First Responders: Workplace Air Safety or Long Term Exposure

To: Tacoma.methanol.sepa@cityoftacoma.org

Wednesday, March 2, 2016

EIS Scoping Comments: Tacoma Manufacturing and Marine Export Facility (TMMEF): “Proposed Methanol Plant”: SEPA Lead Agency: City of Tacoma (File No. SEPA2015-40000260025).

My comment applies to City, State, and Federal Employee (people) located or assigned duty at close proximity to Tacoma Port LNG, Methanol, or natural gas (methane) piping distribution facilities or systems as “first responders” and are full-time employed with “first responders” duties to these natural gas related facilities. Monitoring of workplace air chemical inventory is important to long-term health and welfare of these “first responders” government or any private people employed with such “first responders” duties; as a result, continuous hazard(s) monitoring is critical for these emergency responsive employees’ long term health.

[C]onsidered highly toxic to humans and animals until it biodegrades. Consistent with comment, the EIS will complete a comprehensive analysis of the adequacy of federal, state, and local emergency response capabilities to address spills, explosion, and/or fire along the pipeline route, at the site, and during transfer for shipping purposes. Commenters asked that the EIS consider methanol tank construction and safety measures, including the degree of secondary containment.… See, Methanol EIS Draft Scope of Work 02052016.pdf (at 7)., http://cms.cityoftacoma.org/planning/Methanol%20Plant/Methanol%20EIS%20Draft%20Scope%20of%20Work%2002052016.pdf(last visited Mar 2, 2016).

Continuous air monitoring for all emergency response locations (fire stations), vehicles (emergency response vehicles), or stations (emergency equipment locations)

“Where there is potential exposure to Hydrogen Sulfide, a monitoring strategy is recommended to ensure exposures are kept below acceptable levels and standards and that appropriate action is taken when there are excursions above these levels. Either traditional IH monitoring methods or electronic instruments can be used for this purpose.” See
generally, Monitoring Hydrogen Sulfide (H2S) to meet new exposure standards, (using continuous workplace chemicals exposure monitor for employee health) http://www.draeger.com/sites/assets/PublishingImages/Generic/sidebar-teaser/CA-US/Hydrogen_Sulfide_White_Paper_81297.pdf (last visited Mar 2, 2016).

As Methanol facility publishes listing of fugitive air chemicals released

As a result, expand the continuous air monitoring systems and sensors to include what chemicals are discovered as disclosed by methanol process or natural gas distribution system to be short- and long-term employee workplace hazards; as a result, set appropriate people alarms in monitor equipment and add this time chemical exposure information to each exposed employee for their health record.

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Tacoma We Need to Monitor Our Air: Many Locations

To: Tacoma.methanol.sepa@cityoftacoma.org

Tuesday, March 1, 2016

EIS Scoping Comments: Tacoma Manufacturing and Marine Export Facility (TMMEF): “Proposed Methanol Plant”: SEPA Lead Agency: City of Tacoma (File No. SEPA2015-40000260025).

My comment applies to potential environment impact upon Tacoma and surrounding communities:

Hydrogen Sulfide and Our Community Air

Since we don’t know the sources from which feed the Tacoma LNG and Methanol Facilities natural gas supply raw product input to process—sour gas, sweet gas, fracking gas, or just natural gas, and from which specific location mined; as a result, we must monitor the air hazards introduced into Tacoma Community forever.

It will become necessary to setup monitor multiple air inventory monitor stations within Tacoma Port and Tacoma Community neighborhoods (also Federal Way and Fife Wash.) that will detect and record hydrogen sulfide (“H2S”) content and the amount of hydrogen sulfide within our air inventory at the sampling station. This air monitoring must be done for Community(s) people health and illness prevention. See generally, Hydrogen Sulfide, Oil and Gas, and People’s Health Energy and Resources Group University of California, Berkeley, http://www.bouldercounty.org/doc/landuse/hydrogensulfidestudy.pdf (last visited Mar 1, 2016).

The potential stationary hydrogen sulfide source potential emitters

“flaring operations at both oil and gas facilities, venting, wastewater pits, and an oil refinery….”, supra at 45. The H2S air monitor stations should be located to detect emissions from these emitters.

