RPVCCA_CC_SR_2015_06_02_C_Border_Issues_Status_ReportMEMORANDUM
TO: HONORABLE MAYOR & CITY COUNCIL MEMBERS
FROM: CAROLYNN PETRO, AICP, DEPUTY CITY MANAGER®
DATE: JUNE 2, 2015
SUBJECT: BORDER ISSUES STATUS REPORT
REVIEWED BY: DOUG WILLMORE, CITY MANAGER M11-1
Project Manager: Kit Fox, AICP, Senior Administrative Analyst
RECOMMENDATION
Receive and file the current report on the status of Border Issues.
EXECUTIVE SUMMARY
This month's report includes:
• An update on recent issues and events related to the Rancho LPG butane storage
facility in Los Angeles (San Pedro);
• An update on the proposed 4 -unit detached condominium project at 5883 Crest
Road in Rolling Hills Estates;
• An update on the possible closure of the Defense Fuel Support Point San Pedro
in Los Angeles (San Pedro); and,
• An update on proposed upgrades to the Palos Verdes Reservoir in Rolling Hills
Estates.
BACKGROUND
The following is the regular bi-monthly report to the City Council on various "Border
Issues" potentially affecting the residents of Rancho Palos Verdes. The complete text of
the current status report is available for review on the City's website at:
http://www. rpvca.gov/781 /Border -Issues -Status -Report
1
MEMORANDUM: Border Issues Status Report
June 2, 2015
Page 2
DISCUSSION
Current Border Issues
Rancho LPG Butane Storage Facility, Los Angeles (San Pedro)
In the past two (2) months, interested parties have continued to forward items regarding
and related to the Rancho LPG facility via e-mail. Copies of these e-mails are attached
to tonight's report. Staff will continue to monitor this project in future Border Issues
reports.
5883 Crest Road Condominium Project, Rolling Hills Estates
The Rolling Hills Estates Planning Commission is scheduled to consider a slightly -revised
version of this 4 -unit project at the northeast corner of Crest and Highridge roads on
Monday, June 1, 2015. Staff plans to attend this meeting and provide a further update
as "Late Correspondence" at tonight's meeting.
Closure of Defense Fuel Support Point San Pedro, Los Angeles (San Pedro)
On April 1, 2015, Staff submitted the attached comments on the scope of the draft
Environmental Assessment to the Navy. Staff will continue to monitor this project in future
Border Issues reports.
Palos Verdes Reservoir Upgrades Project, Rolling Hills Estates
On April 10, 2015, Staff submitted the attached comments on the draft Mitigated Negative
Declaration to the Metropolitan Water District. Staff will continue to monitor this project
in future Border Issues reports.
New Border Issues
There are no new Border Issues on which to report at this time.
Attachments:
• E-mails related to the Rancho LPG facility (miscellaneous dates) (Page 3)
• Comments on Draft EA for DFSP San Pedro closure (dated 4/1/15) (Page 36)
• Comments on Draft MND for Palos Verdes Reservoir Upgrades Project (dated
4/10/15) (Page 38)
MABorder Issues\Staff Reports\20150602 Borderlssues_StaffRpt.docx
2
Kit Fox
From:
Janet Gunter <arriane5@aol.com>
Sent:
Monday, April 20, 2015 10:29 PM
To:
darlenezavalney@aol.com; rreg55@hotmail.com; sarahnvaldez@gmail.com;jdimon77
@yahoo.com; president@centralsanpedro.org; heather.hutt@sen.ca.gov;
Lara.Larramendi@mail.house.gov; lisa.pinto@mail.house.gov; Kit Fox;
jnm4ej@yahoo.com
Cc:
rob.wilcox@lacity.org; Ion na@cope- prepared ness.org; jones@usgs.gov;
fmillar@erols.com; d.pettit@nrdc.org; amartinez@earthjustice.org;
wesling.mary@epamail.epa.gov; blumenfeldjared@epa.gov; meer.daniel@epa.gov;
david.wulf@hq.dhs.gov; abaker@sco.ca.gov; kgreeneross@sco.ca.gov;
noelweiss@ca.rr.com
Subject:
YouTube video Rancho LPG / Quest letter to Prof. Bea attempting to discredit
....Response attached.
Attachments:
Final Response+to+Ron+Conrow+by+Patchett+&+Bea.pdf
Remember one very important thing in reviewing these items..... No one on the side of the community is getting rich for
their services to help in this situation. Their interests are pure and without financial gain. This includes world renown
Professor Bob Bea. Motive on the side of our community representatives and all the experts volunteering their precious
time to assist in this effort... is for one thing only ....... the preservation of our lives, our ports and our communities. Any and
all efforts are specifically aimed at preventing the catastrophe that is promised from our own recklessness in ever
introducing this facility.
Paid consultants and lobbyists on the Rancho LPG /Plains All American Pipeline/ Plains Midstream Canada side... to
defend and insulate their operation from scrutiny... are being paid many thousands or even hundreds of thousands of
dollars for their intervention and services. This is something that should not be dismissed when investigating this
matter. The consequences to be paid for ignoring the real truth of disaster potential here are going to be deadly.
Janet Gunter
See original letter sent to Professor Bea below.
Rancho LPG : Quest documents.pdf
9
ReCHO
LPG Holdings LLC
April 09, 2015
Professor Robert G. Bea
60 Shuey Drive
Moraga, CA 94556
Subject: YouTube video about the Rancho LPG Facility in San Pedro, CA
Dear Professor Bea,
It has come to our attention that an inflammatory video trailer about the Rancho LPG facility located
at 2110 North Gaffey Street in San Pedro, CA has been posted on YouTube titled Sizzler for Masters
of Disaster documentary, (https://www.youtube.com/watch?v=TBGt XKNpRk published March 15,
2015. We are concerned not only about the inflammatory nature of this video, but the fact the
claims portrayed in the video by you and other commenters are lacking proven scientific
information required to quantify exactly how the events described in the video can even happen.
As a result, we have commissioned Quest Consultants Inc., an engineering and process safety
consulting firm with considerable worldwide experience in preparing such studies for Liquefied
Petroleum Gas storage facilities, to review the video. Attached to this cover letter is Quest's review
and findings regarding many of the outrageous and unquantified claims contained in the video.
As a respected forensic engineer, you should be able to provide the technical information to support
your claims and those of the other video commenters. However, given past experiences with a
prominent anti -Rancho opponent and video commenter, perhaps some of the comments by you
may have been taken out of context or conceivably you are not aware of the YouTube video?
However, if you support the claims contained in the video, it should be quite simple for you to
produce quantitative validation required to defend the positions of you and the other video
commenters. The questions posed by Quest are straightforward (no gotcha questions) with the
intention of scientifically explaining how an event can or cannot happen. The residents of San Pedro
concerned about "public Safety" are deserving of facts based upon science and not rhetoric!
Sincerely,
Ron Conrow
`P
4CO "k.ar
Western LPG District Manger
Plains/Rancho LPG
I.
QUEST,
CONSULTANTS INC.
April 7, 2015
Mr. Ronald Conrow
Rancho LPG Holdings, LLC
2110 North Gaffey Street
San Pedro, CA 90731
Re: Review of YouTube video
QCl Project 6774
Dear Mr. Conrow:
Quest Consultants inc. (Quest) has completed a review of the miraclegirlprodcutions YouTube video
titled Sizzler for• Masters of Disaster documentary, published March 15, 2015. -chis video production
(haps://www.youttibe.com/watcli?v=TBGt XKNpRk), henceforth referred to as the "Video', claims to
describe and quantify the risks associated with the existing Rancho LPG Holdings, LLC (Rancho) facility
located on North Gaffey Street in San Pedro, California. Quest's review of the Video addresses specific
assertions made in the Video.
One of the principal speakers in the Video is Dr. Robert Bea. Dr. Bea is a retired University of California
professor who worked in the Civil and Environmental Engineering Department. Dr. Bea is a respected
forensic engineer who lends his voice and opinions to the Video.
There are several instances in the video where the continents presented by Dr. Bea may have been taken
out of context. if this is the case, it will be straight -forward for Dr. Bea to identify the text as inaccurate
and present the correct text. if this is not the case and Dr. Bea's comments are presented accurately in the
Video, then Dr. Bea should be able to provide the technical information supporting his position. The text
below taken directly from the video is show in italics.
Dr. Bea: "Rancho is a veil, volatile, explosive, flammable gas. "
Dr. Bea: "It also hen very high risk because of the population and community Thal surrounds it. "
Dr. Bea: "Orae of the tanks fails, within a three mile radius of Thal Intik approximately a half a million
people live. That 's high risk. "
Dr. Bea: "A large amount of propane in storage tanks that can be affecled by strong eoriliquakes,
ignited, thca'S a natural ha=at-d, or' hurncnr hazards; hubris, arrogance, greed, ignoi•dmce, and indolence is
a disaster sooner or laser. "
MAILING P O BOX 721357 XOR- M. OK 73070.8069
5111P'I VG 908 26"' AVENUE \1Y. SUITE 103 NORMAN. OK 73069
TELEPHONE (405) 329.7475 FAX t405) 329-7731
E-mail w rul?qucstconsult.com
5
Mr. Ronald Conrow
April 7.2015
Page 2
These four quotes, directly attributable to Dr. Bea will be discussed below. In addition to the quotes
attributable to Dr. Bea, there are other quotes in the Video that require a review. Since Dr. Bea is a
willing participant in the Video, he must agree with the other quotes presented in the Video. As each
quote is presented and discussed, Dr. Bea should be asked whether he agrees with the quote as presented,
or asked to correct the quote/information presented.
Other quotes in the video not attributed to Dr. Bea.
"There is no waY lv make these tanks safe_ "
"Imagine a Now at the Los ,Angeles harbor the size offfy atomic boutbs. Afire that catmot be part out
ivith «rater that irould !rigger a cascading htferno igniting the mullitucle of storage Tanks, pelroleum
factories, unclergrnamd gas pipes, ctrttl evervlhing in its path. "
"ff'e've got tiro ullrahazardous hutane tanks containing aver 23 million gallons and propane bullet tanks
containing 300,000 gallons. "
" hnagine hots, easily these lanky cam he penetrated by a rockel launched grenade or a high po►rea-ed
r-ille. "
"These ranks are a qucn7eranile from the Los Angeles harbor and would make a high-value large! for tare
terrorist "
"These /auks are built o u stnud baaaks called lique_faclion areas. Ther stcnrd 130 feel from ca ratpture zotue
with a potential ?.3 magnitude quake at laird "
"This propane and butane is store cl above ground in rer-igeraled tanks and when the liquid is ejwsed to
air, it immethateli, vapvwizes to over 230 times its original voltane. ,I leak.Ji-om a rtgplur-e it-oulcl /foal
clown the sand bank. into. the sta-in drain, and spill oul into the harbor. "
"Butane and propane haat at tentperaua-es holler than 3,200 degrees and caanrol he extinguished hy
►rater. No one, nol even fu•eftghtet.s, can approach the blaze. "
Quotes directly attributable to Dr. Bea
The following questions for Dr. Bea will focus on the physical state of the Rancho LPG lacility. the
products stored, and the application of these statements to (his facility. The intent is to have Dr. Bea
demonstrate his expertise in this area by either supporting one or more statements in a technical manner.
or by disagreeing with one or more statements in a technical manner. Each of the quotes above will be
analyzed individually.
