,832 469.0 2,558
4/6/2011 32,428 463.7 2,497
4/7/2011 32,448 450.5 2,428
4/8/2011 32,345 475.6 2,555
4/9/2011 34,603 432.6 2,486
4/10/2011 34,781 403.2 2,330
4/11/2011 34,440 446.0 2,551
4/12/2011 34,820 384.1 2,222
4/13/2011 33,525 369.2 2,056
4/14/2011 32,329 424.6 2,280
4/15/2011 31,853 428.0 2,264
4/16/2011 32,430 426.3 2,296
4/17/2011 32,762 415.6 2,262
4/18/2011 32,652 418.7 2,271
4/19/2011 32,375 430.5 2,315
4/20/2011 32,898 462.7 2,528
4/21/2011 32,823 451.8 2,463
4/22/2011 32,741 516.9 2,811
4/23/2011 32,425 567.6 3,057
4/24/2011 32,397 461.8 2,485
4/25/2011 32,259 497.0 2,663
4/26/2011 32,484 609.7 3,290
4/27/2011 32,165 669.9 3,579
4/28/2011 32,268 531.7 2,850
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
4/29/2011 32,310 447.0 2,399
4/30/2011 31,570 497.0 2,606
5/1/2011 31,388 603.8 3,148
5/2/2011 31,590 671.0 3,521
5/3/2011 31,526 590.8 3,094
5/4/2011 31,217 748.2 3,880
5/5/2011 30,551 716.1 3,634
5/6/2011 30,918 678.4 3,484
5/7/2011 31,593 414.0 2,173
5/8/2011 31,667 332.2 1,748
5/9/2011 28,672 470.1 2,239
5/10/2011 31,950 434.6 2,307
5/11/2011 25,334 184.1 775
5/12/2011 21,016 76.9 268
5/13/2011 21,842 51.8 188
5/14/2011 21,498 48.9 175
5/15/2011 21,449 54.7 195
5/16/2011 20,770 61.7 213
5/17/2011 21,105 77.0 270
5/18/2011 18,877 98.3 308
5/19/2011 19,538 67.9 220
5/20/2011 18,425 110.5 338
5/21/2011 19,882 107.1 354
5/22/2011 18,917 55.5 174
5/23/2011 18,397 152.1 465
5/24/2011 17,975 231.1 690
5/25/2011 19,702 99.1 324
5/26/2011 18,048 96.1 288
5/27/2011 16,286 110.2 298
5/28/2011 17,996 119.0 356
5/29/2011 17,896 119.0 354
5/30/2011 18,759 137.8 429
5/31/2011 20,497 207.1 705
6/1/2011 19,879 310.1 1,024
6/2/2011 20,611 50.0 171
6/3/2011 20,559 16.2 55
6/4/2011 23,771 73.0 288
6/5/2011 28,513 55.8 264
6/6/2011 27,932 6.0 28
6/7/2011 25,169 8.1 34
6/8/2011 26,088 6.0 26
6/9/2011 25,810 8.3 36
6/10/2011 25,930 7.9 34
6/11/2011 24,955 29.2 121
6/12/2011 23,674 19.8 78
6/13/2011 20,055 57.8 193
6/14/2011 20,268 105.1 354
6/15/2011 21,291 176.5 624
6/16/2011 22,329 206.9 767
6/17/2011 22,354 221.7 823
6/18/2011 22,223 211.4 780
6/19/2011 21,781 246.6 892
6/20/2011 19,434 238.4 770
6/21/2011 20,316 197.7 667
6/22/2011 21,061 174.9 612
6/23/2011 21,726 198.4 716
6/24/2011 22,590 188.1 706
6/25/2011 23,875 296.1 1,174
6/26/2011 22,012 375.1 1,371
6/27/2011 21,201 358.8 1,264
6/28/2011 23,008 267.3 1,021
6/29/2011 23,664 275.6 1,083
6/30/2011 24,109 373.9 1,497
7/1/2011 24,104 402.9 1,613
7/2/2011 26,167 425.3 1,848
7/3/2011 27,598 501.4 2,298
7/4/2011 29,142 447.7 2,167
7/5/2011 31,674 444.9 2,341
7/6/2011 33,521 440.2 2,451
7/7/2011 34,194 435.3 2,472
7/8/2011 33,956 451.0 2,544
7/9/2011 34,341 470.8 2,686
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
7/10/2011 33,950 460.2 2,595
7/11/2011 33,805 455.4 2,557
7/12/2011 33,056 394.7 2,167
