Air Pollution Permitting and the Texas Commission on Environmental Quality Neil Carman, PhD February 20, 2017

Texas Commission on Environmental Quality • Air permits regulate air pollutants. • Criteria air pollutants: particles, sulfur dioxide, nitrogen oxides, lead, carbon monoxide, ozone. • Air toxics: benzene and others.

Texas Commission on Environmental Quality • Flaws in air permits - 100% • Flaws in plant air monitoring- 100% • Flaws in complaint investigations • Flaws in enforcement - common

Texas Commission on Environmental Quality • Flaws in air permits – require a Flare Gas Recovery System? • $15 million – cost of 1 new FGRS • Exxon - Ground Multi-Point Flare

Texas Commission on Environmental Quality • Ground flares emit smoke? Quantity? • It’s possible to measure and calculate all the soot particles. • Will Exxon monitor its soot particles? • Tiny soot particles are regulated.

• Ethane cracker - C2H6 hydrocarbon • Ethane  Ethylene • Ethylene C2H4 – forms rings if it’s burned without sufficient oxygen, time, temperature, turbulence. flares can easily smoke.

Health Effects of Air Pollution • Smoke, soot – tiny particles PM2.5 • Soot particles are released by flares and burning fossil fuels. • PM2.5 particles made of unburned chemical toxins called PAHs.

Health Effects of Air Pollution • PAHs – Polycyclic Aromatic Hydrocarbons in smoke particles. • Dozens of PAHs – 40 by CARB are human cancer-causing substances. • PAHs are carcinogens – Benzo-a- pyrene (BAP) – benzene toxin

Health Effects of Air Pollution • PAHs are in the visible & invisible smoke from industrial plants. • Soot particles and PAHs are not monitored continuously in stacks. • Air permits place limits on PM2.5

Health Effects of Air Pollution Benzene

Health Effects of Air Pollution

Texas Commission on Environmental Quality • Flaws in air permits - 100% • Permits list criteria pollutants & a few air toxics (benzene NESHAPS). • No mention of Benzo-a-pyrene or other PAHs. • No specific limit for Benzo-a-pyrene or other PAHs.

Texas Commission on Environmental Quality • Flaws in plant air monitoring- 100% • No precise monitoring and tracking of all PM2.5, benzo-a-pyrene, PAHs. • Flares tend to be poorly monitored. Technology exists to measure benzene from flares if required.

Texas Commission on Environmental Quality • Flaws in complaint investigations • Timeliness in responding – critical to confirm violations. Tardiness! • Must confirm a violation at your home, but winds can shift plume. • TCEQ tends to favor industry.

Texas Commission on Environmental Quality • Flaws in enforcement cases. • Many violations are not counted or cited in the violation letters. I saw this in many cases, even now. • Penalties are negotiated down. • Too few large plants sued by Tx AG.

First, Do No Harm: Air Pollution