The first quote by Dr. Bea is, "Rancho is a very volatile, etplosive../lantmable gas. "
Clearly. the Rancho facility, is not a gas. but the Rancho facility (toes store flammable liquefied gases
(propane and butane in liquefied form). It would be beneficial to educate the listener that volatility only
applies to liquids (or some solids that sublime like carbon dioxide) but not to gases. Other common
materials are both volatile and flammable. Materials such as gasoline. diesel. kerosene, acetone. and ethyl
alcohol, are all volatile liquids and are quite common and, once vaporized. will produce a flammable gas.
If a material is flammable, it can be involved in an explosion. Thus, all the materials outlined above are
also "explosive."
Q 1.1 E T
Al
Mr. Ronald Conrow
April 7, 2015
Page 3
Dr. Bea, would you agree with the statement above? If not, what is technically wrong with this
statement?
The second quote by Dr. Bea is. "It also hers rery high risk hecause ojNte population and connnrod1j, that
surrountLc it. "
The statement is made in reference to Rancho being "high risk" due to the population around the facility.
Since risk is a product of consequence and frequency, in order to make the statement above, Dr. Bea must
have calculated both components of risk. as well as defined what "high" means in regard to risk. Since
this exercise must have already been completed by Dr. Bea in order to make such a statement, it should be
straight -forward to identify the following components that make Rancho a "high risk" facility.
Component I - Consequences used in the risk calculation.
• What accident scenarios were considered?
o Which materials were released?
• How were the materials released?
• What were the initial conditions of the released materials?
• In terms of potential impact on the public, which single consequence affected the largest number of people?
o How was this particular event modeled?
• What "cascading events- or domino events were evaluated?'
• What models were used to quantify the extents of the potential hazards associated with the released
materials?
• What hazard levels (e.g.. kW1m' for fires) were used in the modeling of the potential hazards and what do
they define (e.g., injury, mortality)?
o Since people were the subject of the "high risk" statement, these hazard levels should be
appropriate for people.
• Please describe how the presence or absence of people affected the consequence calculations.
Component 2 - Frequencies used in the risk calculation.
• for each originating release identified in Component I, there is an associated frequency. For instance, if
catastrophic failure of a refrigerated tank holding butane is one of the scenarios evaluated, theft you must
have calculated the event frequency of such a failure. If the total frequency of such an event is comprised
of several independent frequencies, then you must have values for each independent event. For instance.
for the catastrophic failure of a single refrigerated butane tank, you would have developed several
independent frequencies, as a minimum. One failure mechanism referenced in the video is soil movement,
please provide a list of independent events and the documentation supporting their failure frequencies.
o Catastrophic failure due to soil movement.
o Catastrophic failure due to ...
Catastrophic failure due to ...
• The same questions can be applied to the other vessels in the Rancho facility. Please provide the
supporting failure frequency information for each of the following vessels.
o Horizontal pressure vessels (liquefied propane and butane bullets)
c Railcars
<; Tank (nicks
• In the video, "cascading events" or domino events are referenced. In order to associate a risk to a
cascading event, you must have developed the frequencies of the events that, when combined, provide a
final frequency ofthe event caused as a result of cascading events. What cascading events did you develop
a frequency for, and how were they developed numerically?
QUEST
7
Mr. Ronald Conrow
April 7, 2015
page 4
For each initiating event frequency (e.g., frequency of pipe rupture), there are a number of distributions
(e.g., hole size as a function of pipe diameter), conditional probabilities (e.g.. immediate, delayed, or no
ignition), as well weather dependencies (e.g., low winds blowing from the northwest during stability D
conditions). Please describe the methodology used to incorporate this information. An example
calculation would be helpfiil.
Ilow was the presence or absence of people around the Rancho facility accounted for in the frequency
calculations?
Component 3 — Level of risk.
• According to your risk calculations, what are the numerical values of risk calculated around the Rancho
facility?
• What numerical value of risk is identified as "high?"
• What risk criteria are you referencing?
c The risk criteria for individual risk
o The risk criteria for societal risk
• Do these risk criteria define "high risk." and if so how?
The third quote by Dr. Bea is "One of dte tanks fails, uvithin a tlu-ee mile radius of that tank
approximately a half a million people live. That s high risk. "
• What does the "one tank fails" have to do with "within a three mile radius of that tank approximately a half
a million people live?"
o Did you develop an impact from the Rancho facility that could produce a hazard zone that extends
three miles from the Rancho facility?
• If so, what accident scenario was it?
■ If so, what hazard endpoint (e.g., kW/m').was used to define the impact?
■ If so, what does this hazard endpoint identify?
•
If so. what is the frequency associated with this event?
• If not, why did you make this statement?
The fourth quote by Dr. Bea is "A lin-ge innount of propane in storage lwrks Met/ can be affeeted by
slrong earthquakes, ignited, that's a ncam-al hazat dr or hronan hazards; hubris, arrogance, greet!,
igirorarrce, and inclolernce is a disasler sooner or later. "
• the propane is stored in the horizontal pressure vessels, the butane is stored in horizontal pressure vessels
and vertical refrigerated tanks.
If Dr. Bea modeled a vessel failure due to an earthquake, then he can provide
• Frequency calculation(s) for developing a failure of a horizontal pressure vessel during an
earthquake.
• Frequency calculation(s) for developing a failure of a refrigerated vessel during an
earthquake.
:i Dr. Bea's comment uses the word ignited. Are you. Dr. Bea, referring to a flash fire, torch fire.
pool fire, or vapor cloud explosion?
o The word hazard refers to -a chemical or physical condition that has the potential for causing
damage to people, property, or the environment." Thus, the fact that a flammable liquefied gas is
stored on site presents a hazard. Using this rational, every car on flue road or plane in the sky (or
on the runway) presents a hazard. Is that correct Dr. Bea.
Human hazards. Dr. Bea, please provide examples, relative to Rancho, on each of the human hazards you
identified.
Q V EV- "
�
•
Mr. Ronald Conrow
April 7. 2015
Page 5
o Hubris (arrogance caused by too great pride)
o Arrogance (full of or due to pride)
o Greed (excessive desire especially for wealth, avarice)
Ignorance (lacking knowledge or experience)
Indolence (idle, lazy)
• How did you quantify these hazards? Please identify methods and quantitative data for the following.
o Consequences associated with each human hazard
o Frequency associated with each human hazard
o tlow were these consequence/frequency pairs incorporated into your risk analysis?
Quotes not attributable to Dr. Bea but presented in the Video
The following quotes come directly from the YouTube video that contains Dr. Bea's comments
referenced above. Each quote is presented below and described. At the end of each quote's discussion,
Dr. Bea will be asked to agree or disagree with the quote.
Quote I - -There is no u•cn• to make these tanks sale. "
Safe is a relative term that has no universal numeric value. If the author assumes that -safe" means zero
risk, then nothing in life is safe. If Dr. Bea agrees with this quote, then he must have numerically defined
-safe' (as would be done in a risk analysis).
Dr. Bea, what is your numeric definition of safe and what reference do you have for it?
Quote 2 - "Imagine a blast at the Los Angeles harbor the size ql fifty alum c homhs. Afire that cannot be
put out with water- that would trigge►• a cascading inferno ignifing the multitude of storage tanks.
peirolennn factories, undergronuul gas pipes, and ereti-thing in its path "
The method of determining how much energy is in a fuel and equating that amount of energy to some
number of atomic bombs has been shown to be purposely deceiving. It requires the reader to believe the
following - The trees in the city park contain enough energy to be equivalent to X atomic bombs.
Clearly, no one would consider the trees in a city park to be equivalent to an atomic bomb. Thus, this
equivalent energy methodology purposely misleads the reader into think that something that is impossible
(e.g., all the trees in the city park "exploding" like an atotnic bomb) is actually possible.
This misleading energy equivalence method works like this;
• Calculate, using the (teat ofcombustion of the fuel, the total amount of energy in a tank, ship, train, car, etc.
For the purposes of Rancho, add the inventories of all the tanks together.
• The amount of energy in one Hiroshima atomic bomb is - 12.5 kT (I kT = 3.97(10)4 Btu)
• Divide the amount of energy of the fuel using the heat of combustion approach by the amount of energy in
one Hiroshima atomic bomb and you define how many Hiroshima atomic bomb energy equivalents are in
the subject material.
• This presentation if purposely deceiving since the 1(iroshinta atomic bomb's energy release was
instantaneous, and the energy of the fuel at Rancho (for instance) cannot be released instantaneously.
• Using this approach for Rancho (assuming all the tanks are 100% full of liquid, which they cannot be) finds
c 300,000 gallons of propane= 2.63(10)0 Btu (using the Gross H,) = 6.62 kT
0 25,000,000 gallons of butane = 2.65(10)" Btu (using the Gross H,) - 667 kT
o Therefore;
QUEST
01
Mr. Ronald Conro%v
April 7. 2015
Page 6
If all five horizontal tanks contained propane (they do not), the five horizontal tanks
would have the energy equivalence of 0.53 Hiroshima atomic bombs..
The two refrigerated butane tanks would have the energy equivalence of 53 Hiroshima
atomic bombs.
o Thus, the energy equivalence in liquefied gas storage at Rancho would be -53.5 Hiroshima atomic
bombs. However, the sequence of events that could lead to all the fuel in the Rancho facility
producing the atomic bomb effect is physically impossible, not just unlikely, impossible.
For the atomic bomb equivalence analogy to be true (as far as immediate destruction potential is
concerned), you would need to agree that the following is physically possible
o instantaneous vaporization of 100 % of the propane and butane in the Rancho facility (all seven
major tanks).
o instantaneous mixing of all vapor with air to stoichiometric concentrations.
o instantaneous compression of all flammable mass to about the size of a softball.
o Detonation of all flammable mass with 100 % yield.