Also we need H2S air monitor stations along length of natural gas piping distribution system pips and all pumping stations where possibility of piping gasket leakage or pumping station seals could leak, supra at 8, note 21. This is important to those persons’ health living within proximity to this distribution natural gas system that feeds the Methanol Facility and LNG Facility.

Oil and gas operations may emit hydrogen sulfide, routinely or accidentally, during the extraction, storage, trans port, or processing stage.20 During of extraction, hydrogen sulfide may be released into the atmosphere at wellheads, pumps, piping, separation devices, oil storage tanks, water storage vessels, and during flaring operations.21 Flares burn gases that cannot be sold as well as gases at points in the system where operating problems may occur, as a safety measure. Because it cannot be sold, hydrogen sulfide is routinely flared. Sulfur dioxide (SO2) is the product of combusting hydrogen sulfide, but in the event of incomplete combustion, H2S may be emitted into the atmosphere. Supra at 8.

Community health and wellness requires we monitor our air

Because we have potential of three hazards present within Tacoma Port—natural gas piping system, LNG Facility, and Methanol Facility—we need to monitor the air we Tacoma Community people must breath: as a result, to know when our health is affected and to what extent by these industrial process(s) operating within our Tacoma Community.

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Let’s review why Tacoma Mayor Likes TPP

Why is the TPP not good for Tacoma people

We, I have, known for a long time the Trans-Pacific Partnership (“TPP”) has been secret for what ending benefit to whom? Therefore, just maybe we can understand a little who is doing what to just who that benefits our Tacoma Community?

The Trans-Pacific Partnership (TPP) is an expansive trade deal being negotiated between twelve countries in the Pacific Rim: Australia, Brunei, Canada, Chile, Japan, Malaysia, Mexico, New Zealand, Peru, Singapore, Vietnam, and the United States. Because the TPP is intended as a “docking agreement,” other countries would be able to join over time.

The TPP touches on a broad range of issues—the environment, workers and jobs, access to medicines, and more. The TPP would also allow foreign corporations to sue governments directly for unlimited cash compensation—in private, non – transparent tribunals—over almost any domestic environmental or other policy that the corporation alleges is hurting its ability to profit.

Despite the impact that the TPP would have on nearly every aspect of our lives, the TPP is being negotiated in near complete secrecy. None of the draft chapters of the agreement have been made public, and the only people with access to texts are a handful of government officials and hundreds of “trade advisors” who almost exclusively represent multinational corporations.

One of the dirtiest secrets of the TPP is its potential to pave the way for dramatically increased fracking across the United States. See, An Explosion of Fracking? One of the Dirtiest Secrets of the Trans-Pacific Partnership Free Trade Agreement Sierra Club, https://www.sierraclub.org/sites/www.sierraclub.org/files/uploads-wysiwig/TPP-LNG_Factsheet_Updated.pdf (last visited Feb 27, 2016).

Tacoma Mayor supports TPP

“She [Mayor] reiterated her support for the proposed free trade Trans-Pacific Partnership Agreement, . . .” See, Tacoma mayor looks abroad in 2016 State of the City speech | The News Tribune, http://www.thenewstribune.com/news/politics-government/article62322212.html (last visited Feb 27, 2016)

What has past combustion sources explained already

The U.S. Department of Energy (DOE) estimates that in the coming decades the United States’ natural gas (NG) demand for electricity generation will increase. Estimates also suggest that NG supply will increasingly come from imported liquefied natural gas (LNG). Additional supplies of NG could come domestically from the production of synthetic natural gas (SNG) via coal gasification-methanation. The objective of this study is to compare greenhouse gas (GHG), SOx, and NOx life-cycle emissions of electricity generated with NG/LNG/SNG and coal. This life-cycle comparison of air emissions from different fuels can help us better understand the advantages and disadvantages of using coal versus globally sourced NG for electricity generation. Our estimates suggest that with the current fleet of power plants, a mix of domestic NG, LNG, and SNG would have lower GHG emissions than coal. If advanced technologies with carbon capture and sequestration (CCS) are used, however, coal and a mix of domestic NG, LNG, and SNG would have very similar life-cycle GHG emissions. For SOx and NOx we find there are significant emissions in the upstream stages of the NG/LNG life-cycles, which contribute to a larger range in SOx and NOx emissions for NG/LNG than for coal and SNG. See generally, Comparative Life-Cycle Air Emissions of Coal, Domestic Natural Gas, LNG, and SNG for Electricity Generation Environ. Sci. Technol. 2007 , 41, 6290 – 6296, http://www.fe.doe.gov/programs/gasregulation/authorizations/2012_applications/sierra_exhibits_12_100_LNG/Ex._80_-_Jaramillo_2007.pdf (last visited Feb 27, 2016).

