California Cracks Down on Warehouse Pollution—Or Does It?

 

As the retail economy transitions from big-box stores to big-box warehouses supporting home delivery, the U. S. has experienced something of a warehouse building boom.  And the South Coast Air Quality Management District (SCAQMD) in Southern California is going to make sure that those warehouses don't pollute the air.

 

How does a warehouse pollute the air?  Good question.  A warehouse itself is just a big room full of stuff.  But getting the stuff in and out of the warehouse requires trucks and forklifts.  Never mind that those trucks are going to be going somewhere else and emitting pollution anyway if that particular warehouse isn't built.  The brilliant minds of the California regulators have determined that warehouse owners and operators are liable for the air pollution caused by any truck that delivers or picks up stuff at the warehouse. 

 

In order to be absolved of these sins, warehouses must either pay a fee that allegedly goes toward the air district's anti-pollution initiatives, or must install electric vehicle chargers or rooftop solar panels.  If the warehouse doesn't comply by the deadline (which varies from now till 2025, depending on the warehouse's size), the SCAQMD can assess fines of $11,700 a day.  And according to an LA Times article, only about half of the warehouses included in current regulations have complied so far.  In order to shame the noncompliant ones, the paper published a 109-line table of the warehouses that haven't complied.  The article noted that the regulators made warehouses in disadvantaged communities a special priority for enforcement. 

 

Nobody in their right mind is in favor of air pollution, other things being equal.  But other things are hardly ever equal, and this attempt on the part of California regulators to reduce pollution that is loosely associated with warehouses shows that the regulatory process has reached the outer limits of feasibility in this case.

 

Let's see if we can analyze the logic of the regulations, such as it is.  Californians need stuff that is typically shipped by truck.  Currently, that stuff is moving less through retail stores and more through warehouses owned by retailers, shippers, and manufacturers, and a lot of truck traffic is going to and from the warehouses. 

 

So far, electric trucks are not much of a thing, although in other regulations California is threatening to ban diesel trucks from the state altogether.  (That would certainly fix the truck-pollution problem, but would deprive most Californians of their stuff.)  The people building warehouses clearly have money to spend on building them, so they can certainly afford to pay either fees the regulators assess—so many dollars per truck coming and going—or they can afford to install lots of charging stations for the electric trucks which will surely materialize ("If you build it, they will come"), or force the warehouses to install solar panels on those nice flat roofs of theirs. 

 

Now suppose you're a poor person living in one of those disadvantaged neighborhoods near which a big new warehouse has been built, and you open your door to diesel fumes emitted by the many trucks that drive past your house on the way to the warehouse.  How is any aspect of these new regulations going to make your life better? 

 

If the warehouse is paying a fee per truck and that goes to the SCAQMD, that isn't going to help you directly unless you get a job at the SCAQMD.

 

If the warehouse installs hordes of electric-truck charging stations, that isn't going to help you until the electric trucks come along, which may be many years from now, if ever.

 

If the warehouse installs solar panels on their roof, there's just as many trucks going by your house as there were before. 

 

Unless you have the particular mindset that rejoices when any polluter is made to pay a penalty for their crime, and derive enough satisfaction from knowing that the warehouse operator is doing daily penance for attracting all those trucks that drive by your door, and that warm glow of vengeance or whatever it is outweighs the problem of all those trucks passing your house, you are no better off with these regulations than without them, at least for the foreseeable future. 

 

Yes, perhaps the regulations move us incrementally closer to the fossil-fuel-free utopia envisioned by many in our elite classes, in which the roar of diesel engines is replaced by the almost imperceptible hum of electric motors—except for the occasional boom of exploding transformers overloaded by too much demand on an outmoded power grid. 

 

I put the regulations in terms of sin and penance rather than in more objective or scientific terms, because that is what they amount to:  a secular version of the religious concepts of sin and salvation.  As I have shown, the warehouse anti-pollution regulations are not going to reduce the diesel emissions from trucks going to and from the warehouse, at least not until most of the California truck fleet becomes electric.  But they punish people who have had the economic initiative to build warehouses in order to meet California's insatiable desire for stuff. 

 

It would make more sense to assess fines on the trucks each time they make a delivery.  But the regulators know they have pushed truckers about as far as they can stand, and so instead they go for large warehouse-owning corporations, which are richer and easier to shake down than individual truckers.  I use the term "shakedown" intentionally, because in some ways, these environmental regulations are taking on the look of the Mafia henchman who comes into a dime store and says to the owner, "Nice little place you got here—a shame if anything happened to it."  Because air quality has become such a sacred cow in California, almost anything can be done in its name, including the slapping of ineffective regulations that don't get at the root of the problem, but appease the gods of air quality. 

 

Perhaps these regulations are just rough spots on the road to a diesel-free future, but in the meantime, I'm glad I don't run a warehouse in California.

 

Sources:  The article "Crackdown on warehouse pollution results in more than 100 violation notices" appeared on the LA Times website at https://www.latimes.com/environment/story/2023-12-22/warehouse-crackdown-results-in-over-100-pollution-violations. 

