Houston, We Have a Problem A Roadmap for Reducing Petrochemical Industry Toxic Emissions in the Lone Star State

Galveston-Houston Association for Smog Prevention Industry Professionals for Clean Air Environmental Defense Fund Environmental Integrity Project

May 2008

Houston, We Have a Problem

A Roadmap for Reducing Petrochemical Industry Toxic Emissions in the Lone Star State

Galveston-Houston Association for Smog Prevention Industry Professionals for Clean Air Environmental Defense Fund Environmental Integrity Project

may 2008 Galveston-Houston Association for Smog Prevention (GHASP) GHASP’s mission is to persuade government and corporate officials to prevent smog. GHASP seeks to accomplish its mission by being the most credible advocate for clean air in the Houston region; by supporting efforts to educate the public and intensify the political climate; and by directly engaging government officials, community lead- ers, the media and industry on regional air pollution issues. For more information, visit www.ghasp.org.

Industry Professionals for Clean Air (IPCA) IPCA is a group of petroleum and petrochemical industry professionals who are concerned about the slow progress toward clean air in the Houston region. We are enlisting like-minded individuals who can offer their expertise in plant operations, economics, design and environmental controls. For more information, visit www.ipcahouston.org.

Environmental Defense Fund (EDF) A leading national nonprofit organization, Environmental Defense Fund repre- sents more than 500,000 members. Since 1967, Environmental Defense Fund has linked science, economics, law and innovative private-sector partnerships to cre- ate breakthrough solutions to the most serious environmental problems. For more ­information, visit www.edf.org.

Environmental Integrity Project (EIP) The Environmental Integrity Project is a nonpartisan, nonprofit organization ­dedicated to more effective enforcement of anti-pollution laws. EIP’s research and reports shed light on how environmental laws affect public health. EIP works closely with communities seeking to enforce these laws. For more information, visit www.environmentalintegrity.org.

Acknowledgements This report was made possible through the support of the Brown Foundation and the Houston Endowment. author: Kelly Haragan Photos courtesy of Galveston-Houston Association for Smog Prevention Contents

1 Summary

3 The Federal Toxics Program Does Not Address Hotspots 4 An Overview of Federal Regulation 4 Why Federal Regulation Fails to Protect Public Health in Toxic Hotspots 4 Toxic Emissions Are Not Monitored and are Under-Reported 5 EPA Fails to Consider Aggregate or Cumulative Health Risks 6 Current Federal Laws Fail to Address Environmental Justice Impacts 7 EPA Lacks an Updated List of Air Toxics and Adequate Health Data

9 State and Local Governments Must Protect Public Health 9 Some State and Local Governments Have Taken Action 11 Texas Lacks an Enforceable Hotspots Program 13 The Houston Example 14 The Source of Houston’s Problems 16 The City of Houston Steps Up

17 Texas Refineries and Chemical Plants Can Do More to Reduce Toxic Pollution 18 Make Pollution Reduction a Corporate Priority Second Only to Safety 19 Increase Monitoring and Verify the Accuracy of Emission Estimates 19 Use Current Best Controls and Management Practices 28 Support Reasonable Regulation to Eliminate Toxic Hotspots

29 Conclusion: A Roadmap for Reducing Industrial Toxic Emissions List of Tables 10 Table 1. Sample State/Local Air Toxics Programs 11 Table 2. TCEQ’s Air Pollutant Watch List 13 Table 3. Houston’s Definite Risk Pollutants 15 Table 4. Industrial Benzene and Butadiene Emissions in Harris County 15 Table 5. Largest Benzene Emitters in the Houston Area 20 Table 6. Harris County Industrial Emissions by Unit 21 Table 7. Leak Definitions 21 Table 8. Repair Timelines 26 Table 9. Tanks Required to Route to Controls

Appendix: Texas Gulf Coast Toxic Hotspots  Houston, We Have a Problem - - - - - s a result, Texas State and federal government officials timeis it importantly, most Perhaps nd, most of all,petrochemical industry of most nd, t a minimum, a adopt industry t should managers and engineers to come up with up come to managersengineers and their reduce to technical the solutions health. public protect emissionsand toxic A similarpractices and controls those to discussedthatthisin others report,or reductions. emission equivalent achieve for limiting toxic emissions, and cities like Houston have struggled to protect their residents’ health. can by improving help toxic monitoring and taking into account real-world (cu mulative) impacts in heavily industrial ized neighborhoods. Texas politicians can also by adopting help legislation to require emission reductions in areas toxicwhere pollution exceeds safe levels, and encouraging, rather than thwarting, local programs designed to protect pub lic health in toxic hotspots. take industryresponsibilto for leaders emissions. toxic their up clean ityto should industry Petrochemical executives prior a reduction pollution toxic make should They safety. to only itysecond regulatory reasonable measures. support A plant theirturn loose should leaders politicians, have been unable however, or unwilling to place adequate limits on industrial toxic air emissions to protect the health Texans. of A industry has not been required to utilize the best available controls and practices ------rthur, Port Neches, and gency’s industrial toxics

ilby Park and Galena Park s the petrochemical capital of the United States, the Houston area is at the center a toxics of

To addressTo thesenum deficiencies, a Unfortunately, Texans cannot count UsingHouston as casea this study, re Summary nd, even morend, alarmingly, even the federal ing the M ber states of and local governments have adopted their own, more stringent air toxics programs. Texas regulators and program is woefully behind schedule in meeting congressional deadlines. A program does not deal with real-world impactstoxic of pollution, particularly in local toxic hotspots. refineries and chemicalplants through theout state Texas of and beyond. on federal or state laws to protect their health. Environmental U.S. The Protection A Texas City. port details many the of shortcomings of federal and state toxics regulation, and provides a roadmap for reducing emis sions these of harmful pollutants from face similar toxic threats. Refineries and chemical plants along the Texas Gulf Coast are major contributors to toxic hotspots in Beaumont, Corpus Christi, Freeport, Port A storm. Numerous studies have docu mented dangerous toxic of levels air pollution in the Houston area, includ neighborhoods. Communities in other industrialized areas throughout Texas A Houston, We Have a Problem   Houston, We Have a Problem for

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Tank landings. roof and cokers; Delayed systems; wastewater and sewers Process systems; exchanger in heat Leaks sulfur and units reforming catalytic units, cracking catalytic with associated vents Refinery units; recovery to toxic air emissions, EP emissions, air toxic to is to provide two-tier protection: protection: two-tier provide to is communi fenceline industrial protect to notintended are regulations toxics EP communities. these for standard weaker, health a separate, communities.” color people-of- and low-income specifically, and, areas urban across pollution ics tox of air impacts disproportionate the of EP One Impacts Justice Environmental Fail Address to Laws Federal Current the rest of the country. EP country. of the rest the EP level that same the to ties than 1 in 1million 1in than of risk cancer lifetime individual an to possible of persons number greatest the (1) To expose A ’s national goals is to “address “address to is goals ’s national 22 Y , and , and A et, when it comes when comes it et, ’s industrial ’s industrial no higher higher no actually sets sets A actually A ’s stated goal goal ’s stated only protects A protects sources pollution emissions toxic those certain from - - these neighborhoods are less transient transient less are neighborhoods these county. of the rest the than of children number a greater have and larger are Channel Ship Houston county. the in highest the among is insurance health of without people percentage the and median city below the percent 30 than more is income family median area, this in neighborhoods nine the In Channel. Ship Houston the near Houston, East in clustered are County Harris in sources toxics. of air levels high to exposure from recover and with cope to resources the not have do thus low-income and often are ties Communities near industrial facili industrial near Communities plant. industrial an near living persons to risk cancer excess mated 1million] [10010,000 in to To limit, (2) 24 For example, industrial industrial For example, 25 Households near the the near Households no higher than 1 in 1in than higher no 26 In addition, addition, In , the esti , the

