A newly submitted peer review of the hazard report for the Strada Verde project suggests that the original guidance regarding the size of the buffer zone that should be required around the Trical agricultural chemical distributor is overstated.
The Strada Verde initiative, Measure N on the Nov. 3 ballot, is at odds with the hazard report, as the development’s location is not clear of the report’s recommended 3.5-mile buffer zone.
The San Benito County Board of Supervisors is scheduled to discuss the hazard report and peer review again on Oct. 6.
The Strada Verde Innovation Park, proposed near Highways 25 and 101 along the Pajaro River, would occupy 2,777 acres, including open land with a 2.4-mile trail; a business center with a hotel, retail shops and restaurants; and an automotive technology and research center with automobile testing tracks.
According to Greg Knight with ABS Consulting, one of the tasks of the peer review his company presented to supervisors on Sept. 22 was to analyze distances “using more realistic scenarios.” The hazard study conducted by EMC Planning Group and Trinity Consulting analyzed consequences for “reasonable worst-case scenarios.”
Though no buffer zone area recommendation is made in the peer review, it states that for nighttime activities a 1.5- to 2-mile radius was expected to be within “a life-threatening health effects or death distance,” and 0.3- to 0.4-miles for daytime activities.
In his presentation, Knight also said “irreversible or other serious, long-lasting adverse health effects or an impaired ability to escape” distances were three to four times farther.
In the peer review, ABS used the Phast modeling software while EMC used Aloha to analyze parameters in the hazard report. In all but one scenario, ABS’ analysis resulted in a lesser distance affected by chemical spills. The largest difference was a chloropicrin railcar spill, with ABS predicting it would significantly affect up to 3.3 miles from Trical, compared to EMC’s 4.8 miles.
Knight said ABS conducted its analysis in a way that is more representative of both daytime and nighttime conditions. He noted the different parameters that had little to no impact, such as radiant solar energy, surface roughness, and wind speed, compared to EMC’s report. Making the most significant impact are the atmospheric stability levels and temperature because ABS gives separate daytime and nighttime parameters.
Ranahit Sahu, an environmental, mechanical and chemical engineer who authored the EMC hazard report, said he welcomed the peer review but questioned the model used by ABS.
“Originally, when we did the study we had to justify the models we used, and that’s laid out in great detail in analyses. Selection of a model is a key parameter,” Sahu said. “We chose the models we did because they are regulatory models, they are approved by governmental agencies. Phast is not. Phast is an industry model.”
Sahu added that because Phast is not approved by governmental agencies, it doesn’t rise to the level of scrutiny of public models such as Aloha and will underpredict dispersion. He said his report takes into account high-energy impact scenarios that are possible, even if they are low-probability events, which are typically analyzed in hazard reports.
“You’re a public agency. You have a responsibility for public health protection and you should be using models that are in the public domain,” Sahu said. “Models that have been verified, developed and then validated by public agencies.”
Sahu also questioned ABS’ atmospheric stability class B for its daytime case. EMC used class F, which is part of the stable classes that occur during the night.
“In my 25 years of doing this kind of work, I’ve never seen any risk management plan that uses B stability,” Sahu said. “By definition, we cannot time when bad things can happen, we cannot say ‘we can only restrict it to daytime conditions’—that is why we do reasonable worst-case.”
After Sahu’s comments, Knight defended the Phast model and its acceptance by governmental agencies, saying he has used the model for risk-management plans that have been accepted by the Environmental Protection Agency and the Occupational Safety and Health Administration.
“I think industry and government in general accept that it’s some of the best science available,” Knight said.
Additionally, he said ABS looked at more reasonable scenarios to compare to the worst-case scenarios so the county would have two data sets to consider.
Following the presentation and public comment in which residents voiced their concern for public health, Supervisor Anthony Botelho said the project was not creating the hazard that has been there for years.
“This company has been making fumigants for better than 40 years and there haven’t been any significant accidents, no tragedies,” Botelho said. “There is a greater likelihood with the distribution of the products going to the destinations where they are being used.”
Botelho added that if people felt it was too hazardous to work at the Strada Verde project, if approved, they had the choice to look for jobs somewhere else.
“Right now there are hundreds of jobs out there within a one-mile area of Trical. Hundreds,” he said.
BenitoLink is a nonprofit news website that reports on San Benito County. Our team is working around the clock during this time when accurate information is essential. It is expensive to produce local news and community support is what keeps the news flowing. Please consider supporting BenitoLink, San Benito County’s news.