Clean AirCouncil 

Statement by Saleem Chapman 

Director of Environmental Justice for the Clean Air Council 

Before the United States Environmental Protection Agency (EPA) 

On the Proposed Petroleum Refinery Sector Risk and 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 of Environmental Justice for the 

Clean Air Council. The Clean Air Council has been an environmental health advocate 

in the mid-Atlantic region since 1967 and is active on a number of environmental 

issues, including the reduction of environmental health risks within socially vulnerable 

communities. I sincerely appreciate this opportunity to speak in support of adopting the 

EPA's proposed rule to control residual risk from hazardous air emissions at the nation's 

petroleum refmeries. From the perspective of the near neighbors of refmeries such a rule 

is long overdue. 

Minority and low-income communities remain more readily affected by environmental 

pollution and the subsequent public health outcomes. Disproportionately, low-income 

and minority populations live in close proximity to oil refineries and, thereby, are 

exposed to a toxic combination of thousands of tons of hazardous pollutants. These 

pollutants are linked to increased rates of cancer, neurologicfll damage and other serious 

health impacts. 

The largest oil-refining complex on the eastern seaboard, Philadelphia Energy Solutions 

(formerly Sunoco ), is hosted by the exceptionally distressed neighborhoods of south and 

southwest Philadelphia, including Grays Ferry. Sunoco had a chronic history of serious 

environmental violations, and enforcement by government agencies can not be said to 

have truly protected the health, welfare and quality of life of the host community. 

Innumerable environmental, socioeconomic, and psychosocial stressors afflict Grays 

Ferry, earning this neighborhood the moniker of the "Forgotten Bottom." It is the home 

of less than 1 percent of Philadelphia's total population, but accounts for 10 percent 

of Philadelphia's recipients for "Section 8" housing, most of which is inhabited by 

persons of color. 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 of this neighborhood feeling 

helpless and powerless to protect their health. Unfortunately these residents do not have 

the economic resources to simply move to a healthier neighborhood. These are the very 

Americans that are most dependent on agencies such as the EPA to look after their 

interests. Can we honestly say that the EPA has met that obligation to the near neighbors 

of refineries? 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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the refinery going. Why is government so slow then to ensure that the emissions from 

such refineries are minimized and that the health of hosting communities is adequately 

protected? 

Ultimately this is an environmental justice issue. Federal standards on residual risk 

from refineries are not adequately designed to protect public 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 data to undertake health-protective measures. 

EPA's proposal takes significant steps in the right direction by requiring enhanced 

monitoring at the fence-line of refining 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 in the communities I work with, I urge EPA to adopt effective fence 

line monitoring for all polluting facilities sited in populated areas. Members of the 

neighborhood being asked to host such facilities deserve to know what they are actually 

being exposed to. EPA's proposed fence line monitoring may not be adequate to 

effectively inform residents. It appears that EPA will allow passive 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.