Dr. Bea, do you agree that the situation described above is physically possible and accurately portrays the
destructive potential of the Rancho facility?
• In order to demonstrate how misleading the energy equivalence methodology is, consider Table I below.
The energy equivalence methodology was made for several common materials that one would easily argue
could not "vaporize instantaneously," yet that is (fie argument made above.
Dr. Bea. do you think fable 1 presents an accurate representation of the immediate destruction potential
of materials such as wood, coal, gasoline, and crude oil?
Quote 3 - "ft'e've got two ultrahazardous butane tanks containing "ver 25 million gallons and propane
bullet tanks containing 300.000 gallons. "
• There is no definition of "ultrahazardous butane tanks" or `ultrahazardous tanks" in general.
• This statement is simply made-up.
• The fact that propane and butane are stored in the Rancho tanks simply identifies the flammable fluids as
being hazardous. There is no definition of uhrahazardous in regard to flammable fuel storage.
Dr. Bea. would you define ultrahazardous in the way identified above? if so, please provide a reference
for the definition.
Quote 4 - "These tanks are a quarter -mile fi-oar the Los Angeles harbor and ►rould crake a high-iahie
target far ant.• lerrorist. "
• What evidence exists that these tanks qualify as a "high-value target for any terrorist?"
Dr. Bea, do you agree with this assessment, and if so, how was it modeled for consequence and frequency
in your risk analysis?
Quote 5 - "These tanks are brtill on sand banks called liquefcrclion ar-ras. Ther stand 150fieet_li•om a
rupture zone n•ith a potential 7.3 nxrgnilude quake at hand "
• Please provide references for the following.
., "file tanks are built on sand banks called liquefaction areas.
o Which rupture zone is 150 feet from the tanks?
Reference for 7.3 magnitude earthquake originating at rupture zone.
QUEST
10
Mr. Ronald Conrow
April 7.201
Page 7
Calculations showing how a 7.3 magnitude quake sone distance away (assumed to be 150 feet)
from the tanks affects the failure ofone or more tanks.
Dr. Bea, have you seen these calculations? If so, who did the calculations, and do you agree with them,
and are the consequences and frequencies included in your risk analysis? If you don't agree with them,
are these events excluded From your risk analysis?
Quote 6 - "This propane and bulane is slorecl above ground in rej-igeraled tanks and it -hen the liquid is
exposed to air, it immediately vaporizes to over 230 thnes its original volume. A leak front a rupture
u-ould Jloal down the sand bank, into the storm drain, rind spill out into the harhor. "
• The author of this quote could use sonic help.
o Propane and butane are stored in the horizontal pressure vessels.
o Only butane is stored in the vertical refrigerated tanks.
o The storage conditions for the propane and butane in the pressure vessels and butane in the
refrigerated tanks do not allow all of the released liquids to "immediately vaporize." This is
physically impossible. Consider the following.
■ Normal boiling point of nitrogen is -320 °F
• Normal boiling point of propane is -43.7 --F
• Normal boiling point of butane (n -butane) is 31.1 �F
o A common demonstration in high school chemistry classes involves the teacher spilling liquid
nitrogen on a lab table. The liquid boils and, over some period of time, it all vaporizes. This does
not happen instantaneously. Thus, if nitrogen with a boiling point over 275 °F lower than propane
and butane does not immediately vaporize, why would propane and butane act differently?
The authors appear to contradict themselves. If the propane and butane immediately vaporize, how can the
propane and butane "float" down into the harbor?
Dr. Bea, do you agree with the quote in the video? If not. do you agree that all the propane and butane
cannot "imntediately vaporize" upon release?
QUEST
11
Table 1
Energy Equivalence Methodology for Common Materials
12
Total Energy
Heat of
Storage Device
Material
Number of
Can Material Act
Total Mass
(heat of combustion
Material
Combustion
Storage Device
Volume or Total
Liquid Density
Hiroshima
Like an Atomic
(BTUAb)
Mass
(lblft)
(lb)
x total mUass)
Bombs
Bomb?
Propane
21.000
20 Ib cylinder tier BBQ grill
20 lb
{Prol arn)
20
420.000
0.0000085
No
Gasoline
>U,UOU
3o gallons (automobile gas tank)
equal to 4 it'
ft
45,4
Ire +ulur gusolinc)
181
3,620.Ut)U
0.000073
No
112 curd td 11x81tx211)or64ft'
5
Wood
6.000
or the anxtunt ot'wood loaned in a
64 It'
(Red Oak)
2.880
17.330.000
0.00035
No
pickup bed
Butane
21.200
Railcar (33.000gallons.85%Rill)
3750 it'
3ln.E36.0 6.0
utaRancho
135,000
2.862.000,000
0.058
No
Propane
21.000
horizontal pressure vessel,
082011'
31?
212.800
4.468.800.000
0.090
No
60.000glal.85%hill
(Pru ane)
57
Crude Oil
18.100
Railcar (33.000 gallons, 85" •° Bill)
.1,750 II
(California
213.750
3.868.875.000
0.078
No
crude oil)
Butane
21.20(1
Rancho horizontal Pressure vessel•
6820 tt
36.0
245.501,)
5,204,(i00,0(H)
O.IU
No
60.000 gal. 85%full
(n -Butane)
Railcar (I hopper car) holds I 10
55
Coal
14.000
lung tons
246.4(x) lbs
t
(��ntiacite)
246.400
3.449.600,000
0.070
No
0 10 x 2.240 lbs)
Gasoline
20.000
1 storage tank (60.000 barrels,
280.300 Ct
45.4
13A(x),000
260.000.000,000
5.24
No
85% Heli)
(regular gasoline)
100 railcar coal train
C'oul
11.000
(100 hopper cars x 110 x 2.2.10
24.040.000 lbs
(Anthracite)
24.640,000
344.960.000,000
6.95
No
lbs)
One Rancho rel}igeratcd storage
37.4
Butane
212oo
tank
1.420.50011'53,125.000
Ut-Buculc)
1.126,250.000.000
22.7
No
(12.5 million gallons. 85%fill)
I w1, Rancho ret'rigerated storage
37'4
Butane
211 200
tanks
2,84 LOW It'
in•Butane)
106,350.000
2.252.500.000.000
45.4
No
(25 million gallons, 85% lull)
I VI.C'C IvcrN large crude carrier.
1.000 legit long) with a capaelt\ of
{'
Crude Oil
18,100
300,000 DWI
672,1x)0,000 lbs
(Califiornia
672,000.000
12.1031.200.000.000
245
No
(dead \,,eight tons),
crude oil)
'lltc carrier holds 300.0(10 lung
tons
12
Mr. Ronald Conrow
April 2. 2015
Page 9
Quote 7 - "Butane and pn'opane hiaw cit lenperattn•es !totter than 3,200 degrees and cannot he
extinguished br traler. Ayo o)te, not even firdightem, can al)proach the blaze. "
• Again the author of this quote could use some help.
It appears the author may be referencing degrees Fahrenheit ff)
.. If so, the author appears to be referencing the adiabatic Flame temperatures for propane and
butane.
For comparison, the adiabatic flame temperatures for some common fuels are listed below.
•. Butane = 3578 T
• Hydrogen = 4010 V
Methane = 3542 T
■ Natural gas _ 3562 T
• Propane = 3596 T
• Wood = 35967
• kerosene = 3801 T
■ Bituminous coal = 3943 T
ne adiabatic flame temperature is a theoretical, not actual, flame temperature. It is produced by a
flame that loses no heat and assumes perfect, complete combustion. As you can see from the list
above, the adiabatic flame temperatures for butane and propane are similar to the adiabatic flame
temperatures for wood and coal.
• While it is true that putting water on a propane or butane pool fire will not extinguish the fire, there are
other materials that have the same behavior (Class B fires including gasoline, paint thinner, oils, e(c.) and
Firefighters are trained to extinguish these types of fires.
There isn't anything for Dr. Bea to continent on here. The author of this quote just does not have the
correct information.
In conclusion, a person of Dr. Bea's background should be able to do two things quite easily.
I. Produce the quantitative validation necessary to defend his stated position that the Rancho facility is a
"high risk" facility.
2. Review the comments from other speakers on the YouTube video. of -.%ltich he is a participant, and either
agree with their comments and conclusions, or slate they are in error and list the reasons why they are in
error.
A person with Dr. 13ea's reputation can only follow the path that is supported by science.
If you have any questions, please contact me directly.
Sincerely.
John B. Cornwell
Principal Engineer
QUEST
13
LAW OFFICES OF ANTHONY G. PATCHETT
P.O. BOX 5232
Glendale, California 91221-1099
818-243-8863 Fax 818-243-9157
Email: mrenvirlaw(j�),sbcglobal.net
RON CONROW
Western LPG District Manager
Plains/Rancho LPG
19430.13eech Avenue
Sbafter, California 93263
ronald.con.row@pla.i.nsniidsti-eam.coiii
April 20, 2015
RE: LETTER TO ROBERT BEA APRIL 9, 2015
Dear Mr. Conrow,
You indicated the questions propounded to retired professor Bob Bea were straightforward with
the intention of a search for the truth.
Professor Bea's attached responses are indicative of his years of experience in Catastrophic Risk
Management and his ability to give an assessment of risk regarding your facility
If you would be so kind to answer the following questions:
Was an exemption to CEQA Guidelines granted, when, and what was the reason for the
exemption?
0 Was the exemption based on economic or other factors? If so what were those factors?
* Was there a hearing, either public or private held regarding the exemption?
0 Was there an opportunity for public comment on the exemption?
* If a public meeting was held was it in compliance with the Brown Act?
0 If a private hearing was held, did the bearing comply with the Brown Act?
* Are there minutes of the hearing?
Did other local, state or federal agencies testify or make presentations at the hearing
regarding the exemption?
1
14
* Was there any public notice to residents of the exemption?
• Was the exemption disclosed to any investors as required under the California
Corporations Code?
# What happens if the refrigeration system fails in the tanks?
* I -low often is the refrigeration system inspected?
* Is there a back -tip system in place for the refrigeration system?
0 What is the inspection/maintenance schedule R)r the refrigeration system?
# Do the maintenance personnel have special qualifications or training?
• In reality, is Rancho's impound basin(represented as capable of capturing the contents of
one of the 12.5 million gallon butane tanks upon rapture) incapable of this action since
refrigerated "liquid" butane gas vaporizes and expands over 200 times its volume (as a
liquid) upon exposure to warmer ambient air temperature? Is the impound basin
dependent on the local ground stability which during an intense earthquake could become
locally unstable due to liquefaction and slope failures?
