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

2. 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.

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

4. 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

5. 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.

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

7. 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.

8. 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

9. 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

10. Health Effects of Air Pollution Benzene

11. Health Effects of Air Pollution

12. 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.

13. 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.

14. 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.

15. 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.

16. First, Do No Harm: Air Pollution