By: Cynthia Palmer, Senior Analyst for Petrochemicals, Moms Clean Air Force
Date: May 16, 2023
About: Environmental Protection Agency Docket ID No. EPA-HQ-OAR-2022-0730-0001
To: Environmental Protection Agency
My name is Cynthia Palmer and I’m the Senior Analyst for Petrochemicals at Moms Clean Air Force, a community of 1.5 million moms and dads fighting for clean air for our children.
This is my best friend, Ursula. We met in college and quickly realized we were soulmates. We remained close over the years. She was my bridesmaid, and I was hers. We were only half joking in saying we wished we didn’t like boys so much, so we could have married each other.
Ursula grew up in Houston just a few miles from four HON facilities: the Houston Refinery, the Goodyear Houston Chemical Plant, The TPC Group Chemical Plant, and the Eco Services Operations Facility. Her mom died when she was a kid, and her dad relocated to Port Arthur where their home overlooked a tank farm. There, they lived near five HON facilities, some just a mile away: Motiva Chemicals Flint Hill Resources, Chevron Chemical, Motiva Port Arthur Refinery, Veolia Technical Solutions, and the Nafta Regions Olefins Complex.
Ursula cannot speak to you. She died from a malignant cancer when her children were in pre-school. We will never know if her death was pure “bad luck” or whether it had something to do with the 9 HON facilities she grew up next to. Or some combination: maybe she paid the price for being athletic and sucking in the extra air as she went running near her home.
What we do know is that ethylene oxide, 1,3-butadiene and dozens of other toxic chemicals emitted by HON facilities can ravage the human body.
I urge you to fix the following 5 components of the rules:
- It’s great that the fenceline monitoring includes six chemicals but this still leaves about half of the facilities with no fenceline monitoring requirements at all. I urge you to consider adding other sentinel pollutants, requiring fenceline monitoring at all facilities, and mandating more sensitive detection technologies.
- We are asking you to increase the flare efficiency and to require direct monitoring of flaring emissions.
- It was a good start to upgrade the Leak Detection and Repair standards for EtO and chloroprene. Please update the LDAR standards for other chemicals as well, and require more advanced detection technologies.
- In your Community-Focused Risk Analysis, we ask you to include non-cancer endpoints such as miscarriages and neuro-developmental impacts, and to explicitly link the risk assessment to the regulatory requirements in the rule.
- We appreciate the removal of the startup, shutdown and malfunction exemptions. Be sure not to add any new SSM exemptions as part of the work practice standards.
A strong chemical manufacturing rule will help reduce the pollution burden for communities living near polluting facilities. This is an important step forward for environmental justice. We are counting on you to make the rules as protective as possible. Maybe you will save someone’s best friend. Thank you.