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37 Because EP 33 36 gency for Research on ccountability Office and cademies have found ct’s goal protecting of public develops a processA develops for ’s regulated’s air toxics list, A ir A pproximately one-fifthof the tox Until EP Further, for those chemicals that A A often lacks adequate health data. the National A Government A duced chemicals in the and U.S. is EP International A are on EP EP primaryThe database for EP screening chemicals new before they en ter the marketplace, determining their potential health effects, and regulating those that present a health hazard, the Clean A health with an ample margin safety of will not be met. IRIS. IRIS includes information on over 500 the of most widely used and pro preferred source for the toxicity values used in human health risk assessments. are missinghowever, from IRIS. for those toxics that are included, the information, such as chemical toxicity values, is years on average 12 old. that IRIS lacks current, basic scientific information necessary for regulating many air toxics. healthno effects for pollutants for which it has little health or no data, the lack updatedof information in IRIS can lead to underestimation real of health world impacts and the failure to regulate dan gerous chemicals. one toone the list regulated of air toxics. 2004 study published in the Management and Waste Air Association screened chemicals 1,086 for potential addition to the toxics list and found that 44 merited consideration for addition. California lists 700 chemicals over as known to cause cancer, birth defects, or otherreproductive harm. Cancer has evaluated more than 900 agentsand identifiedapproximately 400 as carcinogenic or potentially carcino genic to humans. cal health impacts information is the Integrated Risk Information System, or ics regulated under the Clean A ------A - 28 - A has to yet add A has process no P exposures P [toxic] expo A A A to periodically A noted: The true The risks to such 27 Despite the fact that ap s EP 29 ct requires EP other children to lack sufficientnu trition and access to health care. If the federal government is to fulfill systems. In addition, the poverty factor 20% (over the of urban popula tionconsists children of in poverty (U.S. Department Commerce, of 1997)) increases their vulnerability because they are more likely than children, for example, are likely to have additional susceptibility and vulnerability to H because their of daily activities, their immature or developing metabolic systems, or their developing organ emitting sources, decreased health and nutrition status, and lifestyles are considered because it is known that these factors may lead to in creased sensitivity and susceptibility to the effects H of sures. Within the general population, The issueThe becomes complex when other population factors such as age, socio-economicstatus, proximity to A currently lists regulated 187 hazard ir A for doing so. proximately 300 chemicals new enter commerce each EP year, LacksEPA Updated an List of Air Toxics and Adequate Health Data EP toxic)ous (or air pollutants. Clean The A must adopt standards to ensure that fenceline communities, and other sensi tive populations, are protected to at least the same safe risk as levels the rest of the country. update this list, EP but its goal addressing of disproportionate impacts toxic of pollution, then EP sensitive populations are difficult to determine. A than the rest Houston.of Thirteen per centhouseholds of in the neighborhoods around the ship channel have been living in their current residence since or earlier. 1969 Houston, We Have a Problem  in 11 over phased be years. June 1, 2007, will effective became which regulation, The bioaccumulativechemicals. and persistent for alternatives of safer substitution the for mechanism It also into has a Europe. import or produce they that chemicals volume large for data safety companies to provide requires REACH regulation. (REACH) Substances of Chemical Restriction and Evaluation, Authorization Registration, the Union adopted European the 2006 In December The European Union is Ahead on Toxics ing in urban and industrial areas. EP areas. industrial and urban in ing cal governments clean up toxic hotspots. hotspots. up toxic clean governments cal help lo and identify to legislation adopt should Congress market. the enter they before of chemicals impacts health the analyze and determinations, regulatory in emissions of toxic impacts cumulative and aggregate consider factors, emission of accuracy the improve toxics, air for monitoring improved require should liv those for particularly health, public protect notadequately does simply The federal toxics regulatory system system regulatory toxics The federal A - -  Houston, We Have a Problem - -

41 ’s regulatory’s s shown in A A 40 , A various state and local pro , Sample State/Local Toxics Air , A ting priorities, considering cumulative impacts, identifying and prioritizing new chemicals, and requiring standardized, certified, toxic emission reporting. regulating more industrial sources than EP setting more stringent standards than EP using risk-based approaches for set • • • grams improve upon EP Some State and Local Governments Governments Local and State Some Action Taken Have In response to ambient monitoring showing air of elevated levels toxics, a number states of and local air pollution control districts have adopted innovative programs to reduce local public health risks from air toxics. 1, Table Programs system by: • • • - - - : A dditionally, ccording to EP A 38

39

A itself has stated that, in many

n light the of federal government’s failure to adequately regulate air toxics, state and local governments Public Health Public State and Local Local and State Protect Must Governments State and local authorities may complement the federal program by addressing local risk issues that may not be effectively addressed nationally. A successful comprehensive air toxics programwill be that one integrates the residual risk and other federal programs with State and lo cal programs and strengthens those existing programs… A

tecting public health from toxic air emis cases, the residual risks from air toxics may bemost appropriately addressed at the local level. I have an important to role play in pro sions. EP 10 Houston, We Have a Problem New Jersey Resources Board California Air Louisville, KY Oregon Louisiana State T able 1.Sampletate /Local AirToxicsPrograms 47 44 46 45 43 such assmallerbusinessesandcars. exceedances. from sourcesthatcontributetobenchmark Some sourcecategoryruleslimitemissions and pollutantmixtures. exceedances andtheriskfrommultiplepollutants including numberandextentofbenchmark Hotspots aredesignatedbasedoncriteria meet theambientbenchmarkswithin10years. Geographic hotspotsmustdevelopplansto cause exceedancesofambientbenchmarks. “Safety Net”programtargetsfacilitiesthatalone require morestringentcontrols. by-case reviewisconductedandthestatemay emissions. Ifbenchmarksareexceededacase- Facilities mustestimatetheriskposedbytheir technologies. air toxicemission“state-of-the-art”control Requires facilitiesseekingpermitstoapply specific Finally, theprogramrequiresastudyofwhether must beachievedby2011. emissions ofTACs. Reductions in18priorityTACs sources mustsubmitplansforreducing based thresholds.Ifthresholdsareexceeded, and determineiftoxicemissionsexceedhealth- medium industrialsourcestoreportemissions In addition,theprogramrequireslargeand plants. to thehealthandwelfareofhumans,animalsor a TAC inanamountorduration thatisharmful The programincludesageneraldutytonotemit exceeded 1-in-1millioncancergoal. of 17Toxic AirContaminants (TACs) inthearea Louisville’s programwasinstitutedbecauselevels inventory. standards. Alsorequiresstatetoxicemission Rates (MERs)and(2)meetambienttoxicair the sourceexceedestablishedMinimumEmission Control Technology forreducingtoxicemissionsif Requires sourcesto:(1)useMaximumAchievable health-based standardswithin5years. actions toreduceemissionsasnecessarymeet emissions, notifyneighbors,andtakeallpossible toxics, estimatethepublichealthimpactoftheir stationary sourcestoreportemissionsofair Hotspot programrequirescertainlargeandsmall must adoptcontrolstrategies. public health.IfnecessarytoreduceriskCARB contaminants andexposurelevelstoprotect AB1807 requiresidentificationoftoxicair Program Description reductions are needed from other sources, must meetthe1-in-1-millionforsingle (2) newandmodifiedequipment Individual piecesof:(1)existingand P and newmodifiedequipment. in-1-million fromallcollectiveexisting and modifiedequipment,(2)7.5- 3.8-in-1-million fromallcollectivenew applicable TACs mustnotexceed: (1) The cumulativeemissionsofall TACs. 1-in-1-million level. Ambient benchmarksaresetatthe million level. Benchmarks aresetatthe1-in-1- 10 thousandrisklevel. Ambient airstandardsaresetat1-in- a-million risklevel. MERs wereinitiallysetbasedon1-in- use 100-in-1-million. million; SanDiegoandtheBayArea 10-in-1-million; LosAngeles25-in-1- by localairdistrict.Sacramentouses Facility riskreductionlevelsareset public ifriskexceeds10-in-1-million. Notice isrequiredtotheaffected the 1-in-1-millionrisklevel. Threshold forprogramapplicabilityis ollution Thresholds 42

