By: Erandi Treviño, Texas State Coordinator, 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
Thank you for the opportunity to testify today. My name is Erandi Treviño and I am the Texas state organizer for Moms Clean Air Force and their Latino outreach program, Ecomadres. I live in Houston, surrounded by many of the roughly 80 Texas facilities covered by the proposed Chemical Manufacturing rule. Today I am here to call on the EPA to finalize the most robust and comprehensive standards to reduce air pollution from petrochemical facilities to protect the health of community members living nearby.
We know that the petrochemical industry creates a significant climate-warming greenhouse gas pollution while simultaneously releasing a host of toxic pollution known to impact health. According to an EPA analysis, the demographic makeup of communities near the plants covered under the chemical manufacturing proposal found a higher than-average percentage of residents who are African American, low income and/or Hispanic or Latino.
My neighborhood sits next to the Houston Ship Channel which is packed with chemical plants and refineries. It is located next to municipalities such as Deer Park that often see facility violations. Most recently, the Shell Deer Park chemical facility that caught on fire had a record of 1,946 violations over the past decade, including releases of toxic chemicals such as 1,3-butadiene. This facility is currently in “high priority violation” of the Clean Air Act with 12 of the last 12 quarters in noncompliance. There are 95 violations still active today—including the failure to properly control gasses venting from equipment. This facility has a long track record of noncompliance and toxic pollution releases and is not far from the ITC Deer Park facility that caught fire in 2019 releasing benzene and incurred 27 violations since that disaster. The effects on our health from all these toxic pollution releases are cumulative.
Making communities central to this rule would be an important step forward. Moms supports EPA’s efforts to analyze air-toxics risks at the community level that considers cumulative toxic emissions of nearby polluters. I encourage EPA to link the findings in the community risk assessment more directly to the regulatory requirements in the rule. Also, implementation of fenceline monitoring for six toxic air pollutants including benzene and 1,3-butadiene for all facilities along with detection limits and action levels that are protective of human health is crucial.
Air pollution from chemical and petrochemical facilities can increase risk for numerous health issues. It can cause cancer and raise the risk of respiratory, neurological, cardiovascular, and reproductive issues. As someone who suffers from several chronic health issues, I know that poor health can feel like a knee on our neck that cannot hold us back, but causes misery.
Moms supports the removal of exemptions for all start-up, shutdown, and malfunction episodes at these facilities so that companies are no longer allowed to release unlimited amounts of toxic chemicals during these times. The Gulf Coast has progressively seen more storms and Harris County has experienced some of the highest rates of climate weather events in the entire country. In the last few years, my mother’s home flooded with Hurricane Harvey, and my home saw damage from winter storm Uri. Extreme weather events have resulted in a spike of emissions and flaring. Moms support increased combustion efficiency and monitoring for flaring, including continuous emissions monitoring for the flaring stacks. EPA should require the phaseout of open-flame stack flares.
It is unconscionable that companies get a free pass to pollute when families are struggling to recover. I am urging the EPA to finalize a strong chemical manufacturing rule to protect families and children. Thank you.