7/13/2011 32,921 405.2 2,216
7/14/2011 32,298 434.3 2,330
7/15/2011 32,946 456.2 2,496
7/16/2011 32,403 470.1 2,530
7/17/2011 31,636 393.0 2,065
7/18/2011 32,137 432.7 2,310
7/19/2011 32,279 460.0 2,466
7/20/2011 31,755 504.1 2,659
7/21/2011 32,160 484.3 2,587
7/22/2011 32,060 497.7 2,651
7/23/2011 31,593 446.3 2,342
7/24/2011 30,225 384.9 1,932
7/25/2011 30,951 366.7 1,885
7/26/2011 31,700 326.1 1,717
7/27/2011 32,658 360.0 1,953
7/28/2011 33,987 390.4 2,204
7/29/2011 33,498 444.7 2,475
7/30/2011 31,913 449.8 2,384
7/31/2011 29,512 436.4 2,139
8/1/2011 29,242 445.0 2,161
8/2/2011 30,233 429.4 2,157
8/3/2011 31,352 415.6 2,164
8/4/2011 32,036 425.3 2,263
8/5/2011 32,169 459.6 2,456
8/6/2011 32,707 418.9 2,276
8/7/2011 32,491 444.8 2,401
8/8/2011 32,504 467.4 2,523
8/9/2011 33,034 427.7 2,347
8/10/2011 33,944 402.4 2,269
8/11/2011 33,468 374.5 2,082
8/12/2011 32,844 461.4 2,517
8/13/2011 33,005 510.1 2,797
8/14/2011 33,147 455.6 2,509
8/15/2011 33,340 212.9 1,179
8/16/2011 33,154 297.1 1,636
8/17/2011 32,302 419.2 2,249
8/18/2011 32,537 409.5 2,213
8/19/2011 32,774 425.0 2,314
8/20/2011 33,075 438.9 2,411
8/21/2011 36,305 390.5 2,355
8/22/2011 36,666 378.9 2,307
8/23/2011 34,933 448.3 2,601
8/24/2011 32,355 542.1 2,913
8/25/2011 32,392 531.8 2,861
8/26/2011 32,218 486.9 2,606
8/27/2011 33,021 313.8 1,721
8/28/2011 34,348 409.6 2,337
8/29/2011 33,355 403.7 2,237
8/30/2011 33,523 382.8 2,132
8/31/2011 33,636 424.0 2,369
9/1/2011 34,528 427.3 2,451
9/2/2011 35,403 448.8 2,639
9/3/2011 35,290 400.6 2,348
9/4/2011 35,612 441.2 2,610
9/5/2011 35,176 457.4 2,673
9/6/2011 34,807 438.3 2,534
9/7/2011 30,308 116.2 585
9/8/2011 29,506 69.1 338
9/9/2011 28,835 57.4 275
9/10/2011 29,577 40.1 197
9/11/2011 29,824 41.2 204
9/12/2011 31,012 91.0 469
9/13/2011 30,838 346.4 1,775
9/14/2011 30,805 333.2 1,705
9/15/2011 29,654 344.1 1,695
9/16/2011 30,495 340.2 1,723
9/17/2011 30,568 391.6 1,988
9/18/2011 30,470 422.3 2,137
9/19/2011 30,541 410.4 2,082
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
9/20/2011 31,085 387.8 2,003
9/21/2011 29,940 353.3 1,757
9/22/2011 29,517 374.2 1,835
9/23/2011 30,160 432.6 2,167
9/24/2011 32,083 393.7 2,098
9/25/2011 32,955 427.2 2,338
9/26/2011 33,498 512.9 2,854
9/27/2011 33,051 422.0 2,316
9/28/2011 31,823 561.7 2,969
9/29/2011 32,401 463.6 2,495
9/30/2011 30,691 412.2 2,101
10/1/2011 29,692 489.1 2,412
10/2/2011 29,456 488.5 2,390
10/3/2011 29,871 483.2 2,398
10/4/2011 29,720 522.2 2,578
10/5/2011 29,167 532.6 2,580
10/6/2011 28,827 605.2 2,898
10/7/2011 28,370 489.7 2,307
10/8/2011 27,300 254.5 1,154
10/9/2011 25,430 269.1 1,137
10/10/2011 25,829 286.2 1,228
10/11/2011 24,968 303.8 1,260
10/12/2011 23,599 354.0 1,388
10/13/2011 23,411 383.8 1,492
10/14/2011 26,579 586.8 2,591
10/15/2011 29,982 534.5 2,662
10/16/2011 29,376 483.6 2,360