11 Houston, We Have a Problem 2002 2003 2004 2001 1996 1998 Listed Since 2007 1999 2005 2004 2004 2001 2003 2004 2002 2000 1999 2003 - - in- - pres still Benzene Benzene 1,3-butadiene Benzene Pollutant Arsenic Cobalt Nickel Vanadium Nickel Acrolein Butyraldehyde propionaldehyde Valeraldehyde Benzene Styrene Benzene 1,3-butadiene sulfur dioxide hydrogen sulfide hydrogen sulfide hydrogen sulfide hydrogen sulfide hydrogen sulfide hydrogen sulfide benzene reas that do not exceed ct as necessary the level Galena Park Port Arthur Port Neches El Paso Beaumont City Bastrop Cass Freeport Dallas Houston Evadale Christi Corpus City Texas Ferry Lynchburg ir A List Watch able 2. TCEQ’s Air Pollutant El Paso Jefferson Nueces County Bastrop Bowie Brazoria Dallas Galveston Harris Jasper T the air is safe. A these ambient toxic goals may healthent threats. This is because these arelevels based an much of on how individual pollutant can be present in the air without causing more than a 10- in-1million increase in cancer risk. But, health experts prefer the more stringent million1-in-1 standard, cited in the fed toprotect public health with an “ample margin and used safety,” of by number a otherof states. less protective The 10 1 million standard should not be used as a default, and should certainly not be considered acceptable unless all best controls and practices for minimizing emissions have been implemented. This is particularly true because TCEQ’s eral Clean A ------

- - 50 TCEQ does not, 49 s a result, some areas, such areas,such some result, a s ir Pollutant List. Watch A TCEQ’s Air Pollutant Watch Pollutant TCEQ’s Watch Air

51 The state The environmental regula 48 identifies 14 identifiesareasof the statewhere Furthermore, TCEQ’s ambient toxic While there are some examples of Unfortunately, there is no formal no is there Unfortunately, Table 2, Table in Texas. goals, or ESLs, should not be used as the benchmark for determining whether exceeded the state’s health-based toxic health-basedtoxic state’s the exceeded more. or decade a goalsfor TCEQ and local governments obtaining voluntary pollution reductions, these ef forts generally have a poor track record than the state’s ambient toxic goals, or or goals, toxic ambient thanstate’s the try targetdoes to industries ESLs).TCEQ the list, but watch state’s the areasin on toxics voluntary on relies largely agency reductions. CorpusChristi, and have Neches Port as health effects, and have been placed on the state’s A pollu ensuring mechanismtoxic for that healthier to areasreduced is these in tion arelower that levels toxic (i.e., levels List, air monitoring shows ambient toxic lev elsabovethe health based goals, orESLs. These areas have been identified as areas concern of for short term or long however, treat thesehowever, health-based ambi toxicent goals as enforceable limits, and the agency routinely issues permits for sources whose emissions cause exceed ances the of ESLs. Screening Levels, or ESLs. These ambi toxicent goals aredesigned to ensure greatera no than 1 in increase 100,000 in the risk cancer of from individual air toxics, and are used as guidelines during the permitting process. have its own enforceable toxics stan dards. tory the Texas agency, Commission on Environmental Quality (TCEQ), sets target health-based ambient tox whichics levels, it refers to as Effects Texas Lacks an Enforceable Enforceable an Lacks Texas Program Hotspots Unlike some states, Texasimplements the federal toxics program, does but not

42 ollution Thresholds Benchmarks are set at the 1-in-1- million level. Ambient benchmarks are set at the 1-in-1-million level. is Threshold for program applicability the 1-in-1-million risk level. affected Notice is required to the public if risk exceeds 10-in-1-million. risk reduction levels are set Facility uses by local air district. Sacramento 25-in-1- 10-in-1-million; Los Angeles million; San Diego and the Bay Area use 100-in-1-million. MERs were initially set based on 1-in- a-million risk level. Ambient air standards are set at 1-in- 10 thousand risk level. TACs. The cumulative emissions of all must not exceed: (1) applicable TACs 3.8-in-1-million from all collective new and modified equipment, and (2) 7.5- in-1-million from all collective existing and new and modified equipment. P Individual pieces of: (1) existing and (2) new and modified equipment must meet the 1-in-1-million for single sources, other from needed are reductions exceedances. Louisville’s program was instituted because levels in the area (TACs) Air Contaminants of 17 Toxic exceeded 1-in-1 million cancer goal. The program includes a general duty to not emit amount or duration that is harmful in an a TAC to the health and welfare of humans, animals or plants. In addition, the program requires large and medium industrial sources to report emissions and determine if toxic emissions exceed health- based thresholds. If thresholds are exceeded, sources must submit plans for reducing Reductions in 18 priority TACs emissions of TACs. must be achieved by 2011. the program requires a study of whether Finally, specific Requires facilities seeking permits to apply air toxic emission “state-of-the-art” control technologies. must estimate the risk posed by their Facilities emissions. If benchmarks are exceeded a case- by-case review is conducted and the state may require more stringent controls. “Safety Net” program targets facilities that alone cause exceedances of ambient benchmarks. Geographic hotspots must develop plans to meet the ambient benchmarks within 10 years. Hotspots are designated based on criteria including number and extent of benchmark exceedances and the risk from multiple pollutants and pollutant mixtures. Some source category rules limit emissions from sources that contribute to benchmark Program Description of toxic air AB1807 requires identification levels to protect contaminants and exposure to reduce risk CARB public health. If necessary must adopt control strategies. certain large and small Hotspot program requires emissions of air stationary sources to report health impact of their toxics, estimate the public and take all possible emissions, notify neighbors, as necessary to meet actions to reduce emissions 5 years. health-based standards within Requires sources to: (1) use Maximum Achievable for reducing toxic emissions if Technology Control the source exceed established Minimum Emission Rates (MERs) and (2) meet ambient toxic air standards. Also requires state toxic emission inventory. such as smaller businesses and cars. 43 45 46 44 47 rograms Air Toxics P /Local ample State able 1. S T Oregon State Louisiana Louisville, KY Air California Resources Board New Jersey 12 Houston, We Have a Problem Insurance. Health and Children’s Life Unicare and Hospital, Trendmaker Walter TXU, P. Homes, Inc., Sunoco, Texas Moore, PU XCEL and Energy, Energy. TXU Energy, Reliant NRG, Oncor, Luminant, PNM Resources, Generation, Texas, Exelon Company, Entergy El Paso Electric Energy, Direct Energy, CenterPoint Company (SWEPCO), power Electric Company, Southwestern AECT, include: whose members current include: whose members current AeA, TA Co. Oil Co., Marathon and &Production Exploration ChevronTexaco, Inc., PhillipsAmerica, Conoco Co., Valero, Shell include: TxOGA, whose members current Goodyear Texas, Corporation, Co., Formosa Plastics Chemical ExxonMobil LP, Co., Chemicals Equistar Chemical Company, Eastman DuPont, Chemical Corp.,Dow Petroleum Co., Citgo Phillips Chemical Chevron Texas include: Chemical Council, whose members current measure: the groups opposed lobbying following The hotspots. of toxic notice Texas public simply have (2007) would Bill required 1924 Senate WHO OPPOSED TO Corp. Vignette and Valerent, Healthcare, United Inc., Co., Sun Staubach Microsystems, The Texas Instruments, Corp.,SEMATECH, LP,Instruments Samsung Semiconductor Austin LP, National Motorola, Fulbright Inc., &Jaworsky Corp.,INX, Intel &Young, Ernst Inc., Inc., Semiconductor, Dell, Freescale Wakefield, Cushman Inc., & Logic, Cirrus Inc., Computer, Bridge360, Apple Inc. TOTAL and USA, Texas Petrochemicals, Petrochemicals Chemicals, Sunoco LP, Inc., Chemical Chemicals, Solvay Inc., Solutia Haas Rohm and Texas, Shell Inc., Co.,OxyChem, LLC, Petroleum B , whose current members include: include: , whose members current B LIC NOTICE? Chemical, Huntsman, X the risk from exposure to a to exposure from risk the level is risk 10-in-1 million ­acceptable regulations to control toxics. Y toxics. control to regulations of innovative forefront atthe be should Texas of industry, concentration its and one chemical. any from risk the than higher certainly almost but is understood, poorly is of chemicals suite this from The risk chemicals. toxic ious of var acocktail breathe residents areas, industrial of Texas’ many in while cal, IC HOTSPOT Given elevated ambient toxic levels toxic Given ambient elevated LLC, Lyondell

Walmart, Chevron, ExxonMobil, Technologies, Inc., Agilent Power Electric American Corp.,BP ExxonMobil Chemical