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Tacoma Hazards: Required ISO Quality Standards

Hazardous Process: Methanol: Requires Quality Process in Tacoma

What is ISO 9000 Quality?

Quality and hazards containment is a requirement to keep our Tacoma Community and people safe as possible from potential hazards; it follows international standards apply here at home to:

  1. Natural gas (methane gas);
  2. LNG Facility; and
  3. Methanol Facility.

Quality process for plant design, materials selections, construction methods, employee health and welfare, industrial process, computer process control all required ISO9000 compliance https:/en.wikipedia.org/w/index.php?title=ISO_9000&oldid=704628982 (last visited Feb 17, 2016)

We know when hazardous materials are processed, refined, and handled; as a result, the quality, security, and performance of all systems must be operated and available and ready with the least failures because otherwise the Tacoma Community is placed at risk as defined by Tacoma EIS.

The Tacoma Methane Facility is one such processing plant that contains and handles materials that present hazard to workers, local people, and community people; as a result, when things fail or fault. For example, methane, sour natural gas, sweet natural gas, piping systems, container systems, process control systems, fire suppression systems, computer systems, computer software and hardware, material handling system, and human error—all are fault factors necessary for quality audit.

Tacoma community will support a Methanol Facility

For a safe Tacoma Community, we need gas industries to use safe practices always. For example,

The industry handles hazardous fluids and gases through a variety of processes. Considerations of the safety of personnel, both staff and public, of the protection of the environment and of business continuity (maintenance of revenue streams, both for companies and for national economies) require a high level of operational integrity. A key element in the assurance of appropriate products being supplied is the quality management system operated by the goods supplier and service contractor. The experience of previous editions of API Q1 has proven that requirements additional to ISO 9001:2000 are necessary to provide assurance with respect to quality of products and services on a consistent and global basis. See, Quality management system for the oil and natural gas industry (2003-11-10) – ISO, http://www.iso.org/iso/home/news_index/news_archive/news.htm?refid=Ref879 (last visited Feb 17, 2016).

The New Tribune article reminds us about the soundness of the Methanol Facility operation

I agree, safe methanol system construction, materials used, the human control element and all automated control systems are necessary to make the methanol process operate within minimum failures.

See generally, Tacoma: Criticism of methanol plant unfounded thenewstribune, http://www.thenewstribune.com/opinion/letters-to-the-editor/article60665661.html (last visited Feb 17, 2016).

 

It follows, quality is necessary when building and processing gas industrial hazards

Therefore, the Tacoma EIS must mandate all Tacoma gas processing must be compliant with ISO9000 standards and have the audit trail to prove compliance to community for their safe Methanol Facility operation does exist. ISO9000 compliance audit trail will provide the necessary compliance for:

  • Engineering planning activities;
  • Selection of materials used to contain sour methane gas;
  • Piping and safety shutoff valves and shutdown systems;
  • Mitigation plans validated for community hazards protection;
  • Process manual and automatic control systems;
  • All written procedures defined and audited for correct procedures in the event of an unusual event at the Methanol Facility;
  • All computer software audited to current ISO computer hardware and software standards with back up parallel operating control systems in event of computer software or hardware fault.
  • All employee training audited to ISO standards comparable to hazards present within the Tacoma Methanol Facility.

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Cove Point: LNG: Just Information

Tacoma and other communities have LNG as a common concern

Our Tacoma LNG facility already has received Tacoma SEPA FEIS status and do we even understand what the means to Tacoma environmental health? And how do we know?

Stop Cove Point: Another Community: No Fracked Gas Exports

Just a interesting article: Chesapeake Climate Action Network, Stop Cove Point: No Fracked Gas Exports, [accessed 16 February 2016].