10/17/2011 27,729 465.8 2,145
10/18/2011 27,732 496.1 2,285
10/19/2011 29,011 508.3 2,449
10/20/2011 29,964 438.3 2,182
10/21/2011 31,025 492.7 2,539
10/22/2011 28,850 509.8 2,443
10/23/2011 28,600 555.7 2,640
10/24/2011 29,501 549.3 2,692
10/25/2011 29,834 500.4 2,480
10/26/2011 28,359 526.0 2,478
10/27/2011 30,291 459.7 2,313
10/28/2011 31,011 486.9 2,508
10/29/2011 30,873 504.2 2,586
10/30/2011 29,368 543.7 2,652
10/31/2011 27,763 580.3 2,676
11/1/2011 28,691 641.1 3,055
11/2/2011 28,924 560.5 2,693
11/3/2011 30,478 479.8 2,429
11/4/2011 29,442 437.9 2,141
11/5/2011 29,917 506.0 2,515
11/6/2011 29,664 498.5 2,456
11/7/2011 29,823 432.7 2,143
11/8/2011 29,407 405.0 1,978
11/9/2011 28,961 472.0 2,271
11/10/2011 28,502 459.1 2,174
11/11/2011 27,467 434.8 1,984
11/12/2011 26,954 420.3 1,882
11/13/2011 27,904 430.2 1,994
11/14/2011 29,570 384.4 1,888
11/15/2011 29,441 517.3 2,530
11/16/2011 28,923 533.4 2,562
11/17/2011 28,129 470.1 2,196
11/18/2011 28,393 471.3 2,223
11/19/2011 29,016 506.5 2,441
11/20/2011 28,690 438.0 2,088
11/21/2011 28,827 463.4 2,219
11/22/2011 27,969 424.3 1,971
11/23/2011 28,211 394.4 1,848
11/24/2011 28,334 438.9 2,066
11/25/2011 27,803 421.1 1,945
11/26/2011 28,455 406.8 1,923
11/27/2011 28,162 440.0 2,058
11/28/2011 27,819 515.3 2,381
11/29/2011 27,615 554.9 2,545
11/30/2011 27,420 567.4 2,584
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
12/1/2011 27,237 510.9 2,311
12/2/2011 26,843 502.7 2,241
12/3/2011 26,516 431.7 1,901
12/4/2011 26,238 444.7 1,938
12/5/2011 26,377 426.4 1,868
12/6/2011 26,748 399.0 1,773
12/7/2011 25,268 369.8 1,552
12/8/2011 26,568 348.8 1,539
12/9/2011 27,486 339.6 1,551
12/10/2011 26,909 377.5 1,687
12/11/2011 26,686 426.4 1,890
12/12/2011 26,985 438.3 1,965
12/13/2011 29,921 383.9 1,908
12/14/2011 30,279 382.9 1,926
12/15/2011 29,926 363.2 1,805
12/16/2011 29,733 413.2 2,041
12/17/2011 29,670 373.8 1,842
12/18/2011 30,562 392.6 1,993
12/19/2011 29,704 401.5 1,981
12/20/2011 29,596 400.0 1,966
12/21/2011 28,852 391.1 1,874
12/22/2011 30,020 329.5 1,643
12/23/2011 27,969 305.7 1,420
12/24/2011 25,205 336.4 1,408
12/25/2011 26,987 357.6 1,603
12/26/2011 25,602 360.3 1,532
12/27/2011 25,073 384.3 1,600
12/28/2011 26,335 418.6 1,831
12/29/2011 25,906 403.8 1,738
12/30/2011 24,576 436.5 1,782
12/31/2011 25,910 473.9 2,039
1/1/2012 24,917 507.2 2,099
1/2/2012 24,453 473.4 1,923
1/3/2012 23,849 451.9 1,790
1/4/2012 24,199 373.6 1,502
1/5/2012 24,494 364.1 1,481
1/6/2012 25,264 322.9 1,355
1/7/2012 24,877 302.1 1,248
1/8/2012 25,404 385.7 1,627
1/9/2012 25,380 367.8 1,551
1/10/2012 26,270 326.9 1,426
1/11/2012 26,064 297.2 1,287
1/12/2012 25,531 409.8 1,738
1/13/2012 26,121 472.7 2,051
1/14/2012 27,354 453.1 2,059
1/15/2012 27,331 438.6 1,991
1/16/2012 25,291 426.9 1,794
1/17/2012 25,938 422.4 1,820
1/18/2012 22,606 432.2 1,623
