By: Lucia Valentine, West Virginia 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 Lucia Valentine and I am the West Virginia Organizer for Moms Clean Air Force. I am from Shepherdstown, West Virginia, and have lived in the Mountain State my whole life. I am here today because petrochemical manufacturing is one of the heaviest polluting industrial sectors in the country and I strongly support the proposed Chemical Manufacturing rule and call on EPA to finalize the most robust and comprehensive standards to reduce air pollution from petrochemical facilities that are harming people’s health and heating the climate.
More than 80% of the covered facilities under this rule making have violated pollution laws during the last three years (some, for every single quarter). Roughly 1/3 of the covered facilities under this rule making currently have what are classified by the EPA as the most significant and highest priority types of violations. In West Virginia, 4 facilities are covered under the proposed Chemical Manufacturing rulemaking including the Altiva chemical facility in Industry, West Virginia.
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, or Latino. Institute is one of just two majority-Black communities in the state. It is not by accident as chemical and Petrochemical facilities are commonly sited in communities that are disproportionately impacted by multiple pollution sources contributing to a cumulative pollution burden.
Approximately 1,000 feet away from the Altiva facility is the Union Carbide petrochemical facility that has very high ethylene oxide emissions contributing to the area having one of the highest cancer risk rates in the country. In majority-Black census tracts, the estimated risk of cancer from toxic air emissions is more than twice the risk found in majority-white tracts. This is why it is so important for EPA to consider the cumulative toxic emissions of nearby polluters and I support EPA’s efforts with the community risk assessment. I encourage the EPA to link the findings in the community risk assessment more directly to the regulatory requirements in the rule to protect communities overburdened by multiple pollution sources. 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.
Moms Clean Air Force is asking for EPA to remove exemptions for all start-up, shutdown, and malfunction episodes at these facilities, increase the combustion efficiency and monitoring for flaring, enhance leak detection and repair protocols for all hazardous chemicals across the entire facility, and implement precedent-setting fenceline monitoring for six toxic air pollutants. Communities living near chemical and petrochemical facilities need the latest, most advanced fenceline monitoring technologies with detection limits and action levels that would best protect public health. All facilities covered by these rules should have fenceline monitoring as a requirement connected to root-cause analysis and mandatory corrective actions.
The EPA must also link the new flaring restrictions, leak detection and repair requirements, fenceline monitoring, and other safeguards to the need to protect heavily exposed people living at the fenceline.
Again, I strongly support the proposed Chemical Manufacturing rule, and call on EPA to finalize the most robust and comprehensive standards to reduce air pollution from petrochemical facilities as quickly as possible. Thank you for your time today.