# Clean

# AirCouncil
Statement by Saleem Chapman Director ofEnvironmentalJustice for the Clean Air Council Before the United States Environmental Protection Agency (EPA) On the Proposed Petroleum Refinery SectorRiskand Technology Review and New Source Performance Standards, 79 Federal Register 36880 August 5, 2014
Good Morning. My name is Saleem Chapman and I am the Director ofEnvironmental Justice for the CleanAir Council. The Clean Air Council has been an environmental health advocate in the mid-Atlantic region since 1967 and is active on a number ofenvironmental issues, including the reduction ofenvironmental health risks within socially vulnerable communities. I sincerely appreciate this opportunity to speak in support ofadopting the EPA'sproposed rule to control residual risk from hazardous air emissions at the nation's petroleumrefmeries. Fromthe perspective ofthe near neighbors ofrefmeries such a rule is long overdue. Minority and low-income communities remain more readily affected by environmental pollution and the subsequentpublic health outcomes. Disproportionately, low-income and minority populations live in close proximity to oil refineries and, thereby, are exposedto a toxic combination ofthousands oftons ofhazardous pollutants. These pollutants are linked to increased rates ofcancer, neurologicfll damage and other serious health impacts.

The largest oil-refining complex onthe eastern seaboard, PhiladelphiaEnergy Solutions (formerly Sunoco), is hosted by the exceptionally distressed neighborhoods ofsouth and southwest Philadelphia, including Grays Ferry. Sunoco had a chronic history ofserious environmental violations, and enforcementby government agencies can not be said to have truly protected the health, welfare and quality oflife ofthe host community.

Innumerable environmental, socioeconomic, and psychosocial stressors afflict Grays Ferry, earning this neighborhood the moniker ofthe "ForgottenBottom." It is the home ofless than 1percent ofPhiladelphia's total population, but accounts for 10 percent ofPhiladelphia's recipients for "Section 8" housing, most ofwhich is inhabited by persons ofcolor. Even more disconcerting is that the National Air Toxics Assessment (NATA) determined that this community faces elevated risk for cancer and other noncancer negative health effects. This has left many residents ofthis neighborhood feeling helpless andpowerless to protect their health. Unfortunately these residents do nothave the economic resources to simply move to a healthier neighborhood. These are the very Americans that are most dependent on agencies such as the EPAto look after their interests. Can we honestly say that the EPA has met that obligation to the near neighbors ofrefineries? When the Sunoco plant threatened to close down, the federal, state and local government rushed to find a new buyer and to bend regulatory requirements to keep

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www.lwiller com/cleanaircouncilthe refinery going. Why is government so slow then to ensure that the emissions from suchrefineries are minimized and that the health ofhosting communities is adequately protected? Ultimately this is an environmentaljustice issue. Federal standards on residual risk from refineries are not adequately designed to protectpublic health equitably. Socially vulnerable communities already have diminished capacity to manage exposure to environmental health risk. This capacity is further diminished when these communities are not afforded the requisite datato undertake health-protective measures.
EPA's proposal takes significant steps in the right direction by requiring enhanced monitoring at the fence-line ofrefining facilities and by limiting emissions that occur during start-up and shutdown, and by requiring the use technology to further lower dangerous emissions. Once finalized, these changes will assure more limited emissions, better plant-wide air monitoring and hopefully more vigorous enforcement. On behalf ofthe residents inthe communities I work with, I urge EPA to adopt effective fence line monitoring for all polluting facilities sited inpopulated areas. Members ofthe neighborhood being asked to host such facilities deserve to know whatthey are actually being exposed to. EPA's proposed fence line monitoring may not be adequate to effectively inform residents. Itappears that EPA will allowpassive systems that will require lab analysis for results thereby delaying the resident's ability to know in real time what they are being exposed to.

I appreciate this opportunity to appear before this panel, and this concludes my testimony.