By: Tracy Sabetta, Ohio 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. My name is Tracy Sabetta, and I am the state coordinator for Moms Clean Air Force in Columbus, Ohio. On behalf of our 89,000 Ohio members, I strongly support the 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.
The petrochemical and chemical industry have a long history of putting the health and safety of community members and workers at risk. My father worked for decades at Diamond Shamrock Chemical located on the “Chemical Shore” in Ashtabula, Ohio. Our family lived nearby, and I remember as a child riding my bike past Fields Brook, a Lake Erie tributary where the plant discharged its waste. You could smell the chemicals in the air and water. That area is now a superfund site. Then on January 17,1986, a chemical holding tank ignited at the facility and caused an explosion that killed two of my father’s dearest friends, injured 18 and sent a green chemical cloud into the air. My father was covered in that green dust and was rushed to the hospital for decontamination. The doctors said he was fine, but our community would never look at those chemical plants on the shore the same way again. People need protections from these polluting facilities.
Thankfully the proposed chemical manufacturing rule would help reduce air toxics and the related cancer risks for workers and people who live near the more than 200 covered facilities that make chemicals and petrochemicals. More than 80 percent of those facilities have violated pollution laws during the last three years.
Twelve of these facilities are in Ohio. One example is BP-Husky Refining Company in Oregon, not far from Toledo. This facility, which was recently sold to Cenovus Energy, logged three quarters of violations of the Clean Air Act and was charged with serious violations related to an explosion that claimed 2 workers' lives in 2022. These are the kinds of egregious violations that will be addressed under this proposed rule.
When fully implemented, the proposed rule would reduce air toxic emissions from these facilities. This can help lower the risk of workers and community members developing cancer as well as respiratory, neurological, cardiovascular, and reproductive issues. Moms supports the provisions included in this rule and urges you to strengthen them since there are still critically important areas to be addressed:
We support the removal of the start-up, shutdown, and malfunction (SSM) exemptions for polluting episodes at facilities and want to make sure there are no added exemptions.
In addition, we support increased combustion efficiency and monitoring for flaring, including continuous emissions monitoring for the flaring stacks.
One of the most critical provisions is enhanced leak detection and repair (LDAR) protocols for all hazardous chemicals across the entire facility. The failure to revise the leak standards for all toxic chemicals at the vast majority of facilities is a missed opportunity in this rule and should be addressed before finalization.
To best protect heavily exposed individuals living at the fenceline, we support the implementation of precedent-setting fenceline monitoring at all covered facilities for six toxic chemicals including vinyl chloride—a toxic chemical everyone in Ohio became intimately familiar with following the February 3rd train derailment in East Palestine, Ohio. Vinyl chloride is associated with increased risk of lung and liver cancer, brain cancer, and other negative health impacts. Finally, while we appreciate the effort made by the EPA to analyze air toxics risks at the community level, we would urge EPA to use its own community-based risk assessment data to set standards that are fully protective of people’s health.
On behalf of my family and Moms Clean Air Force in Ohio, I strongly support the 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. Thank you.