• Would the calculation of the 5 mile blast radius by Quest differ if there were no impound
basin?
Have you reviewed Sparks, Nevada's Hazardous review of 30,000 pounds ofpropane
explosion?
• Has the Sparks, Nevada's Hazardous review been factored into any study or the hazards
of this site?
• In the event of an explosion at your facility causing property damage, what are the policy
limit,-, for reimbursement to homeowners?
Has Rancho ever submitted an insurance policy as requested by Alan Gordon, California
State Lands commission or the City of Rancho Palos Verdes?
Is there an existence of a high degree of risk of some harm to the person or property of
others by the operation of the Rancho facility? Would. you agree I -TO is dangerous
because of its properties? A flammable gas I iquefied by pressure or refrigeration, which
15
will revert explosively (volume increase) to gas, which is heavier than air, very
flammable and virtually inextinguishable?
* Is there likelihood that the harm that results will be great?
Is the storage of 25 million gallons of butane a matter of common usage in the
community?
0 Would you comment on your inability to eliminate the risk by the exercise of reasonable
care?
* Why your location is not inappropriate for your activity?
• Extent to which Rancho's value to the community is outweighed by its dangerous
attributes?
Is there a mathematical formula to predict how long the butane will remain in a liquid
state in the presence of the heat of an explosion which can demonstrate that the liquid
butane will not remain cool?
Do you believe a butane fire will bum itself out before the cool liquid butane has a
chance to turn into a gas?
• Is Rancho a money loser subsidized by Plains All American? Why does Plains Marketing
pay the rent for the facility drawn on an account in Van Wert, Ohio?
* Is Rancho merely a storage facility for the benefit of Tesoro and Valcro?
• Does Rancho pay any money for the use of the rail line immediately adjacent to the
facility?
Thank you for your coopeAtion.
14
rZV-4-1- �11111-------
1-"e�hcorc'y' G. P sq.
(Retired -Assistant Head DDA, Environmental Crimes/OSHA Division, Los Angeles County)
CC: Michael Karzas 60 Minutes, Dan Wiekel, LA Times
3
16
UNIVERSITY OF CALIFORNIA, BERKELEY
BURKELUN - DAWS I NVINE - LCk AWAqMS , MERM.) - RIVERSIDE - SAN [)I ck) - SAN FRW:1SC0
TWA,'PHONE: (9253631 1587
F -MAIL txa4Vee,bcrkdey.,:du
ZZ
.... . .................. ... --- .. ...... .... - .. ....... ..... . ..... ----
SANTA BARBARA SAN FA CRLIZ.
CFNIER FOR CKFASTROPHICRISK MANAGEMENT
DEPARTMENT OF CIVIL & ENVIRONMENTAL ['-,N(j[NF1r.R[N0'
BERKELF.Y. CALIFORNIA 94720-17 10
April 20, 2015
Mr. Ronald Conrow
Rancho LPG Holdings, LLC
2110 North Gaffey Street
San Pedro, CA 90731
Re: Letter dated April 9, 2015 with responses regarding my statements contained in the You'rube video about
the Rancho LPG Facility in San Pedro, CA
Dear Mr. Conrow:
I have reviewed the contents of your letter to me dated April, 9, 2015 regarding my statements contained in the
YouTube video about the Rancho LPG Facility in San Pedro, CA. This letter summarizes my responses to the
four quotations I made in the YouTube video.
Before I address the four quotations, I would like to address several statements contained in your letter to me.
First, you state:
"We are concerned not only about the inflammatory nature of this video, but the fact the clairns
portrayed in the video by you and other commenters are tacking proven scientific information required
to quantify exactly how the event,, described in the video can even happen,"
The background I reviewed and analyzed that formed the foundation for my statements in this video came from
documentation I have obtained since 2011 regarding the Rancho LPG Facility, surrounding facilities, and
similar LPG facilities in other locations. This documentation .included several qualitative and quantitative 'risk
analyses' of the Rancho LPG Facility that addressed some of the major hazards that confront these facilities and
the uncertainties associated with performance of these facilities given the different kinds of hazards. These
hazards included effects on the facilities and surrounding communities and industrial facilities of intense
earthquakes, ground instability (e.g. liquefaction during earthquakes, instability developed as a result of intense
storm effects), tsunamis, terrorist activities, and those associated with operations and maintenance of the
facilities (e.g. LPG transport into and out of the facilities). This background included several hundred
documents.
After completed review of the background documentation, in mid -2011., I advised Mr. Anthony Patchett that
the primary conclusion I reached after analyzing the available background was:
"the, only sensible way forward is to have an advanced, high quality, thorough, validated risk analysis
performed ... this would be similar to advanced analyses that are done for critical facilities such as
nuclear power plants."
Mr. Patchett commissioned a detailed review of the background documentation pertaining to Quantified R.isk
Analyses (QRA) of the Rancho LPG facilities by Mr. Philip Meyers of PEMY Consulting. Mr. Meyers issued a
report at the end of December 2011 surnmarizing the results of his review. Mr. Meyers developed a series of
detailed recommendations that addressed development of a comprehensive QR,A for these facilities; thus,
corroborating my primary conclusion.
17
The consequence of these developments is that your request for "proven scientific information required to
quantify exactly how the events described in the video can even happen" does not exist at this time. The
statements I made in the video represent my synthesis of the information and conclusions regarding the risks of
major accidents associated with the existing Rancho LPG facilities.
In. your letter you state: "you should be able to provide the technical. information to support your claims and
those of the other video commenters." Your contention that I should be able to provide the technical
information to support those of the other video commenters is not correct. Prior to release of the video, I was
not able to review, validate,, or comment on the comments and observations made by the other video
commenters. Those individuals should be given the opportunity to respond as I am responding to the four
comments I made during the video.
Further, in your letter you state: "However, if you support the claims contained in the video, it should be quite
simple for you to produce quantitative validation required to defend the positions of you and the other video
commenters. Later in this letter, I will provide the background for the four comments I made during the video,
As I summarized in the foregoing paragraph, I will not "defend the positions—of the other video commenters."
Finally, in your letter you state:
"The questions posed by Quest are straightforward (no gotcha questions) with the intention of
scientifically explaining how an event can or cannot happen. The residents of San Pedro concerned
about 'public safety' are deserving of facts based upon science and not rhetoric!"
I agree that the residents of San Pedro and the local, State, and Federal government agencies having
responsibilities for these facilities are deserving of acts based on science not rhetoric. Unfortunately, based on
the available background infortriati'On I have reviewed which includes a QRA performed by Quest Consultants
Inc., I do not think there is sufficient valid and validated information (qualitative and quantitative) to inform the
residents of San Pedro and the responsible local, State, and Federal government agencies regarding the 'public
safety' and risks of major accidents associated with the Rancho LPG facilities. I think it is incumbent upon
Rancho LPG Holdings LLC to provide the residents of San Pedro and the responsible government agencies the
scientifically based infon.-nation on the 'public safety' and risks (likelihoods and consequences) associated with
major accidents involving the Rancho LPG facility.
Next, I will address each of the four statements I made in the video as summarized in your letter to me and
further detailed in the letter from Quest Consultants Inc. to you (dated April 7, 2015).
Dr. Bea: "Rancho is a very volatile, explosive, flaniniable gas,"
The commentary provided by Quest (page 2) properly characterizes the LPG contained in the name of your
company: Rancho LPG Holdings LLC: Liquefied Petroleum Gas:
Clearl), the Raticho lacilit) Is not ai gas, but the Rancho racility does store flammable liquOted gasch
(propane and butane iii liquefied longi). It xxotild be tx-tieficial to educate the listener that volatility ofil)
applies to liquids (or Some solids that sublitne like carbon dioxide) but tiol to gases. Other cominon
materials are both volatile awl Ilan ma MaicrUils such as gasoline. diesel. kerosene. acetooe. arld COIN I
alcohol, are all volatile' liquids wid ars' quite common arid, once vaporized. %%ill produce a I'laIIIIIIA)IC gals.
If`at Ill"Iterial is flammable, it call be involved ill all explosion. flius, all thc inaterials outlined abAwe are
also --cXplosive.-
we
`Dr. Bea: "It also has very high risk because of the population and community that surrounds it."
The commentary provided by Quest (page 3) properly defines the information that should be but is not
available:
'Fhe statement is made in reference to Rancho being -high risk" due to the population around the facility.
Since risk is a product of consequence and frequency, in order to make file statement above, Dr. Bea must
have calculated both components of risk, as well as defined what "high" means in regard to risk. Since
this exercise must have already been completed by Dr. Bea in order to make such a statement, it should be
straight -forward to identify the following components that make Rancho a -high risk" facility.
My staternent is based on the information contained in the series of 'fisk analyses' documents I cited earlier in
this document. My synthesis of that information led to my qualitative assessment of "high risk", That
assessment included an assessment of the likelihoods of major accidents due to the multiple categories of
C�
hazards I cited earlier (earthquakes, severe storms, ground instability, terrorist activities, and operating and
maintenance activities) and the consequences (deaths, severe injuries, property and productivity damages, and
direct and indirect monetary costs).
During the past 45 years, I have been involved as an originator, contributor and reviewer of more than one
hundred QRAs involving 'Fligh Risk Systems.' This work has been associated with design, construction,
maintenance, and operation of onshore and offshore industrial oil and gas exploration, production,
0
transportation, and refining systems. Several of these QRAs were associated with oil and gas production and
transportation facilities located onshore and offshore Southern California near the Rancho LPG facilities. I have
written three books, contributed chapters in 4 other books, written several hundred refereed technical papers and
reports, and taught university undergraduate and graduate courses on System Risk Assessment and Management
(SRAM) of engineered systems for more than 20 years. This work has been closely associated with my forensic
engineering work as a primary investigator on more than 30 major accidents and disasters that have primarily
involved oil and gas exploration, production, transportation, and refining systerns. This work has been involved
with more than 40 major national and international joint industry — government sponsored research projects that
addressed SRAM of complex engineered systems,
The latest of these SRAM research projects was a 6 -year duration project sponsored by the National Science
Foundation, The goal of this project was to develop and validate advanced SRAM methods to address the
complex, interconnected, interactive infrastructure systems (gas storage and transportation, power and water
supply, marine, highway, and railway transportation, communications, flood protection) located in the
California Delta. This research project addressed primary deficiencies found in previous formal quantitative
Q.RAs and PRAs: 1) omission of important categories of uncertainties, 2) systematic incorporation of optimistic
human and organizational 'biases,' 3) assumptions integrated into the risk analyses that were not validated, 4)
systematic underestimate in the consequences of major accidents, 5) omission of important interactions between
infrastructure components and systems, and 6) application of inappropriate risk 'acceptability' and 'tolerability'
criteria. All of these deficiencies resulted in dramatic under -estimates of the infrastructure risks and
inappropriate acceptance — tolerability of those risks. I have detected evidence of all of these deficiencies in the
existing formal QRAs that have been performed for the Rancho LPG facilities.
