Comments to the EPA Science Advisory Board – Fenceline Monitoring July 16, 2013

Anna Hrybyk 2

By Anna Hrybyk, Program Director

My name is Anna Hrybyk, I am a Master in Public Health and the Program Manager for the Louisiana Bucket Brigade.  We work with communities who live on the fenceline of refineries and chemical plants across the state.  We are currently most active with community groups in Shreveport and Baton Rouge.

Based on our review of the presentations to the SAB today, I am requesting that the EPA receive more scientific guidance on fenceline monitoring in order to ensure the best quality data on emissions and accurately measure spikes in multiple air pollutants harmful to health that are frequent during malfunctions.

This guidance would greatly further the prevention of petrochemical accidents which in Louisiana alone are averaging 10 per week according to reports to the National Response Center, and at least 2 accidents per week are from the refineries.  To clearly illustrate the problem with the lack of fenceline monitoring, I would like to draw your attention to a benzene leak from last summer at the ExxonMobil Baton Rouge Refinery in downtown Baton Rouge.

There are over 59,000 people who live within 2 miles of the ExxonMobil Baton Rouge, 94% are African American and 50% of the children are living in poverty.  The refinery is a large part of a sprawling petrochemical complex that includes 19 other permit holders including Honeywell, Formosa Plastics, and Lion Copolymer.

On June 14, 2012 Exxon reported a spill of 10 pounds of benzene.  Horrible VOC odors permeated the community, two babies went to the hospital and 400 workers were being monitored for exposure.  How can 10 pounds of benzene do that you ask?  Well so did we.  After we blew the whistle on Exxon, the company came forward 5 days later and stated that it was actually over 28,000 pounds of benzene that spilled.  No one in the community was notified.  When emergency responders did show up, their PID hand held air monitors could not detect below 1ppm of total VOCs so did not pick up harmful levels of benzene in the air.

Community health could have been protected if there were quality fenceline monitors.  That is why we are requesting today that this Board evaluates for more scientifically accurate monitoring techniques.

We strongly recommend that the Board evaluates the passive samplers – they are not adequate.  They average away the peak exposures and guarantee that the levels of Benzene reported are low – an industry dream come true.

They did a pilot in Corpus Christi that showed there were no benzene issues there while the auto GCMS stations in town using real time measurements showed the opposite and these readings helped DOJ to win a criminal case against Citgo.  EPA should not waste time and money on passives samplers.

The fenceline monitoring system that we recommend provides the best quality data on emissions is:

  1. Community air monitoring stations (Continuous Auto Gas Chromatograph, MetONE PM Sampler, TO-15 Discrete Grab Samples) located in all residential areas within 1 mile of a petrochemical complex measuring for PM 2.5, PAHs, H2S, ammonia, ozone, benzene, toluene, ethylene, xylene 1,3 Butadiene, dichloromethane, carbon tetrachloride, tetrachloroethylene, vinyl chloride, and ethylbenzene.
  1. Continuous Open Path UV and Continuous Boreal Tunable Diode Lasers along all perimeters of a petrochemical complex next to residential areas testing for benzene, toluene, p-Xylene, sulfur dioxide, carbon disulfide and hydrogen sulfide.

Why should the EPA and any community bombarded by petrochemicals settle for anything less than what Chevron in Richmond and others are already doing?

Richmond Community Air Monitoring Program Work Plan: RichmondCommunity Air Monitoring Workplan11712withapp

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