1/19/2012 20,952 442.9 1,541
1/20/2012 22,968 451.4 1,722
1/21/2012 28,051 492.0 2,293
1/22/2012 28,179 505.8 2,367
1/23/2012 27,267 501.2 2,270
1/24/2012 26,924 543.1 2,429
1/25/2012 27,984 476.0 2,212
1/26/2012 29,514 371.6 1,822
1/27/2012 29,369 414.0 2,020
1/28/2012 28,766 432.6 2,067
1/29/2012 26,075 470.7 2,039
1/30/2012 24,580 487.7 1,991
1/31/2012 25,811 488.8 2,096
2/1/2012 27,071 549.8 2,472
2/2/2012 27,464 550.1 2,509
2/3/2012 27,543 561.8 2,570
2/4/2012 28,260 549.3 2,579
2/5/2012 27,672 552.7 2,540
2/6/2012 28,248 540.0 2,534
2/7/2012 29,096 512.1 2,475
2/8/2012 29,572 467.8 2,298
2/9/2012 29,530 517.8 2,540
2/10/2012 27,892 535.7 2,482
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
2/11/2012 27,305 581.0 2,635
2/12/2012 26,335 519.8 2,274
2/13/2012 27,105 478.5 2,155
2/14/2012 26,879 543.1 2,425
2/15/2012 26,810 527.8 2,350
2/16/2012 26,548 347.9 1,534
2/17/2012 25,271 329.1 1,381
2/18/2012 24,951 368.6 1,527
2/19/2012 26,582 562.3 2,483
2/20/2012 25,840 493.1 2,116
2/21/2012 24,550 556.5 2,269
2/22/2012 24,852 575.8 2,377
2/23/2012 25,397 568.1 2,397
2/24/2012 25,660 407.2 1,736
2/25/2012 25,788 493.7 2,115
2/26/2012 24,963 506.3 2,099
2/27/2012 24,633 303.5 1,242
2/28/2012 23,777 299.4 1,182
2/29/2012 24,099 488.0 1,954
3/1/2012 23,922 721.1 2,865
3/2/2012 22,787 625.6 2,368
3/3/2012 23,202 663.5 2,557
3/4/2012 23,466 675.3 2,632
3/5/2012 24,540 646.6 2,636
3/6/2012 24,587 638.3 2,607
3/7/2012 26,106 640.1 2,776
3/8/2012 29,576 578.1 2,840
3/9/2012 30,647 480.7 2,447
3/10/2012 30,357 402.0 2,027
3/11/2012 27,786 387.7 1,789
3/12/2012 26,564 349.1 1,540
3/13/2012 27,606 335.9 1,540
3/14/2012 25,633 371.8 1,583
3/15/2012 25,966 447.7 1,931
3/16/2012 30,010 437.4 2,180
3/17/2012 28,829 421.8 2,020
3/18/2012 26,307 463.4 2,025
3/19/2012 25,805 547.9 2,348
3/20/2012 24,897 535.6 2,215
3/21/2012 26,421 514.8 2,259
3/22/2012 28,825 493.9 2,365
3/23/2012 29,079 467.1 2,256
3/24/2012 28,995 442.0 2,129
3/25/2012 28,384 457.1 2,155
3/26/2012 26,924 492.2 2,201
3/27/2012 25,347 508.1 2,139
3/28/2012 28,974 477.8 2,299
3/29/2012 28,145 502.4 2,349
3/30/2012 28,282 498.1 2,340
3/31/2012 29,642 470.1 2,314
4/1/2012 29,799 440.0 2,178
4/2/2012 29,277 477.5 2,322
4/3/2012 29,894 435.4 2,162
4/4/2012 29,816 416.9 2,065
4/5/2012 29,441 393.9 1,926
4/6/2012 29,194 407.7 1,977
4/7/2012 28,517 424.0 2,009
4/8/2012 29,314 384.4 1,872
4/9/2012 29,036 411.0 1,982
4/10/2012 29,951 468.2 2,329
4/11/2012 29,054 426.1 2,056
4/12/2012 28,203 445.7 2,088
4/13/2012 28,028 382.7 1,782
4/14/2012 29,272 318.7 1,550
4/15/2012 28,371 329.0 1,550
4/16/2012 28,798 336.7 1,611
4/17/2012 28,984 319.8 1,540
4/18/2012 29,242 312.2 1,516
4/19/2012 29,511 319.7 1,567
4/20/2012 28,053 332.3 1,549
4/21/2012 27,543 396.2 1,812
4/22/2012 27,273 442.1 2,003
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