Co., BP, single Marathon et despite despite et chemi - - A A M Texas the including Groups ics. A A of Business, toxic hotspots. toxic up clean to pushed have others many and Court, Commissioner’s County Harris the Coalition, Life Christian M of Houston City the of Bishops, Conference Catholic Texas Services, Environmental and Health tox of air regulation Texas’ strengthen to efforts numerous There been have TexasLegislature The State health. of public tion protec ensure to program atoxics adopt to failed has Texas aproblem, is there show clearly that data monitoring air tion. pollu air toxic from health residents’ their protect to own ontheir action any taking from governments local Texas prohibited have would that legislation adopted almost it program, toxics the improve to legislation adopt to fail ture legislation. toxics est mod opposed that groups lobbying these Notice, box, of Texas. Companies Electric Council, Chemical the Texas associations: industry five from came opposition only the hearing, apublic given were bills two where Senate, Texas the In Coast. Gulf the along area, Houston the near lies district whose Bonnen, Dennis Representative chair, committee environmental of House Representatives Texas the by ahearing even were given bills of these law. none into fact, In none passed were But toxics. air to relating introduced were 15 bills than no less example, for Fails Public the Gas A Gas ssociation, Harris County Public Public County Harris ssociation, Teacher Parent Texas ssociation, ssociation, Not only did the 2007 Texas legisla Texas 2007 the did Not only session, legislative Texas 2007 the In 57 Who Opposed Toxic Hotspot Public Public Hotspot Toxic Opposed Who ssociation, The anti-local government bill bill government The anti-local lists some of the members of members of the some lists 55

and the A the and merican Electronics Electronics merican 52 54 Texas A Texas 53 Texas Oil and and Oil Texas ayor’s Office, Office, ayor’s ssociation of ssociation ssociation ssociation

56 The text The text edical edical - - - - - 13 Houston, We Have a Problem - - 60 - - - s Houston A 62 approach a level level a approach M for its ability to at ccording to a recent th In addition, Houston 61 Immune Cardiovascular, Respiratory, reproductive Female Male reproductive Respiratory Eyes Respiratory, Respiratory Respiratory Respiratory Other Health Risks Respiratory/Cardiovascular Respiratory Respiratory Immune been identified as particularly perni as identified been requiringpriority pollutants cious toxicological the on Based regulation. concentrations the and information the for area Houston the in seen clear is it airpollutants, four selected have city the of portions large that posing airconcentrations ambient can excess thanone riskhigher a people. 100,000 every in death cer 1,3-buta of concentrations Observed ex thanone riskgreater indicating people. 10,000 per death cancer cess Houston-area residents pay a price for diene and diesel P diesel and diene has gained a negative reputation for its air pollution, which makes it harder to attract companies new and the workers Houston needs. A study by CEOs for Citizens, the of out 50 fastest growing metropolitan areas, Houston ranks 49 tract college-educated 25-to-34 year olds. reportThe shows that a major factor in recent college graduates’ choice cities of is a green environment. this toxic pollution. Individuals pay with their health, to due exposure to toxics and general to The ozone. public pays for increased health costs and lowered productivity. No Yes Yes Yes Yes Yes Yes Yes Yes No No Causes Cancer? Causes ) have have ) Recent See 3, Table M 58 59 edicine, Texas Southern ounting evidence demonstrates that demonstrates evidence ounting In Southeast Texas, benzene, 1,3- benzene, Texas, Southeast In diesel and formaldehyde, ­butadiene, P (diesel particulate matter M is Texas Southeast of population the levels disproportionate to exposed to considered airpollutants toxic of thispopulation. riskto health a be A study by Rice University, Baylor edical Branch at Galveston in looked s the petrochemical capital the of able 3. Houston’s Definite Risk Pollutants Acrolein Chlorine 1,3-Butadiene Benzene Acrylonitrile Formaldehyde Pollutant Ozone Fine Particulate Matter (PM2.5) Chromium VI Hexamethylene Diisocyanate Diesel Particulate Matter Ethylene Dibromide T College M of University, University Houston of Law Center and the University Texas of M detail at four pollutants and found: documented dangerous toxic of levels air pollution in parts City the of The city. of Houston recently identified12 chemicals that are present in the air that at levels pose a definitehealth risk. Houston’s DefiniteRisk Pollutants. A United States, theHouston area is at the center a toxics of storm. studies by the City Houston, of local universities, and medical schools have was largely aimed preventing at the City Houstonof from taking action. Example Houston The 14 Houston, We Have a Problem of the City address: address: City of the M • For example: hotspots. Houston’s toxic for responsible is notcars, industry, very likely be will flooding. entirelyfalls on one neighborhood, there problem, but if that same volume of water overrainfall the entire county poses no A the total amount emitted countywide. any toxic) exposure that matters, and not it is the of health risk for an exposed population, publicanalyzing health impacts. In terms it has little relevance when it comes to Even statistic assuming this is accurate, while sources industrial emit 14 percent. cent of County Harris benzene emissions, mobile sources are responsible for 55 per levels, citing the statistic that on-road source of the Houston area’s high benzene mobile sources, like cars, as the true Channel. Ship Houston the along as such together, clustered ten of are contrast, by facilities, industrial Large hotspots. toxic cause not generally do they area, awide across dispersed are emissions source mobile because But, trucks). and of cars tailpipes the from (i.e., sources mobile as well as industry, by emitted is example, for Benzene, industry. including sources, many from comes pollution air Houston’s toxic Problems Houston’s of Source The simple oneanalogy is rainfall: inch of ayor Bill White noted in his 2005 State State 2005 his in noted White ayor Bill The areas on the state’s A state’s onthe The areas areas, or are directly downwind of downwind directly are or areas, industrial primarily are (ESLs), goals health-based state’s the exceed toxics of concentrations where Watch List, that evidence mounting There is Industry representatives often blame home. their Houston make to who we want people of younger health respiratory the protect and homes, of our value the preserve new jobs, attract to ability our to important also is air our Cleaning concentration of the benzene (or ir Pollutant Pollutant ir - 64 63 -

• • Emissions in Harris County. in Harris Emissions Table 4, See industries. terminal and station bulk petroleum and refining, petroleum cal, chemi organic the by emitted are sions, emis of 1,3- butadiene 79 percent and emissions, benzene of industrial percent County, 74 Harris In pollution. of such sources the identify to important is it health, onpublic effect have a significant tissue. lung scar permanently and function, lung reduce asthma, and emphysema, bronchitis, worsen also can It irritation. lung and throat and ing, cough pain, chest cause can ozone High of Houston. all for threat ahealth ate city. the across spread then and Channel Ship Houston the near originate that ozone of high plumes in resulting (NOx), oxides trogen of ni emissions industrial with combine VOCs, other and of toxics emissions M zene levels rise in proportion to ambi to proportion in levelszene rise ben ambient complexes, industrial nothave do that locations In benzene. as well as monoxide carbon emit are cars that levels, showing monoxide carbon high with notassociated are Channel Ship levels Houston over the benzene High Channel; Ship Houston over the substantially levels rise benzene but that Dallas, in those to similar are Houston downtown levels in benzene that found has industry); petrochemical the by impacted areas the showing maps TCEQ’s contains areas. industrial Because toxic industrial emissions emissions industrial toxic Because hotspots, toxic creating to addition In notcars. is Channel Ship the along benzene of the source main the that suggesting monoxide, carbon in rises associated without levels rise benzene channel, ship Houston the ent carbon monoxide levels. A monoxide ent carbon onitoring during airplane flyovers airplane during onitoring Industrial Benzene and Butadiene Butadiene and Benzene Industrial 68 not High ozone levels ozone cre High the problem. Cars Cars problem. the 65 ( A ppendix A ppendix 66 and and 67

69

long ------15 Houston, We Have a Problem -

41% 14% 19%

71 71 - 1 5 3 7 2 8 6 9 11 15 13 17 14 10 Risk Level Percent of County Percent of County Benzene Emissions

