The January 5, 2003, TOM BUTT E-FORUM commented on and reproduced an article in the Contra Costa Times about gross underreporting of flare pollution by Bay Area refineries. According to the article, "The largest Bay Area refinery, ChevronTexaco in Richmond, so poorly monitored flows into its flares that air district engineers did not include the plant in its estimates. A spokesman for the company could not be reached last week."

Chevron has now responded, and the following information was provided by Tom Mann, refinery Technical Director:

Thanks for asking about the recent article on refinery flares that appeared in the Contra Costa Times. Below is more detailed information provided to the refinery’s employees. I hope you will take the opportunity to share this information when asked by friends, neighbors, and family members.

The article was based upon a BAAQMD draft report that is still undergoing review. The draft report currently recommends increasing the BAAQMD's current emissions inventory estimate for flares from 13 tons to 22 tons. The methodology for estimating the figure of 22 tons per day has not been finalized and does not consider all available existing data. Unfortunately, the warning to not "cite or quote" included in the draft report was ignored.

We believe the study measure will conclude that existing available data does not support the 22 tons per day estimate. Chevron’s Richmond Refinery has a good environmental record that should be fairly reported.

Setting the Record Straight on Air Emissions from Refinery Flares

Background

Many of you have read the January 5th article in the Contra Costa Times regarding the use of flares at the Bay Area refineries. The article reported that the Bay Area Air Quality Management District (BAAQMD) had revised its estimates of air emissions from flares at the five Bay Area refineries from 200 pounds per day to a daily rate of 22 tons. This estimate comes from a draft report that is part of a collaborative effort between the Bay Area refineries, the BAAQMD, and the public to accurately determine refinery flare emissions and identify opportunities to apply appropriate, cost effect emission controls.

Flares are used as a safety and emission control mechanism when gasses cannot be recovered during process unit startups or emergencies. We believe that flares are an environmentally sound and reliable means of maintaining safe operations, but continue to look for opportunities to reduce our use of flares. In fact, the refinery should be commended for its success in reducing flare usage over the past few years.

Another view

· In my reading of the report which, I include for you, the Summary findings on page 8 suggest the emissions from flares move from 13 tons per day to 22 in the Bay Area. The news article suggested 200 pounds per day was the previous baseline. I have no idea what the source of that data is, but it is not consistent with the BAAQMD draft report as I understand it.

· We believe that 22 tons per day is a grossly excessive estimate of the actual emissions from flares, and we are working with the Air District to refine the technical assumptions they used to calculate these emission levels. But for the moment, using the basis in the draft report, emissions from the Richmond Refinery Flares are estimated by the BAAQMD to be an average of 2 tons per day. That would make the total for the Bay Area 24. The industry break down is:

Tesoro 13 tons per day

PhillipsConoco 4 tons per day

Shell 3 tons per day

Valero 2 tons per day

Chevron 2 tons per day

These rates are not normalized by throughput. If that is taken into account, our emissions are an order of magnitude better than even the next closest refinery on the above list.

· The Times article also stated that Chevron’s flare monitoring data could not be included in the estimate because we do not adequately monitor our flares. Our flare monitoring information is accurate and was submitted, but the District chose not to include our data in the initial draft of their report, yet in the current version attached our data is included.

· The news article would lead readers to believe that flare emissions are a substantial source of pollution in the Bay Area. Managing flares is an important effort in reducing air emissions, but flares are only a portion of the 500 tons per day produced by man-made sources and the 300 tons per day that occur naturally. Although refineries produce less than 3 percent of the Bay Area’s ozone-forming compounds, we are committed to working with the BAAQMD to lead the effort to improve our air quality.

BAAQMD Draft Report on Flare Emissions

Tom Mann, Technical Manager

Chevron Products Company
Richmond Refinery
841 Chevron Way
Richmond, CA 94801
Tel 510 242 3887 Fax 510 242 3515

mail to: tgmann@chevrontexaco.com

A ChevronTexaco Company