4/23/2012 27,074 447.5 2,012
4/24/2012 27,806 470.6 2,174
4/25/2012 27,362 425.6 1,934
4/26/2012 27,937 410.5 1,905
4/27/2012 26,784 427.7 1,903
4/28/2012 25,291 399.9 1,680
4/29/2012 24,628 409.2 1,674
4/30/2012 24,672 364.9 1,496
5/1/2012 24,929 403.4 1,670
5/2/2012 25,196 368.1 1,540
5/3/2012 25,263 374.6 1,572
5/4/2012 24,868 359.7 1,486
5/5/2012 22,923 376.8 1,435
5/6/2012 23,472 416.7 1,625
5/7/2012 23,352 416.7 1,616
5/8/2012 23,747 388.1 1,531
5/9/2012 24,438 431.5 1,752
5/10/2012 24,409 404.0 1,638
5/11/2012 24,880 381.4 1,576
5/12/2012 25,306 339.3 1,426
5/13/2012 25,646 355.5 1,515
5/14/2012 26,103 290.8 1,261
5/15/2012 26,748 322.0 1,431
5/16/2012 26,983 315.0 1,412
5/17/2012 27,886 304.2 1,409
5/18/2012 27,447 336.7 1,535
5/19/2012 27,261 397.7 1,801
5/20/2012 28,425 383.6 1,811
5/21/2012 27,946 402.4 1,868
5/22/2012 28,531 392.2 1,859
5/23/2012 27,173 355.1 1,603
5/24/2012 27,800 279.3 1,290
5/25/2012 26,695 248.2 1,100
5/26/2012 25,890 298.8 1,285
5/27/2012 25,626 261.1 1,111
5/28/2012 25,853 233.6 1,003
5/29/2012 26,519 264.6 1,165
5/30/2012 27,974 275.8 1,281
5/31/2012 29,488 222.2 1,088
6/1/2012 30,040 234.5 1,170
6/2/2012 28,529 293.7 1,392
6/3/2012 29,191 324.3 1,572
6/4/2012 28,290 351.0 1,649
6/5/2012 20,731 398.5 1,372
6/6/2012 19,313 496.4 1,592
6/7/2012 21,415 391.9 1,394
6/8/2012 20,153 396.5 1,327
6/9/2012 20,280 395.3 1,331
6/10/2012 21,508 529.9 1,893
6/11/2012 23,444 405.1 1,577
6/12/2012 23,426 366.6 1,427
6/13/2012 24,596 398.2 1,627
6/14/2012 25,924 369.4 1,591
6/15/2012 26,626 316.9 1,401
6/16/2012 25,279 311.3 1,307
6/17/2012 23,201 333.9 1,287
6/18/2012 24,892 371.7 1,537
6/19/2012 25,581 400.9 1,703
6/20/2012 25,441 387.0 1,635
6/21/2012 25,095 354.0 1,476
6/22/2012 24,738 330.2 1,357
6/23/2012 25,040 252.2 1,049
6/24/2012 25,150 326.2 1,363
6/25/2012 25,541 346.7 1,471
6/26/2012 25,914 370.3 1,594
6/27/2012 26,154 380.2 1,652
6/28/2012 26,248 393.1 1,714
6/29/2012 26,825 332.1 1,480
6/30/2012 26,241 413.1 1,801
7/1/2012 28,666 395.8 1,885
7/2/2012 28,982 404.0 1,945
7/3/2012 29,046 434.8 2,098
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
7/4/2012 29,709 403.2 1,990
7/5/2012 29,638 379.3 1,867
7/6/2012 29,661 406.7 2,004
7/7/2012 29,149 391.3 1,895
7/8/2012 28,429 334.3 1,579
7/9/2012 28,590 279.2 1,326
7/10/2012 27,664 305.9 1,406
7/11/2012 27,486 339.1 1,548
7/12/2012 27,903 410.1 1,901
7/13/2012 28,625 328.9 1,564
7/14/2012 27,279 407.2 1,845
7/15/2012 27,198 378.2 1,709
7/16/2012 27,250 317.8 1,438
7/17/2012 27,148 374.2 1,688
7/18/2012 27,782 402.1 1,856
7/19/2012 28,102 390.8 1,824
7/20/2012 28,382 390.3 1,840
7/21/2012 28,379 390.0 1,838
7/22/2012 29,039 372.3 1,796
7/23/2012 30,055 368.9 1,842
7/24/2012 29,730 364.6 1,801
7/25/2012 27,547 400.7 1,834
7/26/2012 27,320 412.8 1,873
