Healthy Indoors Magazine
Issue link: https://hi.healthyindoors.com/i/1489776
Healthy Indoors | 53 wide-ranging risks, including malfunctions, inoperative lights and other safety equipment, temperature excursions, tank overflows, and dangerous chemical reactions. We urge EPA to strengthen its proposal by requiring robust back-up power systems for affected processes, and we encourage the agency to help bring about the expanded adoption of community microgrids powered by renewables. • Facility siting. By focusing narrowly on the risk of harm from a single release from a single facility, the EPA proposal fails to capture the magnitude of exposure risk and to account for social conditions and past exposures that exacerbate these risks. We urge EPA to require that facility siting decisions include the evaluation of cumulative pollution exposures, recognizing that many communities live near multiple facilities. • Safer Technology and Alterna- tives Analysis. The proposed rule does not require dangerous facilities to use inherently safer chemicals, processes, or techno logies, even when such alternatives are readily available and feasible. We urge EPA to require all Risk Management Program facilities to assess the availability of safer technologies and to require implementation of safer technologies identified – not simply documentation of their existence. EPA's proposal would require only specific industrial sectors (petroleum and coal products manufacturers and chemical manufacturers) to conduct these alternatives evaluations – and only if the facilities are locat- ed within a mile of each other. Moreover, EPA makes imple- mentation of the safer alterna- tives completely optional. No other types of facilities are asked to conduct alternatives analyses except those using hydrogen fluoride (HF) in an alkylation unit (HF is used as a catalyst in making high-octane gasoline). Hydrogen fluoride presents an extraordinary hazard; HF vapor clouds can sicken or kill workers and residents for miles around. EPA acknowledges that recognized safer alternatives are available and have been success- fully implemented, yet the agency does not tell companies to transi- tion away from hydrogen fluoride. • Worker participation. Recognizing that workers face the greatest risk and have a deep understanding of system operations and associated hazards, we support provisions enabling workers (including