By: Erandi Treviño, Texas State Coordinator, Moms Clean Air Force
Date: September 28, 2022
About: Environmental Protection Agency Docket ID No. EPA-HQ-OLEM-2022-0174
To: Environmental Protection Agency
Good afternoon. My name is Erandi Treviño, and I am the Texas state organizer for Moms Clean Air Force and an organizer for EcoMadres based out of Houston, Texas. I support the proposed EPA Safer Communities by Chemical Accident Prevention (SCCAP) rule that will strengthen the Risk Management Program to help better protect the health and safety of communities living near chemical and petrochemical facilities.
The threat of chemical disasters is still a real and present danger for many communities like mine in Houston. My family lives about 10 miles from the Houston Ship channel, where more than 20 petrochemical plants are located. I was in fifth grade when I learned that children who live within two miles of the ship channel are 56% more likely to develop leukemia.
Nearly 200 million Americans live near Risk Management Program facilities in the US. Houston, Texas; Baton Rouge, Louisiana; and Beaumont-Port Arthur, Texas are high-risk metro areas that contain many schools in multiple vulnerability zones of chemical and petrochemical facilities.
Just minutes from my home sits one of the most at-risk schools – San Jacinto Elementary School in Deer Park, Texas. This school is located in the vulnerability zones of 41 different chemical facilities. Three years ago, in the same town, the Intercontinental Terminals Company had a weeks long series of catastrophic storage tank fires and toxic air emissions. This disaster, originating in Eastern Harris County communities, overcame the whole Houston metropolitan area. It was a striking event and yet, it was sadly not an isolated one. The chemicals that spread in the air as a result of this event were most concentrated and dangerous in the predominantly Latino communities surrounding the facilities. We know that exposure to harmful chemicals can worsen respiratory and other health conditions. Broad disclosure of easily accessible information in languages spoken by affected communities should be required.
Many Risk Management Program facilities throughout the United States are in areas that are seeing increasing impacts from climate change, such as flooding, wildfires, and storm surge. In Texas winter storms and hurricanes have caused devastating damage to our communities. A recent study and report found that roughly a third of Risk Management Program facilities are at increased risk from climate impacts. This is especially important in Texas where the Texas Commission on Environmental Quality has reported they will only selectively monitor the air quality related to natural disasters. The EPA needs to require Risk Management Program facilities to incorporate climate and natural disaster risks into their plans and have plans to address any associated loss of power.
The proposed rule is important for strengthening the existing EPA Risk Management Program and further protecting vulnerable communities from chemical accidents, especially those living near facilities with high accident rates. The current Risk Management Program rule needs urgent reform to help prevent chemical disasters and protect human health and the environment.
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