7/27/2012 27,694 389.0 1,790
7/28/2012 29,403 327.1 1,598
7/29/2012 28,906 348.5 1,674
7/30/2012 28,707 361.0 1,721
7/31/2012 28,680 347.9 1,657
8/1/2012 27,891 375.1 1,738
8/2/2012 31,494 322.6 1,688
8/3/2012 32,095 277.5 1,479
8/4/2012 31,863 293.8 1,555
8/5/2012 31,085 388.3 2,005
8/6/2012 31,473 362.6 1,896
8/7/2012 31,243 361.9 1,878
8/8/2012 30,234 398.5 2,001
8/9/2012 32,896 444.8 2,430
8/10/2012 33,004 385.5 2,113
8/11/2012 31,145 433.7 2,244
8/12/2012 30,629 383.9 1,953
8/13/2012 30,492 409.6 2,075
8/14/2012 31,019 393.9 2,029
8/15/2012 30,839 387.0 1,982
8/16/2012 30,893 428.1 2,197
8/17/2012 30,693 433.1 2,208
8/18/2012 30,440 406.2 2,054
8/19/2012 30,321 401.2 2,021
8/20/2012 30,680 386.4 1,969
8/21/2012 30,754 357.5 1,826
8/22/2012 31,097 327.9 1,694
8/23/2012 31,574 324.0 1,699
8/24/2012 29,239 309.2 1,502
8/25/2012 25,934 291.3 1,255
8/26/2012 25,408 339.5 1,433
8/27/2012 28,534 274.5 1,301
8/28/2012 25,213 354.5 1,485
8/29/2012 28,198 159.5 747
8/30/2012 25,222 20.6 86
8/31/2012 27,639 102.4 470
9/1/2012 28,309 212.0 997
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
9/2/2012 27,038 244.0 1,096
9/3/2012 27,550 299.7 1,372
9/4/2012 29,854 391.0 1,939
9/5/2012 28,634 360.2 1,713
9/6/2012 28,078 436.2 2,034
9/7/2012 28,311 428.3 2,014
9/8/2012 28,318 409.0 1,924
9/9/2012 28,949 395.1 1,900
9/10/2012 28,968 353.1 1,699
9/11/2012 26,835 392.1 1,748
9/12/2012 29,708 438.8 2,165
9/13/2012 28,372 439.2 2,070
9/14/2012 28,472 413.0 1,953
9/15/2012 27,277 401.0 1,817
9/16/2012 27,573 401.0 1,837
9/17/2012 26,892 401.0 1,791
9/18/2012 27,723 401.0 1,847
9/19/2012 27,855 401.0 1,855
9/20/2012 27,554 401.0 1,835
9/21/2012 28,194 401.0 1,878
9/22/2012 28,305 401.0 1,885
9/23/2012 27,873 401.0 1,857
9/24/2012 28,646 401.0 1,908
9/25/2012 28,557 401.0 1,902
9/26/2012 29,131 401.0 1,940
9/27/2012 29,178 401.0 1,943
9/28/2012 29,553 401.0 1,968
9/29/2012 29,362 401.0 1,956
9/30/2012 29,186 401.0 1,944
10/1/2012 32,171 401.0 2,143
10/2/2012 30,627 401.0 2,040
10/3/2012 30,901 400.7 2,057
10/4/2012 30,913 374.2 1,921
10/5/2012 32,326 304.7 1,636
10/6/2012 26,367 293.3 1,285
10/7/2012 24,725 407.7 1,674
10/8/2012 24,683 385.6 1,581
10/9/2012 24,223 375.3 1,510
10/10/2012 24,475 423.6 1,722
10/11/2012 24,520 436.8 1,779
10/12/2012 24,336 340.9 1,378
10/13/2012 24,331 365.1 1,475
10/14/2012 23,780 340.0 1,343
10/15/2012 24,110 313.3 1,255
10/16/2012 25,388 307.0 1,295
10/17/2012 25,083 325.9 1,358
10/18/2012 26,119 259.2 1,124
10/19/2012 23,386 256.8 998
10/20/2012 19,250 285.9 914
10/21/2012 17,644 176.2 516
10/22/2012 19,941 35.5 117
10/23/2012 23,737 32.6 129
10/24/2012 24,529 181.4 739
10/25/2012 24,405 340.4 1,380
10/26/2012 26,025 502.2 2,171
10/27/2012 30,900 427.2 2,192
10/28/2012 28,619 382.9 1,820
10/29/2012 28,723 388.4 1,853
10/30/2012 28,384 407.1 1,920
