COMMENTS ON EPA PROPOSED UPDATES TO EMISSIONS 

STANDARDS FOR REFINERIES 

DR. ROBERT D. BULLARD 

TEXAS SOUTHERN UNIVERSITY 

3100 CLEBURNE AVENUE 

HOUSTON, TEXAS 

PHONE: 713/313-6840 

EMAIL: BULLARDRD@TSU.EDU 

AUGUST 5, 2014 

Good morning. My name is Dr. Robert D. Bullard and I Dean of the Barbara JordanMickey Leland School of Public Affairs at Texas Southern University. First, I want to 

thank the EPA for holding this hearing and allowing the public to speak. It is also 

significant where this hearing is being held in EPA Region 6-not in Dallas but in Galena 

Park-a refinery community that typifies why these new proposed rule changes are 

desperately needed. I have to ask, "What took you so long?" That's a rhetorical 

question. We all know the answer. 

For the past three decades, I have worked with residents who live on the feneline with 

refineries in California, Michigan, New Jersey, Pennsylvania, Louisiana and Texas. I 

have traveled in dozens of these communities and have seen with my own eyes and 

heard with my own ears enough "horror" stories to fill at least a dozen of my books. 

Fenceline communities have waited for years for meaningful federal protection from the 

pollution from refineries. Many state environmental agencies have failed in providing this 

much needed protection. Many environmental justice communities have little confidence 

in the states to lead on refinery emissions reduction. 

That's why what is being proposed by EPA is a big deal. The agency estimates that the 

rules will reduce toxic air emissions by 5,600 tons a year. Many of us had hoped the 

agency would go even further. Nevertheless, I strongly support EPA's effort to move 

forward-instead of backward when it comes to refinery emissions. Residents who live 

on the fenceline with these refineries have a right to know what they are breathing and 

how these chemicals may affect their health. These residents also have a right to be 

protected from harmful pollutants. 

Refineries are not randomly distributed across the American landscape and most 

Americans don't live next to one. So for too long the problems, concerns and challenges 

of fenceline communities have been somewhat invisible and ignored. 

We all wish emission controls and level of protection were such that the refinery CEOs 

and their spouses, children and grandmothers would feel safe living next door. 

However, they don't live next door to these facilities. We know who lives next door to 

the refineries in the Gulf Coast in Louisiana's petrochemical corridor along the 

Mississippi River from Baton Rouge to New Orleans, in Port Arthur, Houston and Corpus 

Christi, Texas. The affected communities living in close proximity to refineries do not 

look like America. They are disproportionately Latino, African-American, and lowincome with higher percentages of children. Many of these neighborhoods have schools, 
parks and playgrounds, and low-income public housing next-door to these refineries 

which pose potential health threats to our most vulnerable population-children. 

This is not a pretty picture. The EPA should not allow any families and especially 

innocent children to be overburdened with pollution and their neighborhoods to become 

toxic "sacrifice zones." 

Requiring oil refiners to take more aggressive measures to reduce their toxic emissions 

from flares, storage tanks and other sources is a big deal. The impact of these new 

requirements will have disproportionate positive benefits to fence line communities who 

have too long suffered from refinery pollution. And in the end, our entire society benefits 

because of fewer illnesses. 

Numerous studies, including some of my own, have documented that poor people and 

people of color in the United States are disproportionately impacted by environmental 

hazards in their homes, schools, neighborhoods, and workplace. Refinery pollution 

poses special health threats to community residents that generally have higher 

concentration of uninsured-heightening their vulnerability. 

One need not be a rocket scientist to understand dumping pollution on communities that 

have persistent health disparities can only make matters worse. Residents in these 

communities are exposed to higher levels of pollution than the rest of the nation and 

experience certain diseases in greater number. Residents who live on the fenceline with 

refineries are paying a high price in the form of higher medical bills and missed school 

and work days, and loss wages. 

The proposed rules would require refiners for the first time to measure concentrations of 

benzene at their fence lines and provide the data to the public. It would for the first time 

require air monitors on the fence line to measure benzene concentrations. Exposure to 

toxic air pollutants, such as benzene, can cause respiratory problems and other serious 

health issues, and can increase the risk of developing cancer. 

EPA should require fence line monitoring that mandates use of the best current 

technology to give neighborhoods a real-time, continuous measure of pollution, and not 

just a snapshot or long-term average that masks peak exposure levels. To be effective, 

the standards also must be accessible to the public, enforceable and requiring corrective 

action be taken by refineries to quickly fix violations. 

These new rules also would require refiners to upgrade pollution controls for storage 

tanks and to ensure that gases are properly destroyed through flaring . EPA should allow 

public access to the monitoring report of flares. 

We are pleased that EPA has committed to undertaking this long overdue rulemaking 

and we urge the agency to use its authority to ensure equal protection from pollution for 

all Americans. 

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