So where is Cove Point at today?

let’s take a look: ‘Dominion Cove Point’ Dominion Cove Point, (construction updates available) [accessed 16 February 2016]

We are going to have a LNG facility here in Tacoma Washington also; therefore, wheat can we learn for other communities? Let’s take a look.

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Just some relational thoughts about natural gas

Just playing-around with Venn Diagrams. However what’s missing is

  • Natural gas (methane gas) process burning flares for both Methanol and LNG facility;
  • Things that fly in the sky (birds) near a natural gas (methanol gas) burning flare(s);
  • Truck and road traffic impact;
  • People that are close by to the facilities.

However, it’s the relational thought to visualize.

Tacoma: LNG: Methanol: Sour-Gas Supply

To: mailto: Tacoma.methanol.sepa@cityoftacoma.org

Sunday, February 7, 2016

EIS Scoping Comments: Tacoma Manufacturing and Marine Export Facility (TMMEF): “Proposed Methanol Plant”: SEPA Lead Agency: City of Tacoma (File No. SEPA2015-40000260025).

My comment applies to SEPA and this Environmental impact statement (“EIS”) related to the natural gas supply feeding the Methanol Facility.

Given, we are able to determine that the natural gas feeding the Tacoma Methanol Facility will be towards the sour gas spectrum because this same gas distribution piping supply system is proposed also feeding the Tacoma LNG Facility. Therefore:

2.2.1.2 Natural Gas Delivery and Pretreatment Systems

Natural gas would be delivered by a distribution pipeline and metered before it enters the Tacoma LNG Facility. Natural gas, upon delivery and prior to conversion to LNG, must be conditioned. This entails the removal of any constituents other than pure methane. These constituents could include ethane, propane, butane, and other heavy – end hydrocarbons, as well as minor quantities of nitrogen, carbon dioxide, sulfur compounds, and water. The pretreatment system would consist of amine gas treating and regeneration, a gas dehydration system, outlet gas filtration, and an intermediate heat transfer fluid system. As part of the pretreatment process, carbon dioxide and sulfur compounds removed from the natural gas would be flared through a ground flare system described in Section 2.2.1.7 (Other Process Facilities). Heavy hydrocarbons are used as fuel gas to the maximum extent possible, also described in Section 2.2.1.7. When operating conditions are such that all of the heavy hydrocarbons are not used as fuel gas, the components are sent to a holding tank. Periodically, this holding tank would be emptied and its contents transferred to a truck and taken off site for disposal or sale to a third party for use as fuel. See, PSE DEIS Chapter 2 Description of Proposed Action.pdf (at 2.3), http://cms.cityoftacoma.org/planning/pse/PSE%20DEIS%20Chapter%202%20Description%20of%20Proposed%20Action.pdf (last visited Feb 7, 2016)

As a result, it is known that Tacoma LNG Facility the gas has stuff within gas supply that must be removed prior to conversion process, but this cleaning of gas indicates this is sour-natural gas and “Sour gas is a natural gas that contains significant amounts of hydrogen sulphide (H2S). It is extremely poisonous to humans and animals even in small quantities, corrosive, flammable and smells like rotten eggs.” Also, people have been evacuated to safe areas because of sour gas release into environment. See, All About Sour Gas The Huffington Post, http://www.huffingtonpost.ca/2013/06/20/sour-gas-hydrogen-sulphide-hs2_n_3473666.html (last visited Feb 7, 2016)

My comment: Two comments, two environmental EIS issues: 1) If Methanol Facility incoming natural gas (methane gas) piping distribution system develops leaks and if this gas is sour gas; as a result, will there be sufficient H2S (hydrogen sulphide) content to cause environment hazard to community (people) from this escaping gas—once smelled then becomes just odorless—killer gas; therefore, human health environmental risk; 2) Sour gas is more corrosives; therefore, requires special materials to withstand H2S gas caused materials and piping failures; therefore, gas containment materials environmental risk that requires necessary materials to contain sour gas and protect my Tacoma Community. See generally, Hydrogen Damage – Metallic Corrosion, http://www.azom.com/article.aspx?ArticleID=104 (last visited Feb 7, 2016).