10/31/2012 26,285 420.7 1,837
11/1/2012 26,646 496.8 2,199
11/2/2012 27,235 515.4 2,331
11/3/2012 26,859 460.3 2,053
U233 FG U233 Total S U233 FG SO2
MSCFD ppm lb/d
DATE
11/4/2012 26,966 491.5 2,201
11/5/2012 27,273 481.4 2,181
11/6/2012 27,422 512.9 2,336
11/7/2012 29,167 440.9 2,136
11/8/2012 29,439 343.7 1,681
11/9/2012 29,321 365.1 1,778
11/10/2012 29,759 346.1 1,711
11/11/2012 29,631 362.4 1,784
11/12/2012 26,908 417.3 1,865
11/13/2012 26,490 376.0 1,654
11/14/2012 24,863 385.3 1,591
11/15/2012 25,275 380.0 1,596
11/16/2012 25,129 353.0 1,473
11/17/2012 25,567 313.4 1,331
11/18/2012 26,089 330.0 1,430
11/19/2012 25,316 340.6 1,432
11/20/2012 25,088 433.5 1,806
11/21/2012 24,724 386.3 1,587
11/22/2012 24,968 413.6 1,715
11/23/2012 24,465 546.1 2,219
11/24/2012 25,390 543.9 2,294
11/25/2012 26,287 503.8 2,200
11/26/2012 26,716 520.4 2,309
11/27/2012 26,558 500.2 2,207
11/28/2012 26,797 501.8 2,234
11/29/2012 26,376 509.0 2,230
11/30/2012 26,244 425.0 1,852
CBE Supplemental Attachment 5
Refinery Action Collaborative letter of
18 December 2013
(3 pages)
BY ELECTRONIC MAIL
18 December 2013
Hon. Federal Glover, Chair, and Members of the Board
Board of Supervisors, Contra Costa County
Hon. Elizabeth Patterson, Mayor, and Council Members
City Council, City of Benicia
Hon. Nancy Parent, Mayor, and Council Members
City Council, City of Pittsburg
Hon. Gayle McLaughlin, Mayor, and Council Members
City Council, City of Richmond
Re: Chevron Richmond Refinery “Modernization” Project,
Phillips 66 San Francisco Refinery Rodeo “Propane Recovery” Project,
Praxair “Contra Costa Pipeline” Project,
Valero Benicia Refinery “Crude by Rail” Project, and
WesPac Pittsburg “Energy Infrastructure” Project—Disclosure of
Refinery Oil Feedstock Quality Among Data for Environmental Review
Dear local government leaders,
The Refinery Action Collaborative (Collaborative) is a labor-community-university
partnership working to address critical environmental health and safety concerns shared
by refinery workers and residents regionally. Collaborative members include the Asian
Pacific Environmental Network, the BlueGreen Alliance, Communities for a Better
Environment, the Labor Occupational Health Program at UC Berkeley, the Natural
Resources Defense Council, the United Steelworkers (USW) International Union, United
Steelworkers Local 5, and United Steelworkers Local 326.
We understand that the proposed projects identified above are currently in environmental
review, including public review of potential environmental health and safety impacts, and
that your city or county is the California Environmental Quality Act “lead agency” in this
review for one or more of these projects. The Collaborative has not taken a position on
the projects at this time. We write to support an adequate environmental review of these