51.55 15.61 26.11 41.77 17.88 34.25 31.80 49.53 21.07 28.95 18.69 16.80 86.68 29.04 (tpy) 77.63 223.44 106.39 Benzene (tons/yr) , includes the results Benzene Emissions Largest Benzene Emitters in 11% 18% 50% Table 5, 5, Table Harris Harris Galveston Galveston Galveston County Galveston Harris Harris Harris Harris Harris Brazoria Brazoria Harris Emissions dustrialfacilities that emit the largest quantities benzene of and pose the great est human health risk from benzene air pollution exposure in the ten-county Houston area. posed. then generates It a facility score that can be compared to other facility scores to assess the relative health risk posed by different facilities. Houstonthe Area theof city’s identifying study, the in 1,3- Butadiene Percent of County Percent of County - - - - odel. 70.11 44.52 200.19 1,3- Butadiene Emissions (tpy) 70 Houston Regional Benzene Pollution Air Reduction: A Voluntary Plan for Major ’s Risk-Screening’s A odel considers the amount of , p. 9, Tables 3, and 9, , p. 1, 4. (Feb. 2007). City of Houston, : s noted above, however, it is not s noted however, above, Sources A in the Houston Area able 5. Largest Benzene Emitters Emissions Butadiene zene and ndustrial Ben able 4. I Industrial Organic Chemicals Standard Industrial Code (2869) Petroleum Refineries (2911) Petroleum Bulk Stations & (5171) Terminals Company City BP Products North America, Texas Equistar Chemicals Chocolate Bayou Complex Deer Park Plant Rohm & Haas Texas, Goodyear Tire and Rubber City Refinery LLC, Texas Marathon Petroleum Co LP Houston Refining Lyondell Exxon Mobil Baytown Facility Plant B Dow Chemical Co., Chemical Channelview Lyondell Georgia Gulf Chemicals & Vinyls City Plant Sterling Chemicals Inc., Texas Equistar Chemicals LP, Channelview Complex Exxon Mobil Chemical, Baytown Chemical Plant Shell Oil Deer Park County in Harris source T fate and transport through the environ ment, the route and extenthuman of exposure, and the number people ex of sions in the ten-county Houston region according to EP a chemical released, the location the of release, the toxicity the of chemical, the solely thesolely quantity a chemical of emit ted that determines thepotential health impacts. City The Houston of evaluated health impacts to due benzene emis Environmental Indicators (RSEI) M The RSEIThe M T 16 Houston, We Have a Problem “ — breathe. must others and own don’t they to air which alterations chemical to make risky right have should the one no issue, because air ethical and isClean amoral Mayor BillHouston White, 2005) 24, (Jan. Address City of the State Up Steps Houston of City The on tanks and wastewater systems; and and systems; wastewater and on tanks controls recovery; gas flare and mization mini flare as: such recommendations, included and industry, with agreements voluntary for point astarting as serve to was proposal The city’s facilities. those for plans reduction benzene draft included and residents, Houston-area to threat health greatest the presented emissions benzene whose facilities plan. tion reduc benzene developed avoluntary and reductions, pollution voluntary aged action. take to decided leaders city residents, of Houston tion protec the ensure to programs state and of federal failure the and neighborhoods, certain levels in toxic high of the light In Initially, the City of Houston encour of Houston City the Initially, 72 This plan identified seven identified plan This

” - - - - lution problem. In November 2007, In problem. lution the pol air Houston’s toxic address to a plan A an in groups, environmental and health public and leaders business with participate, to and ­officials was neveradopted. and state opposition industry from But, facedthe strong proposed ordinance companies responsible for the nuisance. abate toxic the nuisances, and penalize wouldordinance have allowed the to city the levels of toxic pollution in the air. The for whichsance ordinance, set standards emissions. toxic reduce to plan alternative an up with come or plans reduction city’s the adopt either to failed industry Unfortunately, programs. pair re and detection leak to improvements air toxics. toxics. air M until months, six industries Houston gave mayor the foot-dragging, industry’s by Frustrated results. real see to wanted but efforts, voluntary industry’s comed studies. more and outreach public efforts, industry untary vol for called report the Instead tions. reduc emission toxic industrial for steps concrete outline to but failed report, much-anticipated its released force task ay 1, 2008, to reduce ambient levels of ambient reduce 1,ay to 2008, Houston M Houston Instead, the City of Houston agreed agreed of Houston City the Instead, In early 2007, the proposed city a nui ir Quality Task Force, to develop Force, to Task Quality ir ayor Bill White said he wel said White ayor Bill ------ Houston, We Have a Problem It isIt clear that considerable health Furthermore, according to the City analysis Houston’s of benzene of monitor data, more than half the of Harris County monitoring sites exam- including two theof most— con- ined taminated sites, Lynchburg Ferry and that Houston area industries still need more time. risks remain for many Houstonians exposed to unhealthy ambient concen- trations benzene of and other air toxics. While science has only begun to quan- tify cumulative risks, like those from the variety toxic of chemicals present in air, do know Houston’s we that public exposure to individual chemicals such as benzene remains too high in parts of the Some Houston city. air monitors still benzene of levels show above the state’s ambient toxic goals, or Effects Screening Levels. as explained these above, levels, they when areeven met, do not ensure adequate protection public of health.

73 ith the Houston mayor’s deadline for voluntary toxic reduction approaching, what

More to Reduce Toxic Toxic Reduce to More Pollution Texas Refi neries and and neries Refi Texas Do Can Plants Chemical In march 2008, of air Houston’s One positive step is that at least two report or indicated much pollution how they will reduce. task The force claims the actions that individual companies have taken to reduce emissions, and allow companies to report on their leak detection are and repair, storage tank, fl minimization, and other programs. But, company no actually produced a ment withment Texas Petrochemicals for 1,3-butadiene cant reductions.signifi Quality Task a public Force held educa- tion forum on clean air. according to the task force, would highlight the event companiesenteredhave into agreements with the state environmental agency TCEQ)(the and the City Houston, of to reduce toxic emissions. example, For the city and TCEQ entered into an agree- W has industry done? 18 Houston, We Have a Problem • significant improving trend in benzene benzene in trend improving significant Channelview m • should: company Texans. fellow their of health the protect to undertaking be should companies petrochemical and refining that actions out minimum lays roadmap The following emissions. toxic up clean to part their do must leaders industry Texas residents, state’s the all standards. federal ceed ex levels ozone repeatedly and persist ago. adecade than more made reductions emission touting and atcars) (mainly finger the work, pointing to lawyers and lobbyists put their to opted have leaders industry problem, solve to the loose engineers the of turning instead plants, chemical and at Houston’s refineries emissions toxic reducing to comes it air. healthy having along from way is Houston that ozone, suggest for standard quality air federal the meet to inability the and 1,3-butadiene, as such toxics, air other levels of risk acceptable attain to failure region’s the coupled with data, This five years. past the in concentrations • • Y challenges. most meet to rise

Support reasonable regulation to en to regulation reasonable Support public health. public protect and field alevel playing sure and emissions; toxic minimizing for tices prac and controls best current Use emissions; ­calculate to used formulas of any accuracy the verify and monitoring Increase safety; to only second priority petrochemical or refining Every for breathe to safe be to For air the can industry that shown has History M ake pollution reductions a corporate acorporate reductions pollution ake eanwhile, Houston’s toxic hotspots hotspots Houston’s toxic eanwhile, — showed no statistically showed no statistically et, when et, 74 - -

- cost savings may not be made. notbe may savings cost long-term in result that repairs those even then repairs, make to order in tions opera cease temporarily to reluctant are staff production and atodds, are staffs production and staff environmental emissions. preventing of expense atthe production increase to incentive an creating throughput, safety. to only second priority top a are reductions emission that ensure to incentives and practices, of acompany’s analysis adetailed It requires goals. rate corpo “green” generic than more quires re reductions emission toxic Prioritizing to Safety Corporate Priority Second Only Make Pollution Reduction a they make it a priority. The goal should should The goal a priority. it make they if hotspots toxic eliminate and emissions emissions: product off-specification and shutdown startup, reduce to project its describing M Industry leaders can reduce toxic toxic reduce can leaders Industry flaring. reduce to now managed are events upset smallest the Even improvements. further generate to group alarger to doors the opened also mindset This flaring. reduce to effort an in action appropriate more take and situations upset through think to freedom more erations op allowed This rates. production finally and second, minimization priority in third were rates production conditions, these Under emissions. less in result would efforts the if recovery upset of process the slow down to liberty the operations allowing by efforts project the supported (Leadership) M levels. all at accepted be to had philosophy This flare. to practice unacceptable an is it that of aphilosophy adoption the was project of this success overall the to contributors main of the One A s Dow Chemical explained when explained Chemical s Dow any companies base bonuses on bonuses base companies any — safety first, flare flare first, safety 75 If the goals of goals the If anagement anagement 76