John Sherman

4601 N 26th St

Tacoma, WA 98407-4605

Email: jmjsherman@gmail.com

Johnesherman.com

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Procedural: Wash. Natural Gas Industrialize

A great article that presents events chronology

In Tacoma my and other people have a narrow focus about Community issues that potentially affect us with proposed new Port of Tacoma Natural Gas (methane gas) industries: 1) Natural Gas supply piping distribution system; 2) LNG Facility; and 3) the Methanol Facility. All three under consideration for necessary permits to construct and operate within the Tacoma Community.

I think this: every once-in-awhile we must all step back and look at the larger natural gas industrial development beyond our local Community and view what is going on in the rest of Washington State as our Washington State Government is promoting. See, dePlace, Eric, and Adjorlolo, Maoulay., What Methanol Means for the Northwest, (Sightline Institute), (2015) online at http://www.sightline.org/2015/08/17/what-methanol-means-for-the-northwest/ [accessed 6 February 2016].

This article will give more-insight into the natural gas industrial facility(s) planned for Washington State and Oregon. Great overview article that connects all the “dots” to who is doing just what where (that we know about).

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Tacoma Methanol Facility: Methane to Burn

To: Tacoma.methanol.sepa@cityoftacoma.org

Saturday, February 6, 2016

EIS Scoping Comments: Tacoma Manufacturing and Marine Export Facility (TMMEF): “Proposed Methanol Plant”: SEPA Lead Agency: City of Tacoma (File No. SEPA2015-40000260025).

My comment applies to methane-to-methanol conversion process and combustion airborne inventory added—Methanol facility: “The applicant has stated 70% of natural gas will be converted to methanol, while the remainder will be combusted to produce energy for the chemical processes. Emissions associated with this combustion process will need to be disclosed.” See, Methanol EIS Draft Scope of Work 02052016.pdf (p. 5:n.8), http://cms.cityoftacoma.org/planning/Methanol%20Plant/Methanol%20EIS%20Draft%20Scope%20of%20Work%2002052016.pdf (last visited Feb 6, 2016).

In this case, we see “According to the U.S. Energy Information Administration ( EIA ) , . . . With about 100 cubic feet of natural gas needed to produce one gallon of methanol, . . .” See accord, Methanol: The Clear Alternative for Transportation – Methanol-Flexible-Fuel-Vehicles.aspx Methanol Institute, http://www.methanol.org/Energy/Resources/Alternative-Fuel/Methanol-Flexible-Fuel-Vehicles.aspx (last visited Feb 6, 2016).

Therefore, “One metric ton of methanol (2,204.62 lbs) = Approximately 333 U.S. gallons.” See, SCC – Southern Chemical Corporation » Methanol FAQ’s Southern Chemical Corporation, http://www.southernchemical.com/wp/safety-environment/frequently-asked-questions (last visited Feb 6, 2016).

As a result, My factoring, I find: (7.3-million metric tons / 333gallons) * 100-cubic feet natural gas = 2.2-million cubic feet of natural gas required with 70% conversion process; as a result, 0.9-million cubic feet of natural gas is burned or combusted and added to the airborne combustion byproducts inventory. (See, Tacoma “Draft”, Supra, P 2:n. 4).

My comment is this: With 1-million cubic feet natural gas (methane) combusted (burned) and added to Tacoma Community airborne chemical inventory; as a result, how does that compare with the average Tacoma homeowner using natural gas for heating and cooking with their airborne chemical inventory contribution? We have yet to be informed: will the Methanol facility consume “sweet- or sour-natural gas (methane)” because the amount of chemicals entrained within the natural gas stream is more with “sour-natural gas (methane)” and must be cleaned and the residue from cleaning sour-natural gas (methane)’ must go somewhere?

This “Draft” (Feb. 5, 2016) presents “[T]he EIS will not be designed to disclose every molecule of impact or capture every emission. That is an inefficient use of resources. . . .” (Supra, “Draft” p. 4). I disagree because if you are a person that is harmed by a fugitive Methanol Facility chemical molecule then a harm is a actual harm. See also, Soot Wikipedia, the free encyclopedia, https://en.wikipedia.org/w/index.php?title=Soot&oldid=702882659 (last visited Feb 6, 2016). Therefore I would suggest you don’t list the human health harm details but list every chemical molecule that will be fugitive from the Tacoma Methanol Facility processes. Just list all chemicals that will become introduced into the Tacoma Community airborne inventory caused by Methanol Facility!