Concerned Citizens of Mossville and University Network for Human Rights urge Louisiana DEQ to reject Sasol’s request for increase in toxic emissions from Lake Charles facility

FOR IMMEDIATE RELEASE | February 18, 2020

Apartheid-era South African company seeks to significantly increase emissions of volatile organic compounds (VOCs) and carbon monoxide, threatening to exacerbate the toxic burden long suffered by residents of the historic African American community of Mossville

(Mossville, Louisiana, February 18, 2020): Yesterday, the Concerned Citizens of Mossville and the University Network for Human Rights submitted a public comment to the Louisiana Department of Environmental Quality (LDEQ), vigorously opposing a proposal by Sasol Chemicals (USA) LLC to significantly increase toxic emissions from the ethylene unit of the company’s Lake Charles Chemical Complex. The groups also requested a public hearing on the matter. Sasol seeks to increase its emissions of volatile organic compounds (VOCs) by 18% and carbon monoxide by 6%.

The historic African American community of Mossville, surrounded by industrial facilities, has been fighting environmental racism since the 1980s. If granted, Sasol’s request would exacerbate the toxic burden of industrial emissions long suffered by Mossville residents.

The public comment submitted to LDEQ is reprinted below in its entirety.

Submitted by: Concerned Citizens of Mossville & University Network for Human Rights

Technical information prepared by Dr. Kimberly Terrell, Tulane Environmental Law Clinic

RE: Proposed Part 70 Air Operating Permit Renewal and Modification for Sasol Chemicals (USA) LLC/Ethylene Unit – Lake Charles Chemical Complex; AI Number 3271, Permit Number 2743-V10, Activity Number PER20180011.

We urge LDEQ to deny Sasol’s air permit renewal/modification, which would significantly increase emissions of volatile organic compounds (VOCs) from the ethylene unit of Sasol’s Lake Charles Chemical Complex. Mossville, a historic African American community located next to the city of Lake Charles and less than two miles from Sasol’s Lake Charles Chemical Complex, has long suffered the devastating health impacts of industrial emissions from Sasol and other facilities. Sasol now proposes a major increase in its emissions of toxic VOCs and carbon monoxide (CO), as well as increases in particulate matter, nitrogen oxides, and greenhouse gases. As residents of Mossville and as human rights advocates, we find these proposed increases in toxic emissions unacceptable.

The proposed permit would allow Sasol to emit an extra 61 tons per year of VOCs (an 18% increase) and an extra 18 tons per year of carbon monoxide (a 6% increase). According to LDEQ records,[1] there are no LDEQ air monitors in Mossville. The closest VOC monitors are approximately two miles away (at the Westlake and Lighthouse Lane sites), and we are unaware of any evidence indicating that these monitors accurately reflect the VOC levels in Mossville. According to LDEQ records,[2] there is no carbon monoxide monitor anywhere in the southwest region of Louisiana; the closest carbon monoxide monitor is over 100 miles away in Baton Rouge.

In addition to the lack of VOC and CO monitoring in Mossville, there is no ozone monitoring in the vicinity. Ozone monitoring is relevant to Sasol’s request for an increase in VOC emissions because VOCs contribute to ozone formation. According to LDEQ’s records,[3] the closest ozone monitor to Mossville (and the only ozone monitor in the entire southwest region) is in Carlyss, eight miles from Mossville. LDEQ previously had an ozone monitor approximately two miles from Mossville, but deactivated the monitor on January 22, 2015.[4] Before this Westlake monitor was deactivated, ozone levels measured by the monitor were extremely close to violating the current National Ambient Air Quality Standards (NAAQS) threshold (implemented in 2015) of 0.07 ppm for the annual fourth-highest daily maximum eight-hour concentration, averaged over three years. The corresponding value for the Westlake monitor for 2010-2012 was 0.069 ppm. Any significant increase in ozone (for example, from an increase in VOC emissions) would almost certainly result in a violation of NAAQS ozone standards for this monitor.