77

-

- - - 19 Houston, We Have a Problem - - - - - A

—

L, but A A to resolve L system, A L and to SOF A , lists the largest L and differ SOF from est Controls and and est Controls A Because emission report

79 Harris County Industrial ants, much like the DI In addition, companies located in Table 6, Solar Occultation Flux (SOF) These systems can quantify pollut and are used in Sweden to monitor whole plant emissions. SOF systems are less expensive than DI they are dependent on high sun and steady winds. If monitoring results based on tech any these of technologies have been

benzene and 1,3-butadiene, according to state data. ing is notoriously inaccurate, however, there may be additional sources of toxic emissions that warrant improved controls. areas where ambient toxics of levels ex ceed Texas’ ambient toxic goals, or ESLs, shouldfenceline implement monitoring systems to measure the ambient concen trations at the fenceline, both downwind and upwind the of facility. B Current Use Practices Management Better performing facilities nationwide are implementing technologies and best practices that could be used to minimize toxic emissions in the Houston area. M required for years in other jurisdictions or have beenrequired by EP enforcement actions. Emissions by Unit sources of industrial emissions of emission calculations, companies should withwork regulators to determine why, and should amend past emission reports to reflect accurateemission levels. EP should establish protocols, training and quality control procedures for the use of technologies such as DI ensure that their use results in accurate emission estimates. • nologies like DI ------—

78 L system has A s a result, industry self-report ore than 30 studies refinery of conservative, have proven more ac curate than prior estimates based on emission factors. light aromatics, methane and total hydrocarbons. DI The been validated in European studies for hydrocarbon emissions and its results, while generally found to be Detection and Ranging (DIAL) These systems are used extensively in Europe and are being used in Canada. systems The use ultraviolet and infrared lasers to measure pol lutants, including criteria pollutant, Differential Absorption Light Relying on inaccurate and outdated s explained in this report, most esti using ambient monitoring technolo gies that permit site-specificemission estimates. Several such technologies are available, including: • emissions is unacceptable. Where con tinuous monitoring actual of emissions is possible, industry should use such monitoring. Where it is not, companies should verify the accuracy emission of calculations at least every two years, the past 20 years. best The performing refineryemitted three times its reported emissions. worst The emitted twenty times its reported emissions. emission factors in order to estimate ed emissions do not correspond to the actual quantity pollution of released into the air. M emissions using ambient monitoring technologies have been conducted over Increase Monitoring and Verify the the Verify and Monitoring Increase Estimates Emission of Accuracy A mates industrial of emissions are based on outdated and unreliable “emission factors.” A be to eliminate all emissions that con tribute to unsafe ambient air of levels pollution. 20 Houston, We Have a Problem “ — TCEQ, own sources, pollution of on focusing process In the Eliminating Pays Leaks Often for Itself order. in short itself for pays equipment control pollution the cases, In these product. raw able losing company valu longer no was the resolved, was emissions the once problem investigation, Shoreacres In the equipment. leaky locating by save money ultimately they find often facilities of industrial ers Improving, Quality Air Houston: for Forecast T and practices, like those identified identified those like practices, and controls anti-pollution demand should of Texas) state the and of Houston City the (both officials government priority, a reduction toxic make to decide tives execu company Until toxics. reduce to ways identify to equipped best the are facilities these in working engineers the and managers Plant facilities. chemical Houston’s petro from emissions toxic reduce to ways innovative other likely There are notexclusive. certainly are recommendations these But section. this in explained are practices best and gies technolo of these Some towers. cooling cokers, systems, wastewater flares, fugitives, tanks, from emissions reduce implemented be can that TOTALS Wastewater Flares Fugitives Tanks Units Cooling Towers able 6.HarrisCountyIndustrialEmissionsbyUnit(2004) (SpringNatural 2008). Outlook There are technologies and practices practices and technologies There are 1,3-Butadiene Emissions today (tons/yr) 168.08 135.18 31.82 9.28 3.03 347 that will will that ” 80 and and - - - - - Percent Total Butadiene F reductions. emission ­achieving of records track proven have below that repairing leaks. leaks. repairing for a timeline establish and monitoring, periodic require definition), a leak (called limit aleak set programs These (LD Repair and Detection Leak done through generally is tives cost-savings. in result leaks these reducing for ments A fuel. as site on- used soldor be otherwise could air the into leaking gases the because profit plants. atchemical rates,” particularly elevated leak show “significantly still audits 1999, facility since improvements reported. than greater 10average times on were leaks refinery found Center Investigation Enforcement National 1999, In EP underestimated. likely A emissions. fugitive were emissions, of benzene percent 28 and emissions, of butadiene County, percent 42 Harris for Inventory Emission Source Point 2004 TCEQ’s to A compressors. and pumps, connectors, valves, like equipment from A 42% 87% 34% ugitives lthough there have been some some been have there lthough 8% 2% 1% Federal and state regulation of fugi regulation state and Federal lost mean often emissions Fugitive .

Fugitive emissions are leaks leaks are emissions Fugitive nd, fugitive emissions are are emissions fugitive nd, Emissions s a result, many require many s aresult, (tons/yr) Benzene 209.95 155.74 24.42 45.37 51.18 487 A R) programs. R) programs. ccording ccording Percent Total Benzene 28% 87% 38% A 9% 4% 8% ’s - - 82 81

21 Houston, We Have a Problem 89 92

TCEQ (Non HRVOC) 15 days 5 days - rea 8 85 93 100 ppm 500 ppm 500 ppm All VOCs BAAQMD For equipFor

D. See 8, Table D. 88

M 84 Q A 8 . When repairs are anagement District 500 ppm 500 ppm TCEQ 7 days for leaks greater than 10,000 ppm 15 days for all other leaks. TCEQ (HRVOC) 1 day for leaks greater than 10,000 ppm. 5 days for all other leaks. 10,000 ppm D) andD) are more stringent All Other VOCs Leak Definitions. D and SC M M

Q Q

83 AA ir Quality M AA should be minimized within 24 hours identification.of Repairs should be made within days. seven These timelines are more stringent than currently required by Texas and are consistent with those required by the B Repair Timelines Repairs using best available technologies: made, they should be made using the best available technologies for minimizing leaks, including low leak valve packing. If a component than the required levels in Texas. See 7, Table inment toxics service, any leaks Tighter repair timelines: are currently in place in the Bay A A (B

• • 83 87 91 500 ppm 500 ppm 500 ppm -

TCEQ - - a 24 hours BAAQMD 7 days if discovered 24 hours if discovered by operator by agency

Highly Reactive VOCs Highly Reactive R audits, R 90 A for all equip 86

SCAQMD 1-7 days based on component and size of leak R employees, contrac employees, R Petrochemical com A R programall R covering A writtenLD ment inment toxics service, facilities should use leak lower definitions, ppm for100 valves, connectors and other equipment and 500 ppm for pumps, compressors and pressure relief valves. These leak definitions including annual independent audits. annualincluding independent list delay-of-repair the on Components rates. leak in included be should Lower leak definitions: A well-managedLDARprogram: A a include service unitsshould toxic in withgoal compliance facility-wide leak basis, unit-by-unit a on established trainingLD for tor accountability tor LD and able 8. Repair Timelines (ppm) eak Definitions able 7. L Repair connectors and other equipment Valves, Actions Minimization First Attempt Repair Pressure relief valves Pumps and compressors Equipment