This experience has provided me with an extensive 'library' of experience and knowledge about QRAs, PRAs
(Probabilistic Risk Analyses), PSM (Process Safety Management), Safety Cases, and other relevant
technologies that apply to understanding the risks posed by the Rancho LPG facilities. The combination of this
previous experience together with the knowledge I developed from. my review of the previous studies of the
Rancho LPG facilities provided the basis for this and the other statements I made in the video.
19
Dr. Bea: 11 (if) One of the tanks fails, within a three mile radius of that tank approximately half a million
people live. That's high risk.
Based on the results contained in the previous Rancho LPG 'risk analysis' studies I reviewed, the three mile
radius was the distance I estimated that there could be significant negative effects or consequences from the
explosion of one of the Rancho vertical LPG storage tanks. That distance could be significantly greater if both
of the vertical, storage tanks failed during a single event or other nearby facilities (e.g. Rancho horizontal LPG
storage tanks, adjacent refining facilities) were involved in a cascade or propagation of fires and explosions. I
estimated the number of people who could live, work, and be present in this densely populated and industrial
area during such an event. My qualitative assessment of the likelihood and consequences associated with such
an event indicated the risks could be 'High'.
Dr. Bea: "A large amount of propane in storage tanks that can be affected by strong earthquakes,
ignited, that's a natural hazard, or (plus) human hazards: hubris, arrogance, greed, ignorance, and
indolence is a disaster sooner or later."
The commentary provided by Quest (page 4) properly characterizes the storage tanks .1 referenced:
"The propane is stored in the horizontal pressure vessels, the butane is stored in horizontal pressure
vessels and vertical refrigerated tanks."
This commentary also defines the potential types of gas ignition as:
"flash fire, torch fire, pool fire, or vapor cloud explosion" and combinations of these types.
The Quest commentary further observes:
The word hazard refers to **a chemical or physical condition that has the potential for causing
damage to people, property. or the environment." Thus. the fact that a flammable liquefied gas is
stored on site presents a hazard. Using this rational, ever), car on the road or plane in the sky for
on the runway) presents a hazard, Is that correct Dr. Bed?
Yes, I think these are correct statements. It is for these very reasons that the technology associated with SRAM
has been developed. There are many important hazards that need to be properly recognized, evaluated and
managed before there are major accidents that can have dramatic negative effects on people, property,
productivity, environmental quality and the quality of life.
The Quest commentary requested that I address the "human hazards" I detailed in my quotation and how they
are relevant to Rancho. These human hazards were part of the 'equation' (analytical expression) I developed to
explain simply why and how major disasters have and continue to happen. I based this 'Equation for Disaster'
on my detailed 'Root Causes Analyses' studies of more than 600 major accidents and my more than 30 forensic
engineering investigations of major disasters that have included the failures of the flood protection system for
the Greater New Orleans area during and following Hurricane Katrina, the BP Deepwater Horizon Maconodo
well blowout in the Gulf of Mexico, and the PG&E San Bruno gas pipeline fires and explosions.
The Equation for Disaster is: A + B = C. 'A' are natural hazards like explosive hydrocarbons, corrosion, metal
fatigue, earthquakes, tsunami,.-,, hurricanes, and instability of the ground. 'B' are human hazards including
hubris, arrogance, greed, complacency, ignorance, and indolence. 'C' are disasters sooner or later. The
definitions of these human hazards in the Quest commentary (page 5) are appropriate.
4
20
At this point in my review of the documentation associated with the Rancho LPG facilities, I have detected
plentiful evidence of the presence of ALL of the 'B' human hazards in the 'Equation for Disaster.' In addition,
there is ample valid evidence available to characterize the multiplicity of significant natural hazards at and in
the vicinity of these facilities. I conclude it is time for Rancho LPG Holdings LLC to take effective actions to
avoid the 'C' results associated with the facilities it owns and operates,
F�
Robert Bea, PhD, PE (retired)
Professor Emeritus
Center for Catastrophic Risk Management
University of California Berkeley
21
Kit Fox
From:
Janet Gunter <arriane5@aol.com>
Sent:
Monday, April 27, 2015 12:27 PM
To:
gene_seroka@portla.org
Cc:
noelweiss@ca.rr.com; alan.gordon@treasurer.ca.gov; abaker@sco.ca.gov;
jennifer.lucchesi@slc.ca.gov; heather.hutt@sen.ca.gov; MrEnvirlaw@sbcglobal.net;
amartinez@earthjustice.org; jones@usgs.gov; Kit Fox; rgb251@berkeley.edu
Subject:
Rancho LPG and the Port situation
Attachments:
rancho rail accident mar 8 2012 angle 2jpg; la_times_apr4_1977.pdf, la_times,jull6_
1977.pdf, Ipg article proposal 1977.pdf
Hello Mr. Seroka-
While our homeowners have been hitting the problem of the Rancho LPG issue on many fronts.... it dawned on me
today that we should really focus some greater effort on promised discussions with the port. Hence, my contact with you
today. At a State Lands Commission hearing almost a year ago now, your port attorney and Dave Matthewsen promised
Chair, Alan Gordon, that they would be engaging in conversations with the attorney that has been assisting our
homeowners on this issue for several years now, Noel Weiss. Contact was never made by either of the Port reps to bring
this promise to fruition. We would like to schedule a meeting with you to discuss this entire issue.
While the City of LA and its councilman and mayor have both recognized publicly (TV interviews) the jeopardy that this
facility and its operation poses to the adjacent communities, the leadership to take action to "prevent" a looming
catastrophe has been absent. The Rancho Palos Verdes City Council has also solicited the cooperation and assistance
of the City of LA on this issue to no avail.
The latest earthquake in Napal is just a recent reminder of the deadly aftermath that significant quakes represent. The
Port of LA continues to play a vital role in the allowance of an operation that poses an extremely high explosive risk to the
entire Harbor area. That risk, of course, includes the massive and extremely important infrastructure of the industrial port
complexes. In 2004, the Port of LA denied the renewal of the Amerigas/Rancho LPG pipeline lease to a port wharf. The
reason (while the inference was made by the port that it was primarily for the safety of residents) was because the port
could not complete the build out of the China Shipping terminal expansion project with the hazardous pipeline in
place. However, the port "continues" to this day to allow the private Rancho LPG LLC business (no longer a port tenant)
to transport their highly explosive commodity across a port controlled "rail spur" (for a paltry $1200/mo) and across port
controlled rail that fronts on Gaffey St. and runs through the port daily. Each 30,000 gallon rail car of propane/butane gas
has a blast radius of .42 mile. There has NEVER been any analysis to estimate potential for damage from this facility or
this rail transportation practice.... NOR is there any adequate liability insurance in place to cover losses by what FERC
filings illustrate to be... an "insolvent" Rancho LPG. This appears to be a major issue of reckless mismanagement.
The Port of LA is dealing with the current upgrade of its marine oil terminals to MOTEMS standards in an attempt to
protect the assets of the port. Smart. These upgrades include seismic improvements to terminals to meet a seismic
standard of 8.0. Meanwhile, within 1/4 mile of the inner harbor of the port, sits the Rancho LPG facility, built to a seismic
substandard of 5.5 - 6.0! The Rancho 25+ million gallons of both butane and propane gas on premises is the stored
energy equivalent of over 50 atomic bombs! So, the question is, "How prudent is the investment of many millions of
dollars into these improvements at your port marine terminals, when the Rancho facility (with more than a 3 mile blast
radius from a single 12.5 million gallon butane tank)... sitting on the edge of the harbor ... can obliterate any benefit that
might have been derived from those upgrades T' Why is the port and State Lands not asking this question? Why are
they not protecting this major investment??
I know that you have more than likely seen the youtube video that is the promo for a documentary in progress on this
issue, I am again providing that link.
https:Hm.youtube.com/watch?v=TBGt XKNpRk
I have also attached a photo of the rail car collision on your rail spur at Westmont & Gaffey street on March 8, 2012. That
accident miraculously escaped tank rupture. There was also a derailment on the rail fronting Gaffey Street at Channel on
Memorial Day 2005. Again, "luck" saved the day.
Other attachments are archived articles that will help you understand just how long there have been concerns about this
facility. "Pure luck" cannot last forever. On multiple fronts, this situation increases in probability for disaster daily. Our
hope is that you, as the new port leader, will take the action that has been so woefully avoided, to prevent the
inevitable. Whether it is the expected "big one", a "terrorism event" (as warned by retired Coast Guard Commander
Flynn), a failing antiquated 40+ year old infrastructure, or simple human error, the consequences of ignoring this danger
22
are too great to even imagine. But, we MUST respond to this very obvious "clear and present danger". We need you, Mr.
Seroka, to step up.
Please schedule a meeting with us to discuss this asap. The other day was Napal.... but, our time is coming ..... and we
know it won't be too long.
Thank you for your time.
Janet Gunter
23
Kit Fox
From: Seroka, Gene <gene_seroka@portla.org>
Sent: Sunday, May 03, 2015 8:10 PM
To: Janet Gunter
Cc: noelweiss@ca.rr.com; alan.gordon@treasurer.ca.gov; abaker@sco.ca.gov;
jennifer.lucchesi@slc.ca.gov; heather.hutt@sen.ca.gov; MrEnvirlaw@sbcglobal.net;
amartinez@earthjustice.org; jones@usgs.gov; Kit Fox; rgb251@berkeley.edu; Tankersley,
Eileen; Swift, Erica
Subject: Re: Rancho LPG and the Port situation
Janet,
I will be happy to meet with you. Although I am traveling on bush was this week, Eileen will work with you on potential
meeting days/times.
Regards, Gene
Sent from my iPhone
> On Apr 27, 2015, at 12:27 PM, Janet Gunter <arriane5@aol.com> wrote:
> Hello Mr. Seroka-
> While our homeowners have been hitting the problem of the Rancho LPG issue on many fronts .... it dawned on me
today that we should really focus some greater effort on promised discussions with the port. Hence, my contact with
you today. At a State Lands Commission hearing almost a year ago now, your port attorney and Dave Matthewsen
promised Chair, Alan Gordon, that they would be engaging in conversations with the attorney that has been assisting
our homeowners on this issue for several years now, Noel Weiss. Contact was never made by either of the Port reps to
bring this promise to fruition. We would like to schedule a meeting with you to discuss this entire issue.
