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CFASE 

Coalition For A Safe Environment 

1601 N. Wihnington Blvd., Ste. B 

Wihnington, CA 907 44 

jnm4ej@yahoo.com 310-704-1265 

July 16, 2014 

EPA Docket Center 

U.S. Environmental Protection Agency 

William Jefferson Clinton Building 

1200 Pennsylvania Ave., NW, Mail Code 28221 T 

Washington, DC 20460 

Re: Attention Docket ID Number EPA-HQ-OAR-2010-0682 

Petroleum Refinery Sector Risk and Technology Review & New Source Performance Standards 

Su: Public Comments Submission 

Los Angeles Oil Refinery Communities Support New Stricter Air Pollution Standards 

And Demand The Maximum Achievable Toxic Emissions Reductions To Protect Our Health 

Dear Administrator McCarthy/US EPA: 

Los Angeles Oil Refinery Communities support adoption of stricter oil refinery air pollution standards 

and stricter regulation of oil refinery manufacturing operations. Our communities are in a public 

health crisis because regulatory agencies have allowed oil refineries to releases hundreds of tons of 

toxic air pollution each year. 

Our children and families are suffering and dieing from lung cancer, leukemia, lymphoma, myeloma, 

asthma, COPD and numerous other health illnesses because we are exposed to unsafe levels of toxic 

and carcinogenic chemicals every day and every year. 

Are children's lives and futures are at stake, and as parents we must take every action to assure that 

the new amendments will significantly reduce our children's exposure to toxic air pollution from oil 

refineries in our communities. EPA has a legal responsibility to protect our rights to clean air and good 

health. 

We have thousands of families who live fence-line to major oil refineries who breathe refinery toxic 

chemicals every day. There are equipment failures, malfunctions, power outages, flaring, fires and 

explosions regularly at all oil refineries. 
Our organization reviewed flaring data for all 6 major oil refineries in Los Angeles from the year 2000-

2011 and discovered that flaring had increased every year at every oil refinery and there was not one 

investigation by the California South Coast Air Quality Management District, California Air Resources 

Board or the US EPA let alone any enforcement action. 

We have reviewed the US EPA proposed amendments and they are not enough to protect our children 

and communities health and guaranty our safety. The amendments do not require any chemical or 

emission category to be reduced to less than significant. 

We wish to request the following 15 requirements be incorporated into the new proposed 

amendments: 

1. Mandatory Flare Reduction Plan. 

2. Mandatory use of Vapor Recovery Systems to eliminate & prevent flaring. 

3. Mandatory 24/7 Real Time Fence-Line Monitoring of all chemicals released by oil refineries. 

4. Mandatory Real Time On-Line Public Website Reporting of all daily air pollution & flaring 

events. 

5. Mandatory Emergency Back-Up Power to prevent flaring from power outages. 

6. Mandatory Flare Combustion Efficiency Standards. 

7. Mandatory Maintenance & Parts Replacement Plan to prevent breakdowns & malfunctions. 

8. Mandatory Maximum Achievable Control Technology for all air pollution emission sources. 

9. Mandatory Phase Out Plan of Dangerous & Toxic Chemicals that cause health & safety impacts. 

10. Mandatory Public Health Exposure Limit on all Toxic Chemicals. 

11. Mandatory Health Impact Assessments for oil refineries in addition to Health Risk Assessments. 

12. No Annual Averaging of Emissions Data to hide high emissions releases on flaring days. 

13. Eliminate all Startup, Shutdown & Malfunction emissions releases reporting exemptions. 

14. A Life Time Cancer Risk no higher than 1 in 1 million for a single chemical or cumulative 

chemicals. 

15. Request US EPA sponsor Public Health Studies of fence-line communities to oil refineries. 
We wish to submit photos of some of our Los Angeles Community members who are impacted by 

exposure to oil refinery toxic air pollution: 

We wish to submit photos of Los Angeles oil refinery flaring, fires and explosions: 

Respectfully Submiited, 

r7!~ JesseN. Marquez 

Executive Director