Facts, Investigations, and Rumors: The Houston Tank-Farm Fire

NOTE:  Due to an oversight, this blog was not posted last week.  It was intended to appear on Apr. 1.  My apologies in case you missed it.---KDS

As most readers of this blog know, most of what appears here is commentary on engineering-ethics-related news from other sources.  First-hand reporting is not my bag, if for no other reason that I don't have time for it, and there aren't a lot of sources who are willing to be called at 5 AM, which is usually around the time I'm writing it.  But a week or so ago I received some information almost by chance, and it puts me in something of an ethical dilemma.  Do I write about something that wasn't intended for publication or not?  Well, with certain precautions, I've decided to go ahead.

Here's the known and widely publicized facts:  On Sunday, Mar. 17, a fire began at the Intercontinental Terminals Company (ITC) tank farm in Deer Park, an industrial suburb of Houston.  It quickly spread and at one point involved 11 of the 242 tanks at the facility.  Firefighters could only spread foam on nearby tanks to keep the fire from spreading, but had to wait for the products contained in the tanks to burn away, which took several days.  These products included toluene, xylene, naphtha, and benzene, a known carcinogen.  The fire made a huge black plume visible for miles, and caused the closure of several local school districts for a day or two.  Authorities also temporarily closed a portion of the nearby Houston Channel to shipping due to the fire.

Naturally, the fire is going to be investigated.  Although no one was killed or injured as an immediate result of the fire, millions of dollars' worth of chemicals and plant facilities were destroyed, and an unknown amount of toxic chemicals was released into the air, the ground, and the water nearby.  Anything this consequential is worth investigating because of the lessons that can be learned to avoid similar accidents in the future.

An independent agency, the U. S. Chemical Safety Board, announced last week that it was opening its investigation into the accident.  This board is recognized for its thorough and reliable conduct of mishap investigations, which can take months or even years before a well-researched report is issued.  In the meantime, before such reports are available, the cause remains officially unknown, although the facts that wind up in the official report are presumably somewhere waiting to be investigated.

And in the meantime, the last thing any company official is going to do is talk loosely about what they think might have happened.  This explains the relatively small amount of information that ITC released on its own during the fire, which burned off and on for nearly a week.  Lawyers flock to major accidents like—well, I was going to mention a species of bird, but we'll just let it go at that.  Already the Texas attorney general has announced that he's suing ITC for the pollution caused by the fire, and other suits will follow as night follows the day.  And the less fodder given by a company's officials to lawyers to use against them, the better, as far as the company is concerned.

So much for officialdom.  Now for the rumors and unconfirmed reports.  I did manage to find a reference in a minor Houston news outlet (the Houston Press) to the following report:  "Also Wednesday morning, the Houston Chronicle was quoting an unidentified worker as says the fire may have been started when a tank overheated and a safety valve did not shut that down."  I was unable to locate the original Chronicle story, but (and here's my contribution to the mix), it fits in with what a friend of mine heard from his connections back in Deer Park, where he was raised and worked in the refining business for most of his career before retiring to my area.  For obvious reasons, he will remain anonymous here.

On the Friday after the fire began, he told me the following.  At a tank farm there are tanks, pipes, valves, and pumps to send the various products to nearby facilities or transportation points such as loading locations for tank cars and tank trucks.  Some of these pumps are quite large, using multiple-horsepower motors that consume many kilowatts of power.  If an order comes through to a technician to send a certain amount of product to a certain pipe, the appropriate pump is turned on first and then the valve is opened, because otherwise, unforeseen back pressure or other issues might cause products to go the wrong way and get mixed up.

But it's vitally important, especially when a large powerful pump is involved, to turn on the valve shortly after the pump is turned on.  If this isn't done, all the energy that the pump's spinning impeller puts into the liquid can't go anywhere and turns into heat.  And the product—often a flammable one such as naphtha—can get hot enough to rise past its flash point, so that once the valve is turned on and any air is present, the product will spontaneously catch fire.

Normally there are thermal cutout sensors that will detect when a pump's outlet overheats due to misguided operation such as this, and shut off the pump automatically.  But sensors sometimes fail.

What my friend heard was that someone turned on a pump in preparation for shipping some flammable product out of the plant, but due to paperwork or some other delay, the appropriate valve wasn't turned on for some 17 hours.  That's plenty of time for a pump without a safety thermal cutout to get its product way too hot.  And so sometime Sunday, the product caught fire, and the rest is very public history. 

Distorted through a rumor mill and two news outlets, that more detailed story fits in with the unconfirmed and unattributed report that a "tank overheated" and a "safety valve" (read: thermal cutout) did not shut it down.  So strictly speaking, I'm not reporting a scoop here.  But it does sound like confirmation of another unattributed report.

Whatever the rumors say, we'll have to wait for the Chemical Safety Board to interview everyone concerned, compile the data they can obtain from SCADA (supervisory control and data acquisition) digital records, and anything else they find that's relevant to getting to the bottom of this accident officially.  But in the meantime, plant operators everywhere should pay extra attention to pumps and valves and timing.

Sources:  Besides my friend, I consulted the report on the fire carried by Chemical and Engineering News at https://cen.acs.org/safety/industrial-safety/Houston-chemical-distribution-tank-farm/97/web/2019/03 and found the unattributed report of the overheated tank at https://www.houstonpress.com/news/itc-tank-fire-extinguished-but-some-school-remain-closed-11258138.