LDEQ’s own data shows that actual VOC emissions within one kilometer of the Westlake monitoring site (30.262347, -93.284906) increased more than five-fold between 2014 and 2018, from 9.04 tons in 2014 to 45.30 tons in 2018.[5]

The lack of air monitoring in Mossville is alarming, particularly in light of the results of Sasol’s air dispersion modeling. Specifically, the proposed permit shows that ambient concentrations of carbon monoxide and PM2.5 after this permit modification would be within 3% of the NAAQS threshold.[6] This emissions level does not allow adequate room for error in Sasol’s air dispersion modeling, and there is no information in the proposed permit to suggest that the margin of error for Sasol’s air dispersion modeling is less than or equal to 3%. In fact, studies have repeatedly demonstrated that AERMOD can underpredict ambient concentrations of criteria pollutants.[7] Thus, ambient air concentrations near Sasol’s Lake Charles Chemical Complex may already be above NAAQS thresholds. The proposed emissions increases only elevate the likelihood of NAAQS violations.

In 1998 and 2001, the U.S. Agency for Toxic Substances and Disease Registry (ATSDR) investigated Mossville residents’ exposure to dioxins, highly toxic chemical compounds that are linked to cancer and a number of other harmful health impacts.[8] The ATSDR conducted its dioxin exposure investigation in coordination with the EPA, LDEQ, and LDH. According to the ATSDR’s findings, Mossville residents’ average blood dioxin levels were more than three times higher than the national comparison group.[9] Elevated dioxin levels were also found in the attic dust, indoor dust, and yard soil of Mossville homes, as well as in local fish, fruits, vegetables, and nuts.[10] Elevated dioxin levels in Mossville were subsequently linked to six local industrial facilities, including Sasol (the other five industries were Conoco Phillips, Entergy, Georgia Gulf, Lyondell, and PPG).[11]

We strongly suspect that Mossville residents are already exposed to dangerously high levels of VOCs, CO, and ozone. Sasol now proposes a major increase in emissions of these toxins, with utter disregard for the health and well-being of Mossville residents. LDEQ must not only reject Sasol’s proposal to increase emissions, but must also immediately install air monitors in Mossville (particularly for all pollutants where existing data indicate that ambient concentrations are near NAAQS thresholds, including ozone, carbon monoxide, and PM2.5) as well as require Sasol and other Lake Charles facilities to reduce emissions of all chemicals to EPA-recommended levels.

We hereby request a public hearing on Sasol’s Proposed Part 70 Air Operating Permit Renewal and Modification.

[1] Louisiana Department of Environmental Quality. “Louisiana Ambient Air Monitoring Sites.” Updated May 2017. https://www.deq.louisiana.gov/assets/docs/Air/LouisianaAmbientAirMonitoringSites.pdf (attached).

[2] Id.

[3] Id.

[4] Louisiana Department of Environmental Quality. “2015 Louisiana Annual Network Assessment,” page 18. https://www.deq.louisiana.gov/assets/docs/Air/Ambient_Air_Data/2015/LDEQ_2015_Annual_Network_Assessment.pdf (attached).

[5] See Louisiana Department of Environmental Quality Emissions Reporting and Inventory Center (ERIC) database: business.deq.louisiana.gov/Eric/EricReports/RadiusReportSelector

[6] Sasol Proposed Title V Permit Renewal and Modification, page 4. Jan 17, 2020. EDMS # 12014011.

[7] Gibson et al., 2014; Rood, 2014; Dresser and Huizer, 2011; Chen et al., 2009 (attached).

[8] U.S. Agency for Toxic Substances and Disease Registry. “Health Consultation: Follow-up Exposure Investigation.” Mar 13, 2006. https://www.atsdr.cdc.gov/HAC/pha/CalcasieuEstuary/CalcasieuEstuaryHC031306.pdf (attached).

[9] Costner, Pat. “Dioxin and PCB Contamination in Mossville, Louisiana: A Review of the Exposure Investigation by ATSDR,” page 1. Feb 23, 2000. https://pdfs.semanticscholar.org/6fca/70539a61737f7761ff88289e1ef057259b44.pdf (attached).

[10] “Industrial Sources of Dioxin Poisoning in Mossville, Louisiana: A Report Based on the Government’s Own Data,” pages 8-14. Revised July 2007. https://www.loe.org/images/content/100423/mossville.pdf (attached).

[11] Id, page 5.