By: Rachel Meyer, Ohio River Valley 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
My name is Rachel Meyer and I am the Ohio River Valley Field Coordinator for Moms Clean Air Force, an organization with over 1.5 million members working to protect children from air pollution and climate change. I am from Independence Township, Beaver County in Pennsylvania.
I support the Proposal to Strengthen Standards for Synthetic Organic Chemical Plants and Polymers and Resins Plants and urge the EPA to finalize the most robust and comprehensive standards to protect the health of families living nearby.
Petrochemical manufacturing is one of the heaviest polluting industrial sectors in the country. My family’s home is located near petrochemical facilities, and we have experienced multiple high pollution events during times of start up, shut down, and malfunctions. The cumulative impacts of toxic pollution releases during SSM events can increase the risk of cancer as well as respiratory, cardiovascular, neurological, and reproductive problems for the people living nearby. Families living near petrochemical facilities should be protected from harmful pollution at all times, as promised in the Clean Air Act. I strongly support the removal of pollution exemptions during SSM and I urge the EPA to keep any new versions of SSM exemptions out of these rules before they are finalized.
As community members, we often are not told what is being emitted from a facility even when we can smell chemicals in the air. People in our community are scared about how the pollution is affecting their children. Children are especially vulnerable to pollution from these facilities because their bodies are still developing and because they breathe in more air relative to their size than adults. Breathing in more air can mean breathing in more pollution. Science has found an association between higher levels of air toxics, such as benzene and 1,3-butadiene, and increased rates of childhood leukemia. These same air toxics are commonly emitted by petrochemical facilities. Knowing how harmful air toxics are to health, but not knowing what is actually being emitted by local plants is a serious source of anxiety for me and far too many parents. The requirement for fenceline monitoring of six pollutants will improve transparency for communities living with these facilities that have a history of repeated violations. The latest, most advanced fenceline monitoring technology available must be required at every facility covered by these rules. Also, the current action levels should be lowered to be more health protective.
Flaring is another huge source of concern for communities like mine living near petrochemical facilities. We dread seeing the flames rise up often accompanied by plumes of dark smoke. The rule requiring increased combustion efficiency and monitoring for flaring is an additional needed safeguard for people’s health, but there needs to be a phaseout of open-flame stack flares as an additional requirement.
There must also be higher standards for leak detection and repair. The most advanced technologies should be required including optical gas imaging and these standards should apply for all facilities.
I want to commend the EPA for the inclusion of the community risk assessment. It is so important to take into consideration toxic emissions of nearby polluters. I hope to see this data factored into future rulemaking and look forward to seeing how it will further improve conditions for communities.
The proposed rules are so very needed for the protection of people in our communities. I thank the EPA for these rules and call on them 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. Thank you.