Letter To US EPA July 30, 2007

·July 3O, 2007

RE: Murphy Oil USA, Inc Meraux, LA 70075
AI Number 1238, Permit Number 2500-00001-V2, Activity Number PER2C05C006

We have in this past week, recently learned of the availability of EDMS
on the Louisiana DEQ website. In light of this new information
regarding the location of the proposed tanks and the continuous ongoing
nuisances and violations of many permits at the Murphy Refinery, Meraux
LA, WE URGE YOU not to allow this proposed expansion of processes and
more storage tanks. According to Louisiana Law, a regulatory permit may
not authorize the maintenance of a nuisance or a danger to public health
or safety. All emissions control equipment shall be maintained in good
condition and operated properly. Murphy has demonstrated it has done
neither.

Please review our comments Opposing this Permit from the June 19, 2007
LEDQ Public comment Hearing regarding Murphy Refinery's Proposed Permit
for Expansion (available at LDEQ - EDMS website document 36057433 dated
6/20/07) and the transcript from the public hearing (document 36118975
dated 6/19/07).
.
The Totality of Emission is not safe
The Clean Air Act requires major sources of air pollution to obtain
pre-construction permits before making changes that would result in a
significant emissions increase of an pollutant; requiring the
installation of the best available technology and pollution control
equipment which will yield the lowest achievable emissions level. These
modifications proposed in the renewal of the air permit (even with its
questionable emissions trading and contemporaneous baseline) states "NOx
emissions increase is significant due to theses projects."

The projects will have "significant increase" in NOx emissions and
increased in SO2 emissions. Murphy states in LDEQ - EDMS document
35772816 dated 3/06/07 "Any decreases in Nox and SO2 emissions will not
occur until 2008/2009 and will be through the Revamp of #2SRU." This
#2SRU has been noted numerous times in incident and unauthorized release
reports at this LDEQ - EDMS website. Most recently on July 12, 2007
incident #97825, document 36145560 dated 7/20/07 "corrosion damage"
#2SRU shutdown.


Most other emergency and unauthorized release incidents note "plugged
with Katrina Debris" (incident #91403 on 10/16/06 document 35632280
dated 1/12/07) or other references to hurricane damage not yet repaired
("After Hurricane Katrina most of the instrumentation in the tank farm
was damaged.: incident #92042 on 11/14/06 document 35602119 dated
1/12/07).

Over 12,000 pounds of S02 was released from 5/13/07 - 5/22/07 (Document
96333 dated 5/25/07). By allowing this refinery to operate with faulty
equipment the pollution controls are continuously bypassed. The
pollution controls themselves are not maintained in good condition nor
operated properly.

The Total SO2 emissions from this refinery just in recent months is
TOXIC.
Having recently learned of LDQ's EDMS availability to the public in late
July 2007, one should be astonished at the level of SO2 emitted by this
refinery in recent months. Unknown levels of hydrocarbons and benzene as
well. Even with limited understanding, it appears most all of the
emergency and unauthorized spills and releases are due to Katrina Damage
Not Corrected (even at this late date) and / or faulty equipment allowed
to be patched but not overhauled nor corrected. By allowing this
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LDEQ-EDMS Document 36207258, Page 3 of 5
.. ;
refinery to operate faulty equipment the residents of St Bernard Parish
are placed in a very dangerous, toxic and noisy environment.
It is the NOISE of this faulty equipment that enters our homes. It is
interesting to note that there are NO entries in the DEQ incident log
for March April and early May 2007, yet that is the time we camcorded
the events which were setting off wireless doorbells, vehicle alarms and
shaking our windows as far out as seven blocks from the refinery. While
not certain, we have the fear that the entire refinery operated at that
time with no pollution controls, or with such faulty equipment that the
refinery knowingly exposed us to toxicity. Certainly, due to the level
of noise, they ran the operation processes without quality assurance.
We were continuously told it was the normal noise level for ongoing
processes; that they had not changed anything on the refinery campus in
the 15 years since we moved here; and then we were told it was a faulty
compressor and faulty hydrocraker. Later we learned the hydrocracker
was taken off line in June 2007 for a repair to a hole. The compressor
is still not restored, as we witness flaring with black and white smoke
as an ongoing part of the operations, not just emergencies.

