NACAA 

national association of clean air agencies 

BOARD OF DIRECTORS 

Co-Presidents 

George S. Aburn, Jr. 

Maryland 

Merlyn Hough 

Springfield, OR 

Co-Vice Presidents 

Stuart A. Clark 

Washington 

Thomas Huynh 

Philadelphia, PA 

Co-Treasurers 

Barry R. Stephens 

Tennessee 

Ursula Kramer 

Tucson, AZ 

Past Co-Presidents 

David J. Shaw 

New York 

Barry R. Wallerstein 

Los Angeles, CA 

Directors 

Mark Asmundson 

Mount Vernon, WA 

Rick Brunetti 

Kansas 

Robert H. Colby 

Chattanooga, TN 

Richard Corey 

California 

Sandra Ely 

New Mexico 

Anne Gobin 

Connecticut 

David Klemp 

Montana 

Bart A. Sponseller 

Wisconsin 

Richard A. Stedman 

Monterey, CA 

Executive Director 

S. William Becker 

Testimony of Arturo Blanco 

on behalf of the National Association of Clean Air Agencies 

on the U.S. Environmental Protection Agency's 

Proposed Risk and Technology Review Standards for 

Hazardous Air Pollutants from Petroleum Refineries 

(Docket ID No. EPA-HQ-OAR-2010-0682) 

Galena Park, Texas 

August5,2014 

Good Afternoon. My name is Arturo Blanco and I am the Chief of 

the Bureau of Pollution Control and Prevention in the Houston Department 

of Health and Human Services. I am here today on behalf of the National 

Association of Clean Air Agencies - or NACAA - of which I am a Past 

President. NACAA members include 42 state and 116 local air pollution 

control agencies that partner with EPA to implement and enforce the 

Clean Air Act. I am pleased to have the opportunity to testify and to 

provide some initial reactions to EPA's recently proposed Risk and 

Technology Review Standards for the Petroleum Refinery Sector. 

NACAA has long been concerned about emissions of hazardous air 

pollutants from refineries. According to EPA, refinery emissions include 

benzene, 1-3-Butadiene, naphthalene and other compounds, which are 

associated with a variety of adverse health effects, including cancer, 

neurological effects, blood disorders, damage to the liver, skin illnesses, 

depression of the immune system and other serious disorders. 

Additionally, because of their locations, many petroleum refineries pose 

special environmental justice concerns. NACAA believes these sources 

should be well controlled and that public health should be afforded the 

maximum protection the law provides. 

In light of the serious public health concerns, and because the 

current standards for this source category are outdated, NACAA fully 

supports EPA's efforts to address emissions from petroleum refineries. 

We are pleased that EPA has proposed a rule that calls for additional 

measures for these sources, which include requirements related to 

fenceline monitoring; flaring; start-up, shutdown and malfunction; storage 

tanks; and delayed coking units. 

During the comment period, NACAA will continue to review the 

proposed rule and submit more complete written comments by the 

deadline. However, based on our preliminary review, today I would like to 

raise issues for further consideration and offer some suggestions to 

ensure that the proposed rule is successful. 

444 North Capitol Street, NW • Suite 307 • Washington, DC 20001 • phone 202.624.7864 • fax 202.624.7863 • www.4cleanair.org 
Fenceline Monitoring 

EPA's proposal would require fenceline monitoring. Specifically, it includes an 

annual average benzene concentration to be measured using two-week passive 

samples placed at the refinery's perimeter. 

NACAA fully supports a fenceline monitoring requirement. However, our 

member agencies have concerns about the use of passive monitoring over a two-week 

period, rather than using real-time monitoring. For example, it could be difficult to 

determine when a spike in emissions actually occurred or, worse, emissions spikes may 

not be flagged at all if they are averaged within two weeks' worth of data. Additionally, 

there would be a lag time in the availability of the data to regulatory authorities and the 

public. We recommend EPA more thoroughly analyze the benefits and costs of realtime versus passive monitoring before issuing a final rule. NACAA urges EPA to opt for 

the strategy that provides the best information that is most accessible for the public, the 

regulators, and for the facilities themselves, and provide a means to approve alternative 

equivalent fenceline monitoring 

While NACAA supports a benzene action level, we have concerns about the 

action level of 9 11g/m3 that EPA proposed. Benzene is a carcinogen associated with 

serious health effects. Houston conducted a study that concluded that average 

benzene concentrations at all monitors, including those in industrial areas near 

petroleum refineries, are considerably below the proposed action level (even before the 

background adjustment). So, NACAA members are concerned that the proposed action 

level is too high and will not provide any significant health protection to the public. We 

encourage EPA to examine all available data and reconsider what the best action level 

should be. 

Risk Assessment 

NAACA shares EPA's goal of protecting public health. However, the proposal 

states that, using MACT-allowable emissions, the estimated maximum individual lifetime 

cancer risks are up to 100 in one-million and that the risks are "acceptable." We have 

serious concerns with this level of risk. Moreover, NACAA has repeatedly 

recommended improvements to EPA's risk assessment methodology during numerous 

rulemakings. If conducted properly, an improved risk assessment could show that the 

risks are even higher than the already unacceptable levels EPA has estimated. We 

strongly recommend that EPA reevaluate the risks related to petroleum refinery 

emissions, based on our recommended parameters, and ensure that the final rule 

adequately protects public health consistent with the mandates of Section 112 of the 

Clean Air Act. 

I thank you for this opportunity to testify. As I stated earlier, these are NACAA's 

preliminary reactions and the association will submit additional comments by the 

deadline. I am happy to answer any questions you have. 

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