> While the City of LA and its councilman and mayor have both recognized publicly (TV interviews) the jeopardy that
this facility and its operation poses to the adjacent communities, the leadership to take action to "prevent" a looming
catastrophe has been absent. The Rancho Palos Verdes City Council has also solicited the cooperation and assistance of
the City of LA on this issue to no avail.
> The latest earthquake in Napal is just a recent reminder of the deadly aftermath that significant quakes represent.
The Port of LA continues to play a vital role in the allowance of an operation that poses an extremely high explosive risk
to the entire Harbor area. That risk, of course, includes the massive and extremely important infrastructure of the
industrial port complexes. In 2004, the Port of LA denied the renewal of the Amerigas/Rancho LPG pipeline lease to a
port wharf. The reason (while the inference was made by the port that it was primarily for the safety of residents) was
because the port could not complete the build out of the China Shipping terminal expansion project with the hazardous
pipeline in place. However, the port "continues" to this day to allow the private Rancho LPG LLC business (no longer a
port tenant) to transport their highly explosive commodity across a port controlled "rail spur" (for a paltry $1200/mo)
and across port controlled rail that fronts on Gaffey St. and runs through the port daily. Each 30,000 gallon rail car of
propane/butane gas has a blast radius of .42 mile. There has NEVER been any analysis to estimate potential for damage
from this facility or this rail transportation practice.... NOR is there any adequate liability insurance in place to cover
losses by what FERC filings illustrate to be... an "insolvent" Rancho LPG. This appears to be a major issue of reckless
mismanagement.
> The Port of LA is dealing with the current upgrade of its marine oil terminals to MOTEMS standards in an attempt to
protect the assets of the port. Smart. These upgrades include seismic improvements to terminals to meet a seismic
standard of 8.0. Meanwhile, within 1/4 mile of the inner harbor of the port, sits the Rancho LPG facility, built to a
seismic substandard of 5.5 - 6.0! The Rancho 25+ million gallons of both butane and propane gas on premises is the
24
stored energy equivalent of over 50 atomic bombs! So, the question is, "How prudent is the investment of many
millions of dollars into these improvements at your port marine terminals, when the Rancho facility (with more than a 3
mile blast radius from a single 12.5 million gallon butane tank)... sitting on the edge of the harbor ... can obliterate any
benefit that might have been derived from those upgrades ?" Why is the port and State Lands not asking this question?
Why are they not protecting this major investment??
> I know that you have more than likely seen the youtube video that is the promo for a documentary in progress on this
issue, I am again providing that link.
> https:Hm.youtube.com/watch?v=TBGt_XKNpRk
> I have also attached a photo of the rail car collision on your rail spur at Westmont & Gaffey street on March 8, 2012.
That accident miraculously escaped tank rupture. There was also a derailment on the rail fronting Gaffey Street at
Channel on Memorial Day 2005. Again, "luck" saved the day.
> Other attachments are archived articles that will help you understand just how long there have been concerns about
this facility. "Pure luck" cannot last forever. On multiple fronts, this situation increases in probability for disaster daily.
Our hope is that you, as the new port leader, will take the action that has been so woefully avoided, to prevent the
inevitable. Whether it is the expected "big one", a "terrorism event" (as warned by retired Coast Guard Commander
Flynn), a failing antiquated 40+ year old infrastructure, or simple human error, the consequences of ignoring this danger
are too great to even imagine. But, we MUST respond to this very obvious "clear and present danger". We need you,
Mr. Seroka, to step up.
> Please schedule a meeting with us to discuss this asap. The other day was Napal.... but, our time is coming ..... and we
know it won't be too long.
> Thank you for your time.
> Janet Gunter
> <rancho rail accident mar 8 2012 angle 2.jpg> <la_times_apr4_1977.pdf>
> <la_times_ju116_1977.pdf> <Ipg article proposal 1977.pdf>
-----------------------------------Confidentiality Notice --------------------------------------------------
This electronic message transmission contains information from the Port of Los Angeles, which may be confidential. If
you are not the intended recipient, be aware that any disclosure, copying, distribution or use of the content of this
information is prohibited. If you have received this communication in error, please notify us immediately by e-mail and
delete the original message and any attachment without reading or saving in any manner.
z
25
Kit Fox
From:
Janet Gunter <arriane5@aol.com>
Sent:
Thursday, May 07, 2015 9:33 AM
To:
heather.hutt@sen.ca.gov; Lara.Larramendi@mail.house.gov; lisa.pinto@mail.house.gov;
amartinez@earthjustice.org; MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; det310
@juno.com; connie@rutter.us; igornla@cox.net; darzavalney@aol.com; rreg55
@hotmail.com; jdimon77@yahoo.com; president@centralsanpedro.org;
dwgkaw@hotmail.com; jhwinkler@me.com; carl.southwell@gmail.com;
sarahnvaldez@gmail.com; jwilliamgibson@ca.rr.com; Kit Fox;
irene@miraclegirlproductions.org; gene_seroka@portla.org; rob.wilcox@lacity.org;
fmillar@erols.com; kaiephron@yahoo.com
Cc:
rgb251@berkeley.edu; Ipryor@usc.edu; ahricko@hsc.usc.edu; meshkati@usc.edu
Subject:
4 min. report- hazard of crude due to addition of a "modicum" of LPG..."PURE LPG
CARS" NOT MENTIONED!
Please Watch!
The incredibly higher danger of the transport of "full rail cars of butane and propane gas" (that which is making the new
crude oil more volatile) is not even mentioned in this report! The Rancho LPG storage facility transports its 30,000 gallons
of "pure and highly... highly explosive" propane and butane in rail cars that run through our neighborhoods and the port
daily!! The blast radius from a single 30,000 gallon railcar of the propane or butane commodity has a .42 mile blast
radius! Rancho is also transporting this gas on the backs of large trucks which have an inherently higher rate of
accident. All of this action that gravely jeopardizes adjacent local residential populations, schools and youth sports fields
continues to be conducted without so much as a comprehensive risk analysis! This irresponsibility must stop!
http://www. aol. com/article/2015/05/06/oil-train-derailment-prompts-evacuation-in-north-dakota-
town/21180327/?icid=maing-grid7%7Cmain5%7Cd15%7Csec3_Ink4%26pLid%3D1230698675&a_dgi=aolshare_facebook
Janet Gunter
26
Kit Fox
From: Janet Gunter <arriane5@aol.com>
Sent: Thursday, May 07, 2015 11:28 AM
To: det310@juno.com; connie@rutter.us; noelweiss@ca.rr.com; MrEnvirlaw@sbcglobal.net;
amartinez@earthjustice.org; igornla@cox.net; dwgkaw@hotmail.com; burlingl02
@aol.com; darzavalney@aol.com; sarahnvaldez@gmail.com;jdimon77@yahoo.com;
rreg55@hotmail.com; dlrivera@prodigy.net; peter.burmeister@sbcglobal.net;
mandm8602@att.net; bonbon90731@gmail.com; jody james@sbcglobal.net;
john@nrcwater.com; carl.southwell@gmail.com; Kit Fox; chateau4us@att.net;
claudia.r.mcculloch@gmail.com; ruboysen@aol.com; jhwinkler@me.com;
hanslaetz@gmail.com; irene@miraclegirlproductions.org;
president@centralsanpedro.org; fxfeeney@aol.com; fmillarfoe@gmail.com;
fmillar@erols.com
Cc: rgb251@berkeley.edu; ahricko@usc.edu; meshkati@usc.edu; Ipryor@usc.edu;
heather.hutt@sen.ca.gov; Lara.Larramendi@mail.house.gov; lisa.pinto@mail.house.gov
Subject: THIS IS WHO OWNS RANCHO LPG ........ PLAINS ".....A GLIMPSE AT CHARACTER OF
OPERATORS!
http://www.bakersfieldcalifornian.com/business/kern-gusher/xl5lO915323/EPA-faults-air-
districts-approval-of-oil-train-terminal-near-Taft
27
5/22/2015 EPA faults air district's approval of oil train terminal near ... - The Bakersfield Californian
(HTTP:)/1NEATHER.BAKERSFIELD.COM/US/CA/BAKERSFIELD.HTML)
(HTTP://WEATHER.BAKERSFIELD.COM/US/CA/BAKERSFIELD.HTML)5r 0F(HTTP://WEATHER.BAKERSFIELD.COM/US/CA/BAKERSFIELD.HTML)
+D Login (/login?return=%2FBIogs%2F2015%Z1.5/o2F05%2FEPA-faults-air-district-s-approval-of-oil-train-
terminal-near-Taft.html) & Register (/registration?return=%2FBIogs%2F2015%2F05%2F05%2FEPA-
faults-air-d istrict-s-approval-of-oil-train-terminal-near-Taft. html)
MR AT CBCC
EPA faults air district's approval of oil
train terminal near Taft
(/B logs/2O15/O5/O5/EPA-fa u Its -a i r-
district-s-approval-of-oil-train-terminal-
near-Taft.html)
By JOHN COX, The Bakersfield Californian jcox@bakersfield.com
SUNDAY, MAY 17, 2015 3:47 AM
http://Www.bakersfield.com/Blogsl2015tO5tO5lEPA-faults-air-district-s-approval-of-oil-train-terminal-near-Taft.html 28 1/5
5/22/2015 EPA faults air district's approval of oil train terminal near... -The Bakersfield Californian
)m/mycapture/remoteimage.asp?
am%2Fimage%2F2015%2F05%2F05%2F600x600-g90-w%2F1952135269-data-
Dx%2F%20The%20Californian&BackURL=http%3A%2F%2Fwww.bakersfield.com%2FBIogs%2F2015%2
urinal-near-Taft.html&BackText=Back%20to%20the%20Story)
John Cox/ The Californian
One hundred tanker cars formed a mile -long train waiting to be unloaded in early December at Plain
Pipeline LP's new rail -to -pipeline near Taft. The train carried about 70,000 barrels of oil, or about 3 m
facility was designed to handle two such trains per day.
................................................................................................................................................................................................................................................
Federal officials say a new oil -by -rail terminal near Taft qualifies as a major air
polluter that should have undergone a more rigorous environmental review.