We noticed the log of incidents is complaint driven; placing the burden
of monitoring on the residents. We have requested independent
monitoring (air and video with tape) to be moved closer to the source;
perhaps on Despaux and MaryAnn Trailer Drives of Despaux and Mytrle
Grove Drives. We have also requested the Citizens Advisory Board be
open to the public.
.
Louisiana State Law
A regulatory permit may not authorize the maintenance of a nuisance or
a danger to public health or safety. All emissions control equipment
shall be maintained in good condition and operated properly.

State Noise Laws
RS 30:2051 "Louisiana Air Control Law"
RS 30:2052
NOTE: Paragraph (7) as enacted by Acts 2006, No. 445, §3, effective
July 1, .2007.
{7} To adopt and promulgate rules and regulations establishing and
implementing a comprehensive program for the control and abatement of
environmental noise pollution. The regulations shall be consistent with
applicable federal laws, rules, and regulations and, at a minimum, shall
provide fro the following:
(a) Criteria and standards for noise control and abatement.
(b) Levels of noise appropriate to defined areas under various
conditions.
.
TANK FARM EXPANSION
The Tank Farm is a source of toxic odors without relief. "Primary seal
of Tank 250-3 failed....4/12/07" as reported by Murphy in Document
35955308 dated 4/19/07. LDEQ Public Hearing Exhibit #5 Document
36057433 dated 6/20/07 shows the toxicity level of benzene our school
children will be exposed to twice daily commuting to the new Middle
School in August 2007. The only High School Campus is within walking
distance. Adding more uncontrolled tanks is unacceptable. LDEQ - EDMS
Document 3578982 dated 1/05/07 refers to a December 30, 2005 report
which discloses "discrepancies in the type of seals installed on several
storage tanks at "the refinery and indicates "Murphy had knowledge of
the violations since December 21, 2001."

These Storage Tanks are proposed for an area of land adjacent to the
Levee System which failed in the Hurricane of 2005 (Katrina, August 29,
2005) Document 36143926 dated 6/26/07. These Tanks are also within
yards of an existing subdivision that is trying to revitalize the
community and restore their family's lives.

It's time the US EPA change the regulations and requirements for refinery
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LDEQ-EDMS Document 36207258, Page 4 of 5

and chemical storage tanks that are allowed in flood plains. Coffeyville
Kansas is one such example. Our own experience with the crude oil spill
in Chalmette, LA brings several issues to light. Even if the refinery
was in compliance with federal regulations, they did NOT implement their
hurricane preparedness plans. The Federal Regulations are not adequate.
The tanks have been allowed too close to residential neighborhoods.
Flood Plains will Flood and at times it will be catastrophic; and this
flooding will happen whether the EPA anti-spill plan requires facilities
to prevent inundation from catastrophic flooding or not.

It is most irresponsible for EPA, DEQ and the refinery to expand the
tank farm in this flood zone, within yards of a subdivision, adjacent to
a Levee System, on what currently appears to be Wetlands. The results
are a given. It is reckless of the refinery to expand the tank farm,
knowing the results. Yet, it is not a surprise that the refinery will
justify their irresponsibility by claiming they are at least in
compliance.

In keeping with the mission of the US EPA Superfund Cleanup of the Crude
Oil Spill site, we urge US EPA to continue its endeavors to assist us in
this revitalization and restoration of our community. We urge US EPA not
to allow these expansions until they can be done without additional
danger, noise, emission and nuisances.

Respectfully Submitted,

Suzanne Kneale
2114 Corinne Drive (South)
Chalmette, LA 70043

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