## Whatwould EPA's proposed rule change at oil refineries? July 25, 2014



### FencelineMonitoring Forthe first time, the EPA would require refineries to monitor air concentrations of benzene, a toxic chemicalthat can cause cancer. The refineries are required to make the raw data available to the public through an EPA database. For each refinery, 12 to 24 monitors would be installed onthe perimeter. The monitors would collect air samples for a two week period. The EPA has set a benzene limit of9 ug/m3• (The Louisiana Toxic Air Pollutant Ambient Air Standard for benzene is 12 ug/m3 .) An oil refinerythat exceeds this limit must develop and implement a corrective action plan for reducing benzene emissions. Ifbenzene emissions continue to exceed the limit, the refinery must submit proposed actions for loweringbenzene emissions to the EPA for EPA's approval.



### EliminateExemptions fromAirPollution RegulationsDuringStartup, Shutdown, andMalfunctions
EPA would prohibit all refineries from releasing hazardous air pollutants into the air from reliefvalves, and require monitoring of reliefvalves to ensure compliance. Under this rule, it is no longer a defense that unpermitted pollution released during startup, shutdown or malfunction at an oil refinery was "unavoidable." benzene concentrations. A benzene concentration over 9 ug/m3 is prohibited.

No more excuses for unpermitted air pollution during oil refinery malfunctions, startups, and shutdowns. General support for this requirement. EPA should also require real-time air monitors to shorten the monitoring time period. The data from real-time monitors should be transmitted from the monitors to an EPA website that the public can access and take actionto stop excess pollution. EPA should make any act or attempt to manipulate the monitor or falsify monitoring data a federal crime. A refinery companythat submits monitoring datato the EPA should sign a sworn statement that the data was not manipulated or falsified in anyway. EPA should require refineries to split samples with nearby communities. EPA should require verification of monitoring data by an independent 3rd party. General support for this requirement.
EPA should require that states, like Louisiana, enforce the law when excess pollution occurs during a malfunction, startup, or shutdown at an oil refinery.
EPA should prohibit states, like Louisiana, from issuing permit waivers that allow increased air pollution.

### THE PROPOSED EPARULE Storage Tank Emission Controls EPA would update regulations for storage tanks at oil refineries with new technology controls to lower emissions. These regulations would also apply to smaller tanks.



### Limits on Flaring EPA would require new monitors and new operations to reduce flaring and the toxic gaseous clouds ofsmoke caused by flaring.



### Acceptable cancer risk from oil refinery pollution EPA would not require any change to oil refinery emissions or operations based on its assessment that cancer and non-cancer health risks from exposure are acceptable. 

### WHAT WOULD CHANGE

Updated controls to reduce emissions from storaae tanks

.

No more flaring with visible emissions that exceed 5 minutes in a 2 hour eriod.

No change. 

### COMMENTS BYLA GROUPS* General support for this requirement.

EPA should allow public access to the monitoring reports offlares at oil refineries without significant delay between the time offlaring and the monitoring report. EPA should provide a clear explanation of this new requirement to fenceline communities.

(No data]



## * The comments were developed by environmentaljustice groups, including fenceline community organizations, in Louisiana who attended a training session hosted bythe Deep South Center for Environmental Justice. -.;:::::===wr---:-

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