The U.S. Environmental Protection Agency said in letters mailed Thursday that the
facility was wrongly permitted by the San Joaquin Valley Air Pollution Control
District, and that Houston-based terminal owner Plains Marketing LP violated the
Clean Air Act by failing to obtain proper permission to operate it.
29
http://www.bakersfield.com/Blogsl2015/05tO5tEPA-faults-air-district-s-approval-of-oil-train-terminal-near-Taft.html 215
5/22/2015 EPA faults air district's approval of oil train terminal near ... - The Bakersfield Californian
It remained unclear Monday what the io-count notice of violations might mean to
the facility's operation. Plains was given to days starting April 30 to arrange a
meeting to discuss the findings with the EPA.
Each count carries a maximum fine of $37,500 per day, starting the day the notice
was issued. Criminal penalties are possible if the company remains in violation 30
days after the notice was sent.
Plains said Monday it could not comment because it had not yet received formal
notification of the allegations.
A lawyer for the air district faulted the notice, saying the EPA's findings run
contrary to years of established practice.
Opened in November, the Plains facility is capable of receiving up to two oil trains
per day, each a mile long, and diverting the crude into pipelines connected to
refineries around the state. Its permit currently allows for only one mile -long
shipment per day.
The facility, one of two large oil -by -rail terminals permitted near Bakersfield, is the
target of a lawsuit environmental activists filed in January in Kern County Superior
Court. It alleges Plains worked with the air district to minimize public scrutiny of
the project, and that a more rigorous review is in order.
Such terminals have stirred controversy across North America because of a series of
fiery oil train derailments in recent years. But the January lawsuit, and now the
EPA's notice of violations, focus on emissions, not potential derailments, as a
reason to be wary of the projects.
A spokeswoman for Earth Justice, one of the environmental groups opposed to the
Plains terminal, said the EPA's finding was not directly related to January's legal
action, but that it is nevertheless a big help to the lawsuit.
http://www.bakersfield.com/Blogs/2015/05/05/EPA-faults-air-district-s-approval-of-al-train-terminal-near-Taft.htm1 30 3/5
5/22/2015
EPA faults air district's approval of oil train terminal near ... - The Bakersfield Californian
The EPA notice said the air district concluded in 2012 the terminal was exempt from
a more robust review, because its emissions fell below a certain level.
But the federal agency said the air district failed to consider potential air pollution
from floating roofs inside oil storage tanks at the site. If those roofs had been
properly taken into account, the EPA said, the terminal would been classified as a
major polluter, triggering a wider review.
Air district Counsel Annette Ballatore-William son countered, saying roof tank
emissions occur at most once per year, during maintenance and repair, and that the
EPA has long accepted the air agency's approach to regulating floating roof tanks.
"We're a little bit frustrated" by the EPA notice, she said. "We think, based on our
reviews, the EPA is dead wrong."
Ballatore -Williamson said she was unsure whether her agency would try to attend
any meeting between Plains and the EPA, but noted the district "definitely has an
interest in defending the legitimacy of its practices."
Several environmental advocacy groups expressed satisfaction with the EPA's
notice of violations, including the Sierra Club's local chapter.
"This terminal wreaks havoc on our region's already compromised air quality and
our communities now fear the risk of exploding trains," Gordon Nipp, vice
chairman of the Sierra Club's Kern-Kaweah Chapter, said in a news release.
Subscribing has is perksw
'�jingrrintinrK M Tho Aakarefiald Palifnmian nm -j isnrfrrrts
31
http://www.bakersfield.com/Blogs/2015105105/EPA-faults-air-district-s-approval-of-oil-train-terminal-near-Taft.htm1 4/5
Kit Fox
From: Janet Gunter <arriane5@aol.com>
Sent: Wednesday, May 20, 2015 9:53 PM
To: MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com; amartinez@earthjustice.org;
connie@rutter.us; igornla@cox.net; jhwinkler@me.com; lonnacalhoun@me.com;
darlenezavalney@aol.com; sarahnvaldez@gmail.com; pedrolaurie@yahoo.com; det310
@juno.com; Jody fames@sbcglobal.net; bon bon90731@gmail.com;
irene@miraclegirlproductions.org; fxfeeney@aol.com; igornla@cox.net; Kit Fox;
donna.littlejohn@langnews.com; nick.green@langnews.com;
paul_h_rosenberg@hotmail.com; jdimon77@yahoo.com;
president@centralsanpedro.org; rreg55@hotmail.com; pmwarren@cox.net; burling102
@aol.com; mikelisk@aol.com; readsmd@aol.com; dwgkaw@hotmail.com;
jwilliamgibson@ca.rr.com; cicoriae@aol.com; alsattler@igc.org;
marciesmiller@sbcglobal.net; dlrivera@prodigy.net; peter.burmeister@sbcglobal.net;
mandm8602@att.net
Cc: heather.hutt@sen.ca.gov; Lara.Larramendi@mail.house.gov; lisa.pinto@mail.house.gov;
rgb251@berkeley.edu; Ipryor@usc.edu; carl.southwell@gmail.com; abaker@sco.ca.gov;
alan.gordon@treasurer.ca.gov; david.wulf@hq.dhs.gov; rob.wilcox@lacity.org;
matthew.rodriguez@calepa.ca.gov; carlos.delaguerra@lacity.org;
gene_seroka@portla.org
Subject: More on the history of Rancho LPG's operators.."Plains"...more insight into a hard reality
Improperly sited facility storing 25+ Million Gallons of highly explosive gas ... sitting on an earthquake fault of 7.3 potential
in tanks built over 40 years ago to a seismic standard of 5.5 .... with a 3.1 mile radius of blast impact from a single "one" of
two 12.5 million gallon butane tanks on "USGS" designated "landslide" area.... located within 1,000 ft. of homes, schools
and shops ..... and "operated" by this cast of characters? Really? And, what is anyone doing about it? EPA has no
protective regulations in place whatsoever to guard the public's safety .... the City of LA has said that their "hands are
tied and Rancho/Plains says they are "legal". Is there any justification for this insanity and recklessness? The answer
is "no". Deadly and unacceptable consequences lie in wait while everyone simply twiddles their thumbs awaiting the
disaster. See story:
http://america.aljazeera.com/articles/2015/5/20/plains-all-american-has-history-of-oil-spills.html
Janet Gunter
32
Kit Fox
From:
ReadSMD@aol.com
Sent:
Thursday, May 21, 2015 10:01 PM
To:
arriane5@aol.com; MrEnvirlaw@sbcglobal.net; noelweiss@ca.rr.com;
amartinez@earthjustice.org; connie@rutter.us; igornla@cox.net; jhwinkler@me.com;
lonnacalhoun@me.com; darienezavalney@aol.com; sarahnvaldez@gmail.com;
pedrolaurie@yahoo.com; det310@juno.com; jody fames@sbcglobal.net; bonbon90731
@gmail.com; irene@miraclegirlproductions.org; fxfeeney@aol.com; Kit Fox;
donna.littlejohn@langnews.com; nick.green@langnews.com;
paul_h_rosenberg@hotmail.com; jdimon77@yahoo.com;
president@centralsanpedro.org; rreg55@hotmail.com; pmwarren@cox.net; burling102
@aol.com; mikelisk@aol.com; dwgkaw@hotmail.com; jwilliamgibson@ca.rr.com;
cicoriae@aol.com; alsattler@igc.org; marciesmiller@sbcglobal.net; dlrivera@prodigy.net;
peter.burmeister@sbcglobal.net; mandm8602@att.net
Cc:
heather.hutt@sen.ca.gov; Lara.Larramendi@mail.house.gov; lisa.pinto@mail.house.gov;
rgb251@berkeley.edu; Ipryor@usc.edu; carl.southwell@gmail.com; abaker@sco.ca.gov;
alan.gordon@treasurer.ca.gov; david.wulf@hq.dhs.gov; rob.wilcox@lacity.org;
matthew.rodriguez@calepa.ca.gov; carlos.delaguerra@lacity.org;
gene_seroka@portla.org
Subject:
Re: More on the history of Rancho LPG's operators.."Plains"...more insight in...
Janet --the chronic dysfunction that parallels Rancho/Plains is the repeated ineffectiveness of our various area politicians,
agencies, and organs of government to respond to this problem. When I drive by, it has occurred to me that perhaps a
well -targeted campaign involving civil disobedience would start a more effective process.
In a message dated 5/20/2015 9:53:00 P.M. Pacific Daylight Time, arriane5@aol.com writes:
Improperly sited facility storing 25+ Million Gallons of highly explosive gas ... sitting on an earthquake fault of 7.3
potential in tanks built over 40 years ago to a seismic standard of 5.5 .... with a 3.1 mile radius of blast impact from
a single "one" of two 12.5 million gallon butane tanks on "USGS" designated "landslide" area.... located within
1,000 ft. of homes, schools and shops ..... and "operated" by this cast of characters? Really? And, what is
anyone doing about it? EPA has no protective regulations in place whatsoever to guard the public's safety .... the
City of LA has said that their "hands are tied and Rancho/Plains says they are "legal". Is there any
justification for this insanity and recklessness? The answer is "no". Deadly and unacceptable consequences lie
in wait while everyone simply twiddles their thumbs awaiting the disaster. See story:
http://america.aljazeera.com/articles/2015/5/20/plains-all-american-has-history-of-oil-spills. html
Janet Gunter
Firm behind California oil spill has shaky
safety record
Plains All American Pipeline has a long history of safety and environmental violations,
records show
May 20, 2015 12:42PM ET Updated 9:50PM ET
33
by Renee Lewis
The U.S. pipeline operator responsible for Tuesday's rupture, which released up to
105,000 gallons of oil into the Pacific Ocean off Southern California, has a shaky safety
record, reports show.
A rupture in a 24 -inch pipeline operated by Plains All American Pipeline left a 4 -mile trail of oil
on the shores along Highway 101 near Santa Barbara, according to Coast Guard Petty
Officer Andrea Anderson.
Officials warned the public to keep off the polluted shoreline after toxic fumes were reported in
the area. The California Department of Fish and Wildlife said Wednesday that it was
assessing the damage to the area's wildlife and on Wednesday night, Gov. Jerry
Brown declared a state of emergency in Santa Barbara County due to the effects of the spill.
Plains said it shut down the flow of oil after the spill and initiated its emergency response
procedures. Boom trucks were sent in Tuesday to clean the water.
"Plains deeply regrets this release has occurred and is making every effort to limit its
environmental impact," the company said in a statement. "Our focus remains on ensuring the
safety of all involved."
The company did not respond to Al Jazeera's request for comment.