projects that includes, among other factors that have the potential to affect refinery safety
and emissions, public disclosure of potential changes in refinery oil feedstock quality.
Our Collaborative’s founding principles commit us to “pursue solutions that improve
transparency and public accountability in the refinery industry.” In a major effort earlier
this year, our groups reached consensus on a Recommendation to Ensure Prevention of
Feedstock-Related Emissions Increase, released in June 2013, that calls for the public
disclosure and review of each Bay Area refiner’s oil feedstock quality.1 We also have
supported community leaders’ call for full and transparent environmental review of all
potential risks associated with the Valero Benicia proposal, including its potential to
facilitate a change in refinery oil feedstock quality.2 More recently, we made
recommendations to the Governor’s Interagency Refineries Task Force that called,
among other things, for public reporting of refinery crude feed quality, explaining that:
Disclosure by the refineries of the quality of crude oil entering the plant is necessary
for assessing the efficacy of a plant’s safety measures and air pollution controls.3
As leaders of the public environmental reviews for these proposed projects under the
state’s Environmental Quality Act, your agencies are positioned to address these needs.
Accordingly, we respectfully ask you to ensure that the environmental reviews of these
proposed projects will disclose and address current and potentially changing refinery oil
feedstock quality among the factors affecting community and worker health and safety.
On Behalf of the Collaborative,
Miya Yoshitani, Executive Director
Asian Pacific Environmental Network
Charlotte Brody, Vice President for Health Initiatives
BlueGreen Alliance
Greg Karras, Senior Scientist
Communities for a Better Environment
Nazima EL-Askari, MPH, Program Coordinator
Labor Occupational Health Program, UC Berkeley
Diane Bailey, Senior Scientist
Natural Resources Defense Council
Ron Espinoza, District 12 Sub-Director
1 Bay Area Air Quality Management District Proposed Regulation 12, Rule 15; March 2013
Preliminary Draft Petroleum Refining Emissions Tracking Rule; comments submitted to Jack
Broadbent, Executive Officer, BAAQMD. 13 June 2013. See page 3.
2 Supporting the Committee’s position on the Valero Crude-by-Rail Project; letter to the Benicia
Good Neighbor Steering Committee c/o Marilyn Bardet. 25 July 2013.
3 Initial Response of the Collaborative to the Findings & Recommendations of the July 2013
Draft Report of the Interagency Working Group on Refinery Safety; 10 October 2013. See p. 7.
United Steelworkers International
Mike Smith, Local 5 Field Rep.
United Steelworkers Local 5
Moxie J. Loeffler, D.O.
Internal Medicine Physician