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 ofthe Barbara JordanMickey Leland School of PublicAffairs at Texas Southern University. First, Iwant to thankthe EPAfor holding this hearing and allowing the publicto speak

. It is also significantwhere 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. Forthe past three decades, I have worked with residents who live on the feneline with refineries in California, Michigan, NewJersey, Pennsylvania, Louisiana and Texas. I have traveled in dozens ofthese 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 foryears for meaningful federal protection from the pollution from refineries. Many state environmental agencies have failed in providing this much needed protection

. Many environmentaljustice communities have little confidence in the states to lead on refinery emissions reduction. That'swhy 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 agencywould go even further. Nevertheless, Istrongly 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 howthese chemicals may affecttheir health

.These residents also have a right to be protected from harmful pollutants. Refineries are not randomly distributed across theAmerican landscape and most Americans don't live next to one. So fortoo long the problems, concerns and challenges offenceline communities have been somewhat invisible and ignored. We all wish emission controls and level of protection were such that the refinery CEOs and theirspouses, children and grandmothers would feel safe living next door. However, they don't live next doorto these facilities. We know who lives next doorto the refineries in the GulfCoast in Louisiana's petrochemical corridor along the Mississippi Riverfrom Baton Rouge to New Orleans, in PortArthur, 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 ofchildren. Many ofthese neighborhoods have schools,parks and playgrounds, and low-income public housing next-doorto 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 "sacrificezones
." Requiring oil refiners to take more aggressive measures to reduce theirtoxic emissions from flares, storage tanks and other sources is a big deal. The impact ofthese new requirements will have disproportionate positive benefits to fence line communities who have too long suffered from refinery pollution

.And in the end, ourentire society benefits because offewer illnesses. Numerous studies, including some of my own, have documented that poor people and people ofcolor 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 mattersworse. Residents in these communities are exposed to higher levels ofpollution than the rest ofthe 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 forthe first time to measure concentrations of benzene at theirfence lines and provide the data to the public

. Itwould forthe 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 increasethe risk ofdeveloping cancer. EPA should require fence line monitoring that mandates use ofthe best current technology to give neighborhoods a real-time, continuous measure of pollution, and not justa snapshot or long-term average that masks peak exposure levels

. To be effective, the standards also must be accessibleto the public, enforceable and requiring corrective action be taken by refineries to quicklyfix 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 offlares

. We are pleased that EPA has committed to undertaking this long overdue rulemaking and we urgethe agencyto use its authority to ensure equal protection from pollution for all Americans.



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