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