What would EPA's proposed rule change at oil refineries? July 25, 2014 

Fenceline Monitoring 

For the first time, the EPA would require 

refineries to monitor air concentrations of 

benzene, a toxic chemical that 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 on the 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/m 3

.) An oil refinery that exceeds 

this limit must develop and implement a 

corrective action plan for reducing benzene 

emissions. If benzene emissions continue to 

exceed the limit, the refinery must submit 

proposed actions for lowering benzene 

emissions to the EPA for EPA's approval. 

Eliminate Exemptions from Air Pollution 

Regulations During Startup, Shutdown, 

and Malfunctions 

EPA would prohibit all refineries from 

releasing hazardous air pollutants into the air 

from relief valves, and require monitoring of 

relief valves 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 action to stop excess pollution. 

EPA should make any act or attempt to 

manipulate the monitor or falsify 

monitoring data a federal crime. A refinery 

company that submits monitoring data to 

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 EPA RULE 

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 of smoke 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 BY LA GROUPS* 

General support for this requirement. 

EPA should allow public access to the 

monitoring reports of flares at oil refineries 

without significant delay between the time 

of flaring and the monitoring report. 

EPA should provide a clear explanation of 

this new requirement to fenceline 

communities. 

(No data] 

* The comments were developed by environmental justice groups, including fence line community organizations, in Louisiana who attended a 

training session hosted by the Deep South Center for Environmental Justice. 

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