T T • Recommendations: panies should enhanced implement leak detection and repair programs that include the following: • 22 Houston, We Have a Problem • welded connections. with replaced be should connections Flanged pumps. drive magnetic or diaphragm as such pumps seal-less with replaced be should pumps Similarly valves. phragm dia or bellows as such components, leakless with replaced be should nents compo leaking all practice, engineering to traditional LD traditional to five repair actions in any 12-month 12-month any in actions repair five than more requires service toxic in LD of monitored list the to added be should unsafe-to-monitor, or difficult as notqualify does which Imaging, Gas Optical Passive with leaking be A monitoring. LD traditional replace than rather supplement to used be therefore, chemicals. all for or ppm below 500 leaks for notreliable is it components, “unsafe-to-monitor” or “difficult-to-monitor” monitoring for and of leaks sources unknown previously identifying for wonderful is Imaging Gas While emissions. of plumes leaking identify visually can that devices camera-like video portable, are These leaks. detect to quarterly atleast devices Imaging Gas Optical Passive use should Facilities Imaging: Gas Optical Passive good with consistent extent To the requirements. similar SC The period. year five a within period 24-hour any in VOC more or pounds 500 of release second a (2) or period, hour 24- any in VOC pounds 2,000 than more involving release (1)any ing: follow controls or recovery to routed be should devices relief Pressure controls. or recovery to routed nently perma or technology, available best the using replaced be should it ppm, 10,000 than greater leaks for period A R components and made subject subject made and R components ny equipment found to to found ny equipment A QM A R monitoring. R monitoring. D currently has has currently D 94

95 It should, It should,

- A R - - - high winds) or operating conditions (e.g., conditions operating or winds) high (e.g., weather like factors, real-world But, flare. the to VOCs sent of the percent 99 to 98 destroys flaring that assumption on the based calculated generally are emissions Flare underreported. likely meteorological variables. be compromised by operational and and efficiencythe destruction can emissions of toxics and other pollutants, not, however, completely all eliminate gases. burn The combustion doesprocess are used to by facilities petrochemical flamesarevisible foroften miles. Flares canreach 600stacks flare feet,andtheir source at Somefacilities. petrochemical the most identifiableeasily pollution F minimization plans, conduct root cause cause root conduct plans, minimization develop flare systems, recovery gas flare install should plants rochemical Recommendations: …” pollutants noxious other and dioxide of sulfur releases high ceptably unac in results This equipment. control pollution bypass to used is or ations situ non-emergency routine, in occurs “frequently flaring that found tions emergencies. to be attributed could events of flaring 4percent only 2003, 1999 and tween M operation. ­routine during emissions flare to facilities ted permit even has TCEQ cases, some In operations. routine of part a as flares use often companies emergencies, for flares using of instead Unfortunately, recovered. be cannot and failures ity facil emergency of result a as released are that gases of volumes large treating be should purpose sole Their limited. ly strict be should they emissions, toxic of emissions. higher cantly signifi in result can ratio) steam poor lares anagement District found that be that found District anagement A California’s South Coast A Coast South California’s Because flares are significant sources sources significant are flares Because s with fugitives, flare emissions are are emissions flare fugitives, s with .

To the general public, are flares 96 Similarly, EP Similarly, Refineries and pet and Refineries A investiga ir Quality Quality ir 97 ------23 Houston, We Have a Problem - - Flare - - during

In addition In Minimize Flaring with

104 (June pp. 83–85. 2002), (April 2005). 12, ll petrochemical facilities should Flare Gas Recovery Minimization Strategy During Plant Upsets: Freeport Hydrocarbon Processing, Steven Krietenstein, Dow Chemical Co., ery’s emission-reduction objectives and conserving facility resources.” — tine flaring and reduce flaringtineflaring reduce and (1) routine(1) operations, (2) planned startup, shutdown and maintenance, and (3) small upsets. Elimination of flaring, exceptduring trueemergen cies, will be the proof whether of facilities have installed adequate flare gas recovery capacity. minimizationFlare plans. petrochemical recovery, gas flare to detailed flare develop facilitiesshould minimizationeliminate to plans rou Chemical Dow Saved Flaring Reducing Million $2.5 Company 2001 2003, to From Dow in Chemical Company, Freeport, reported Texas, a 54 percent reduction from startup, emissions in shutdown and off- ­spececification incidents. The project optimized the equipment of use re-circulate to off-spec hydrocar Flare Gas Recovery Virtually Eliminated Eliminated Virtually Recovery Gas Flare Refinery Dorado El Oil’s Lion at Flaring Dorado El Lion Refinery, Oil Company’s Arkansas, in installed 2 flare gas recovery systems, which “reduced levels, therebyflaring near-zero to achieving the refin applyingof this emission-reducing technology at others.” install sufficient flare gas recovery capacity to handle all gases from: bons the to front the of plant be to reprocessed. In Dowdoing so, documented million. $2.5 of savings — a

• ------. Some rea A ir Quality

101 The district The Petrochemical 100 The district The es 102

103 anagement District Several state and local 98

99 any Houston-area refineries have anagement District flaring rule ir Quality M Flare gas recovery systems reduce California’s South Coast A forcement actions by the EP Valero touts recentValero investments in flare-gas recovery systems at of some its facilities, and notes that the com signed consent decrees to settle en theseof agreements call for enhance mentsto flare gas recovery systems. minimization flare of emissions during such events. timates that its rule will reduce flare emissions, includingemissions, VOC by more than 50 percent from 2003 by 2010. levels, requires: improved monitoring, (1) (2) flaring only as a resultemergency, of shutdown, startup, turnaround, or essential operational need, and (3) prevention measures. found that adding compressor capac ity and instituting better flare man agement practices resulted in an 85 percent reduction in emissions VOC between 2002 and 2005. prohibits flaring non-emergenciesin unless the flaring is consistent with a facility’s flare minimizationplan, which must include all feasible flaring ing is not good air pollution control practice. air pollution control districts have adopted rules prohibiting all routine flaring. Flare gas recovery systems allow plants to recover gases, which are valuable product, rather than simply burning them. Federal regulators acknowledge the benefitsof flare gas andrecovery, state that routineflar Flare Gas Recovery: facilities have alternatives to flaring. emissions. California’s Bay A A M pany is considering the “feasibility

analyses flaring of events, and improve flaremonitoring. • m 24 Houston, We Have a Problem • •

currently required by two air districts required bycurrently districts two air emergency events. The plans are proper monitoring, however, is it monitoring, proper heights. flare and air, ambient plume with of the dilution undefined the turbulence, and winds to due flames of flare nature irregular the heat, radiant and temperatures high to due to measure difficult are Flare monitoring: measures. ule for implementation of corrective changes), and maintenance a sched event (including design, operation and offlaring likelihood another similar of means availableall to reduce the causes to event,the flaring ananalysis the root causecontributing and all include of adetermination detailed more of VOCs. ing events in 100resulting pounds or conduct root forcause analyses flar should andfacilities petrochemical emissions, dothese notreports in and the actions totaken minimize ance of authorized pollution limits an exceed actions totaken minimize, onreport the likely cause of, and any tions against Houston area refineries. events in some of its enforcement ac action for refinery hydrocarbon flaring vestigations, reporting, and corrective flaring events. ies to conduct root cause analyses of Root analysis. cause personnel on reduction. flare and awarenessto focus plantprograms as welldepressurization, as training procedures tional such as slower vessel reduction measures, including opera plans should include feasible all flare Source Standards. Performance by EP and have been in California proposed South Coast and Bay clude root cause analyses. M anagement require Districts refiner While While Texas to requires facilities A for refineriessubject to New 106 108 EP The should analysis Flare emissions emissions Flare A has required in A 109 California’s rea Without Without A A ir Quality ir Quality ll refining ll refining 105 Such ------107 - - atmospheric pressure can also lead to to lead also can pressure atmospheric in changes or roof) onafloating water (e.g., standing Rain maintenance. poor or wind due to out-of-circular get tanks where true particularly is This tanks. of the walls the meets roof the where seals the from and roof the holes in out of leak Emissions roof. floating or more. or 10 of factors by underreported be to emissions tank LID using studies other as well as TCEQ by Studies inventory. the in reflected is what than higher much likely are however, emissions, County. Harris for Inventory Emission Source Point 2004 TCEQ’s to according area, Houston the in emissions benzene of source largest T

an M

 include: to monitoring flare enhanced conduct 15 every minutes. atleast value net heating and weight molecular VOC content, of determining capable analyzer on-line by monitoring HRVOC content and monitoring, sure pres and temperature monitoring, flow continuous including: flare, the to going stream gas of the monitoring enhanced conduct to required rently cur are HRVOC service in area community. surrounding the to risks health presenting are emissions flare whether or adequately performing are flares whether know to impossible      

k ost tanks are equipped with a fixed afixed with equipped are tanks ost A Flares in the Houston-Galveston Houston-Galveston the in Flares s continuous volumetric vent volumetric continuous video monitor video and integrity, seal water flowrate, steam value, net heating benzene for composition speciated calculations, velocity hourly exit gas flow,gas area exceeds an ESL, ESL, an exceeds area the which for toxics other any and . ll petrochemical facilities should should facilities petrochemical ll

