# API Comments on: EPA's Petroleum RefinerySectorRisk andTechnology Reviewand New Source Performance Standards

EPA Public Hearing, Galena Park, TX

MatthewTodd 8/5/2014API Comments at the August 5, 2014 EPA Public Hearing on the Proposed Petroleum Refinery Sector Risk and Technology Review and New Source Performance Standards Good morning. My name is MatthewTodd and I'm speaking today on behalfofthe American Petroleum Institute. API represents over 600 oil and natural gas companies, leaders ofa technology-driven industrythat supplies most ofAmerica's energy, supports more than 9.8 millionjobs and 8 percent ofthe U.S. economy, and, since 2000, has invested nearly $2 trillion in U.S. capital projects to advance all forms ofenergy, including alternatives. Our members are dedicated to continuous efforts to improve the compatibility ofour operations with the environment and our communities while economically developing energy resources and supplying high quality products and services to consumers. We recognize our responsibility to workwith the public, the government, and others to develop and to use natural resources in an environmentally sound mannerwhile protectingthe health and safety ofour employees and the public. Many ofour members will be directly impacted by the proposed Refinery Sector Rule which is the focus oftoday's public hearing.

I have three key points that I would like to make today.1. Air quality in the United States has improved significantly, continues to improve, and our industry is doing its partto contribute to this success. 2. After significant effort, the US EPA has concluded in this rulemaking that the public is protected with an ample margin ofsafety. 3. The safe operation ofour refineries to protect ourworkers and the community is our number one priority. Myfirst point is that air quality has improved significantly, continues to improve and our industry is contributingtothese improvements. According tothe EPA Report on the Environment, mean benzene concentrations have dropped by 66% from 1994-2009 nationwide. Locally, the improvements to air quality have been even more dramatic. The Houston Regional Monitoring Network, an extensive collection ofambient air monitoring stations across the Houston area, shows an 85% reduction of BTEX, a mixture of key pollutants. In fact, since 2006, all oftheir monitors have been well belowthe TCEQ's Air Monitoring Comparison Values for benzene. This term is used by TCEQ to collectively describe the safe concentrations ofa particular chemical in the air used to evaluate ambient air monitoring data. The U.S. oil and natural gas industry has been a key part ofthat improvement, investing over $268 billion since 1990toward improvingthe environmental performance of its products, facilities and operations. In the year2012 alone, approximately $14.9 billion was expended on environmental protection.
Mysecond key point is thatthe EPA has concluded in this rulemakingthat the public is protected with an ample margin ofsafetyfrom refinery emissions. Once again, EPA has reached this conclusion, this time after developing an entirely new protocol for refineries to reporttheir emissions and a multimillion dollar information collection request, including data collection from every refinery for all emission sources and direct emission testing for a number ofemission
sources. All ofthis information is then processed through conservative risk modelingwhich has determined that communities around refineries are protected with an ample margin ofsafetyfrom refinery emissions.

Whilethis is myfinal pointtoday, itgoes without sayingthatthe safe operation ofour refineries to protect ourworkers and the community is our number one priority. As such, API will be taking a close lookto ensure these proposed regulations don't compromise the safety ofourworkers and the community. For example, in this rule, EPA has proposed requirements prohibiting the use ofequipment whose sole purpose is to prevent over-pressuring ofequipment and avoid potentially catastrophic damage. This prohibition will not only increase safety risk butwill require many additional flares. Obviously, this part ofthe proposal needs to be revised from a safety perspective. Our written comments will address this provision in greater detail, as well as other parts of the proposal.

In closing, API appreciates the opportunityto provide this testimony on this important rulemaking for our industry. I'd like to reiterate that: 1. Air quality in the United States has improved significantly, continues to improve, and our industry is doing its partto contribute tothis success. 2. After significant effort, the EPA has concluded in this rulemaking thatthe public is protected with an ample margin ofsafety from refinery emissions. 3. The safe operation ofour refineries to protect ourworkers and the community is our number one priority. We will be submitting detailed comments tothe docket to ensure thatthe final regulation doesn't inhibitthe safe operation ofour refineries, doesn't increase emissions from any sources, and is cost-effective.

Thank you.