Public Comment to U S EPA on the proposed
"Refinery Rules"
more information on submitting public comments
here
Dear Gina McCarthy,
Global Community Monitor is writing in support of the
U.S. Environmental Protection Agency's efforts to strengthen refinery air toxics
emission limits and monitoring requirements to protect public health. The EPA
must reduce emissions of toxic chemicals from refineries based on the best
scientific understanding of the harm this hazardous pollution can cause,
especially for children, women of child bearing age and the elderly.
Let
me say first we support the bulk of the new rule, except for the flawed so
called "fenceline monitoring" section that fails to take into account many
important facts as well as the latest technologies which deliver data that
actually could inform corrective action by a refinery.
Today I'd like to
focus on a huge basic flaw in your staff proposal to use "benzene badges" to
absorb two weeks of air at a time to obtain an average of benzene
exposures.
As I am sure you are well aware, the largest US refineries are
located in clusters in port areas of Texas and Louisiana. In most cases, and
there some insignificant exceptions, the refineries are located directly
adjacent to one another and share a common fenceline on at least one boundary if
not several.
The refinery used for the journal article written to prop
up this flawed proposal, was curiously the Koch Brothers West Refinery in Corpus
Christi, TX. It is the only refinery in Corpus that does not share a fenceline
with its neighbor refineries. Please have your staff justify this choice and
rationale to not also study the vast majority of cases where refineries are
adjacent.
Obviously, with undeniable variability of wind direction and
changes over a two week period, no data of any value would inform corrective
action because you can never know which of all the fugitive sources in a
refinery contributed to the exceedence of of the risk based threshold. If you
add in additional large sources of one or more refinery, there is little that
can be said if anything about which refinery could be asked to "correct" the
excess. As you know, refineries are skilled at blaming the other
guy.
Another reason, there is no value in 2 week averages of benzene in
many refinery areas like Corpus, Houston, Lake Charles, Port Arthur, Wilmington
and throughout the region is that the refineries are located adjacent to at
least one major freeway. This means these refineries could just blame the
freeway and object to the plan to correct!
Thanks for listening,
Gina!
Best,
Denny
Denny Larson
Executive
Director
Global Community Monitor (GCM)
www.gcmonitor.org
Poverty
is not an accident. Like slavery and apartheid, it is man-made and can be
removed by the actions of human beings.
Nelson Mandela