Tuesday's spill follows a long history of safety and environmental violations by the company in
the United States and Canada, news reports and Environmental Protection Agency records
show.
In 2014 a Plains pipeline ruptured in Los Angeles' Atwater Village, sending more than 18,000
gallons of crude running through the city's streets. Toxic fumes were reported in the industrial
area for days after the spill.
The company has been cited for 10 oil spills that violated the Clean Water Act in Texas,
Louisiana, Oklahoma and Kansas. In 2010, Plains settled with the EPA after agreeing to pay
$3.2 million in civil penalties.
z
34
In April 2011 a pipeline operated by the company's Canadian branch, Plains Midstream
Canada, ruptured in a remote area of Alberta's boreal forest, releasing at least 37,000 barrels
of crude oil. The same line ruptured in 2006, spilling about 180 barrels.
In a 2012 spill, a smaller line operated by Plains Midstream Canada ruptured, spilling 2,900
barrels of crude into the Red Deer River in central Alberta. The company was ordered in
January to hire a third party to audit its pipelines in Alberta, Saskatchewan, Manitoba and
Ontario after regulators said the company failed to comply with previous safety directives.
Despite its spill record, Plains has plans to construct a pipeline in Arkansas, where an Exxon
Mobil pipeline ruptured in March 2013, spilling more than 134,000 gallons of crude oil into a
housing subdivision, forcing hundreds of residents to evacuate.
Plains' recent pipeline ruptures come amid increasing pipeline accidents across the U.S.
involving different operators, government data show.
There were 704 oil and gas pipeline incidents involving leaks or emergency shutdowns to
avoid accidents in 2014, according to data from the Pipeline and Hazardous Materials Safety
Administration (PHMSA), a branch of the U.S. Department of Transportation.
That averages nearly two spills every day last year in the United States.
The pipeline incidents from 2014 resulted in 19 deaths, 96 injuries and over $300 million in
reported property damage, PHMSA data show. Since 1995, there have been more than
10,000 incidents, 371 deaths, 1,398 injuries and in excess of $6 billion in reported property
damage.
3
35
-JI I Y MANAGER'S OFFICE
X)MINISTRAI10111
1 April 2015
Naval Facilities Engineering Command Southwest
DFSP San Pedro EA Project Manager
ATTN: Code JE20.13713
1220 Pacific Hwy,
San Diego, CA 92132-5190
SUBJECT: Comments on the Scope of the Draft Environmental Assessment for
the Proposed Closure of Defense Fuel Support Point (DFSP) San
Pedro
Dear Sir/Madam:
The City of Rancho Palos Verdes has received notice of the proposed closure of DFSP
San Pedro, and we attended the open house and public scoping session that was held
on March 18, 201.15 in San Pedro. We offer the following comments on the scope of the
draft Environmental Assessment (EA) to be prepared for this proposal:
We understand that, once the draft EA completed, it will be released for a 15 -day
public review and comment period, as required pursuant to the provisions of the
National Environmental Policy Act (NEPA). We further understand that the draft
EA could be released by this summer. With summer vacations and other family
obligations, we are concerned that residents in Rancho Palos Verdes, the
surrounding Los Angeles communities of San Pedro and Wilmington, and the City
of Lomita would not have sufficient time to review and provide meaningful
comments on the draft EA if only fifteen (15) days are provided to do so. As such,
the City of Rancho Palos Verdes respectfully requests that the public comment
period for the draft EA be extended to at least forty-five (45) days.
2. The project area for this proposal excludes the sites of the former San Pedro and
Palos Verdes Navy housing complexes, as well as portions of the DFSP San Pedro
site that are leased for bell fields and a Los Angeles Police Department (LAPD)
shooting range. However, the portions of the site utilized by the Palos Verdes
Peninsula Land Conservancy (PVPLC) for a native plant nursery and captive
breeding program for endangered Palos Verdes blue butterflies do not appear to
have been excluded. PVPLC's operations at DFSP San Pedro are of vital
importance to habitat preservation and restoration efforts on the Palos Verdes
Peninsula, The draft EA should address both the on- and off-site biological
30940 1 1AW)HORNL BLVD. / RANCHO RA1,0'8\/F.NDF,. GA 902/5-,15,1391/ (3,10) 544-5207,,FAX (310),544-5291 /WWWATWA(,( N,
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PRIM €::O EO ON k)[GY0111) R\P4.`R
36
DFSP San Pedro EA Project Manager
1 April 2016
Page 2
resources impacts of any changes to PVPLC's operations at DFSP San Pedro that
may result from its full or partial closure.
3. We noted at the scoping meeting that there was an apparent discrepancy between
the disposition of the underground concrete storage tanks between Alternatives I
and 2. While both alternatives noted that these tanks would be abandoned in
place, Alternative 1 stated that they would be filled with inert material but
Alternative 2 only stated that they would be abandoned. We were told that the
tanks would be filled under both alternatives, but this needs to be clarified in the
draft EA.
4. Alternative.s 1 and 3 describe the existing office and administration buildings being
maintained in "caretaker" condition, while Alternative 2 describes them as being
maintained in "as is" condition. The draft EA should clearly describe what these
terms mean.
5. It seems clear that each of the proposed alternatives will result in varying levels of
disturbance and disruption of the site. The draft EA should quantify the
environmental impacts of each of these alternatives in terms of:
a. Quantities and depths of earth movement (i.e., cut, fill, import and export)
b. Number and routing (Le,, Gaffey Street vs. Western Avenue) of truck trips
c. Air quality, noise and hazardous materials exposure for sensitive receptors
6. We understand that the proposed project does not address the future use of the
property in -the event of its eventual disposal by the Navy. Nevertheless, we would
like to see the draft EA address in general terms the possible future use(s) that
might be. suitable on the property (in terms of the exposure of future employees,
visitors or residents to environmental conditions) under Alternatives 1, 2 and 3.
Again, thank you for the opportunity to comment upon this important project. If you have
any questions or need additional information, please feel to contact me at (310) 544-5226
or via e-mail at kihl@rpvca.gov.
Sincerely,
Kit FOX, AICP
Senior Administrative Analyst
cc: Mayor Jim Knight and Rancho Palos Verdes City Council
Doug Willmore, City Manager
Carolynn. Petru, Deputy City Manager
M:\Border lssuesTFSP.San Pedro Closure\20150401—EAComments.docx
37
CITYOF A N C H 0 PALO VE R D HS'
C/I FY MANACAI'RS 0A FIC"E*'
ADMINISTRATION
10 April 2015
Malinda Stalvey
Environmental Planning Team
Metropolitan Water District
PO Box 54153
Los Angeles, CA 90054
SUBJECT: Comments in Response to the Notice of Intent to Adopt a Mitigated
Negative Declaration for the Palos Verdes Reservoir Upgrades Project
Dear Ms. Stalvey:
The City of Rancho Palos Verdes appreciates the opportunity to comment upon the
proposed Mitigated Negative Declaration (MND) for the above-mentioned project. We
have reviewed the MND, and offer the following comments:
The Project Description in the Initial Study (pp. 1-16) raises several questions:
a. What are the two (2) MWD member agencies that will be reconnected to
the reservoir after the upgrades are complete?
b. What will be the new maximum capacity of the reservoir after the upgrades
are complete?
C. Is a back-up generator or other emergency power supply for the reservoir
proposed as a part of the upgrade project? If not, why not?
d. It is our understanding that the Chandler Quarry in Rolling Hills Estates no
longer accepts construction and demolition material. If this is the case, what
will be the destination for this material?
2. The discussion of Hydrology and Water Quality impacts in the Initial Study (pp. 50-
53) concludes that impacts related to the exposure of people and structures to risk
of loss, injury or death due to flooding resulting from a failure of the reservoir will
be less than significant, and no mitigation measures are recommended. However,
the inundation map for the Palos Verdes Reservoir prepared by MWD in the 1970s
(see enclosure) clearly shows that portions of Green Hills Memorial Park and the
Rolling Hills Riviera neighborhood in Rancho Palos Verdes could be flooded to
depths of up to ten feet (10') in the event of a catastrophic failure of the reservoir.
We understand that part of the purpose of the proposed project is to upgrade the
3£)9401 LAM/111ORM BLVI,.)./ RANCI K) CA 90275-5391/ (310) 5,14 52W /�"AX (310) 1544 5291 Itwv�vvmlv(;A,G0111
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PR' HA.)ONR[.(.,Y(,1
............. " I ......... .............. ............. .................... ........................ ...... 1. 11-1 - ............ 11111 11 38..__ ... .......... ... .. ... ..... . .........
Malinda Stalvey
10 April 2016
Page 2
reservoir to current safety standards. Nevertheless, the City of Rancho Palos
Verdes respectfully requests the inclusion of the following mitigation measures as
a part of the MND:
a. MWD shall prepare an updated inundation map for the Palos Verdes
Reservoir, based upon its expected maximum capacity after the completion
of upgrades. A copy of this map shall be provided to the City of Rancho
Palos Verdes and first responders (i.e., Los Angeles County Sheriff and Los
Angeles County Fire) for emergency preparation, planning and response
purposes.
b. MWD shall develop, in conjunction with the City of Rancho Palos Verdes
and first responders, a system for emergency public notification of
downstream residents in the event that an imminent failure of the reservoir
is observed, either as a result of routine inspection or an unusual event
(e.g., earthquake, etc,).
31 The discussion of Transportation/Traffic in the Initial Study (pp. 67-71) concludes
that construction traffic entering and exiting the project site could have a significant
impact upon the safety of recreational trail users along Palos Verdes Drive North
and Palos Verdes Drive East, and recommends the use of flagmen and guards as
a mitigation measure. The City concurs with this assessment, but would also point
out that the segments of Palos Verdes Drive North and Palos Verdes Drive East
adjacent to the reservoir are a part of a major commuter route for Palos Verdes
Peninsula residents. The City of Rancho Palos Verdes respectfully suggests that
the use of flagging operations should be expanded to include motorists as well,
particularly during peak morning and evening commute hours.
Again, thank you for the opportunity to comment upon this important project. If you have
any questions or need additional information, please feel free to contact me at (310) 544-
5226 or via e-mail at kiff@rpvca.gov.
Sincerely,
/4�
Kit FOX, A1CP
Senior Administrative Analyst
cc: Mayor Jim Knight and Rancho Palos Verdes City Council
Doug Willmore, City Manager
Carolynn Petru, Deputy City Manager
Tracy Bonano, Emergency Services Coordinator
Nicole Jules, Deputy Director of Public Works
MABorder IssuesTalos Verdes Reservoir12015041 Q_MNDComments,docx
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