Storage tanks are the single single the are tanks Storage ing. A ctual tank tank ctual 111

A R, have found found have R,

- 110

-

25 Houston, We Have a Problem

- - -

114 anagement anagement M Tanks Required Required Tanks more stringent re more

enefits of Vapor Recovery Recovery Vapor of enefits irQuality A Lessons Learned: Installing Vapor rea rea A

Recovery Units on Crude Oil Storage Tanks, lessons/11_final_vap.pdf (Oct. www/epa.gov/gasstar/pdf/ 2003). Texas currentlycontrols requires Texas s shown in Table 9, 9, Table in shown s A quirements are currentlyare by required quirements Bay the Districtregulations federal and certain to tanks. storage ­applicable B Touts EPA Tanks Storage Oil Crude for “VRUs (Vapor Recovery relatively are Units) simple systems that can capture about 95% the of Btu-rich vapors for fuel. sale as or for onsite use Currently between 8,000 and 10,000 installed are VRUs the in productionoil sector, with average four an of tanks connected partners STAR Gas each Natural to VRU. generatedhave significant from savings recovering and marketing these vapors while at the same time substantially reducing methane and HAP emissions. Partners found have that when the vapors volume of sufficient,is on installing a VRU one or multiple crude storageoil tanks $260,060 to up can save per year and payback little as in three as months.” — U.S. EPA, capacity of 10,000 gallons or greater gallonsor 10,000 of capacity maximumpres a and vapor organic all tanks(2) greater, or psi 11 of sure maximumwith 40,000 a of capacity maximum a and greater gallonsor or psi 4.0 pressureof vapor organic all tanks(3) and arethat greater, Control leakers. chronic be to found minimum a 95 have should devices efficiency. percent tanks for maximumwith a organic if:greater or psia 11 pressureof vapor tanks those con crude and oilstore (1) maximum a capacity have and densate the (2) or greater gallonsor 40,000 of a have tanks and liquids other store maximumgallon capacity. 25,000 Controls, to Route to

- - - 113 113 anagement Repairs 112 Facilities should Companies should in ir Quality M ll floating roof tanks and A t a minimum, following a the t use the of capured vapors. or recovery to routed tanksbe should all tanks maximumwith a (1) ­controls: crease the number tanks of routed to vapor recovery or control devices. recoveryVapor systems are relatively inexpensive and their costs can often be recovered through the sale or re 72 hours detection. of should be made using the best avail technologies,able including the best seal systems. GasRecovery: openings with defects or visible gaps should be completed before filling an emptied and degassed tank, or within 7-days discovery of defect. of The South Coast A District requires such repairs within LeakMinimization andRepair: Leaks from tanks storing toxics should be minimized to the extent possible within 24 hours. Repairs or replacement any of piping, valves, vents, seals, gaskets, or covers roof of tanks quarterly and after any repairs. Results should be documented. If leaks are found, inspections should be conducted to determine their source and repairs made. InspectionsandPassive Optical Gas Imaging: seals should be visually inspected twice per Passive year. Optical Gas Imaging should be used to search for leaks in all fixed floatingand roof a • • • Recommendations: reduce emissions from storage tanks by improving inspections for and repairs of leaks, and by using closed systems vent for tanks with excessive toxic emissions. emissions. In addition, tank emissions are extremely high during the landing of floating roofs for maintenance, cleaning, or a change product. of 26 Houston, We Have a Problem T 40 CFRPart63,SubG (60.112(b)) 40 CFRPart60,SubKB 40 CFRPart61,SubFF(61.343) BAAQMD 8-5-301 Rule (63.119(a)(2)) able 9.T anks RequiredtoouteControls • should: facilities systems, wastewater from sions Recommendations: Houston region. of benzene emissions in the ten-county weresystems responsible for 10 percent City of Houston found that wastewater emissions at refineriesnationwide. source largest of are the third VOC that wastewaterdetermined systems span hundreds of acres. The EP each unit at and often the facility that serve systems are large systems W astewater   follows: as sources additional cover to panded ex be should systems wastewater for requirements control Current requirements: control Expand a Refineries and chemical plants plants chemical and Refineries exemptions for: for: exemptions the utilizing without rules water waste TCEQ’s with comply should of 10 M threshold lowerwould current the NESH Waste Benzene federal the with comply yr) should ( year per 5megagrams than greater or to equal waste facility from quantity benzene annual ny wastewater system with total total with system ny wastewater ≥ 20,000 ≥ 40,000 ≥ 20,000 ≥ 265 ≥ 40,000 ≥ 10,000&≤40,000 Tank Max.Capacity (gallons) g/yr. .

Industrial wastewater Industrial 116

117 To reduce toxic emis toxic To reduce

A P. This A has has

115 M - The g/ ≥ 11 ≥ 4 ≥ 11.1 ≥ 11.1 of totalorganicHAP) ≥ 0.1(maximumvaporpressure of totalorganicHAP) ≥ 1.9(maximumvaporpressure Pressure (psi) Tank MaximumOrganicVapor - - • •

Gas Imaging. Gas Optical Passive during leaking be to found components wastewater any and hatches, boxes, junction hubs, sewer include: should streams ter wastewa for components monitored List: LDAR to Components Wastewater Add period. a12-month in failed are inspections more or three if daily to increased monitoring with weekly, seals water inspect to quired re currently are HRVOC service in area Houston the in Facilities week. per twice to increased be should dry not are they ensure to traps of pea inspection visual Routine quarterly. Imaging Gas Optical Passive with facilities treatment and lection col wastewater all inspect should Monitoring: Improve (2) affected VOC waste streams for for streams VOC waste affected (2) 10 to M equal or than less VOC loading annual with (1) plants control option.” control overall percent “90 alternative the or biotreatment when utilizing VOC reduction percent a95 at least achieve should sources n addition, VOC load of annual sum the which ing is less than or equal to 10 to M equal or than less is ing

Facilities’ list of LD of list Facilities’

the equivalent. Requires closedventsystemor these limits. systems onlyfortanksbelow for fixedroofandclosedvent Exemption fromrequirement control system Requires pressuretankor balance fuel gasorprocess,vapor Requires control,routingto Controls 118

119 Companies Companies g,

or or A -

R g.I -

-

- 27 Houston, We Have a Problem - - - - - et Y lberta 124 Coker emis Coker 126 125 Petrochemical facili ontana refinery and Delayed cokers are

. ll or modified new coke A ers k o C ed y artinez, California. L Study found that the delayed blowdown and coke handling system for a Billings, M has designed totally enclosed systems for California and German refiner ies, including the Tesoro Refinery in M Improved Monitoring: sions, including and VOC benzene emissions, should be monitored during drilling. Drilling is part the of coking process during which pressure water jets are used to fracture the coke bed in a drum and allow it to fall into the receiving area. Best Available Technologies and Practices: drum unheading areas and coke handling areas should be enclosed and vented to a blowdown system. Conoco has installed an enclosed management practices for reducing leaks into cooling water, includ ing installation of redundant heat exchanger capacity, where feasible, to allow for rerouting of hot process gases when a leak occurs. Delayedcokers are significant sources A ela • U.S. refineriesU.S. notdo report fugitive emissions or benzene VOC of from the delayed coking process. Recommendations: ties should, at a minimum, take the fol lowing steps to reduce toxic emissions from cokers: • D used at refineries to convert petroleum residuals into liquid and gas products. A byproduct the of process is petroleum a solidcoke, concentrated carbon material. toxicof emissions that are not included in emission inventories. A The DI cokers are the single largest source refineryof benzeneemissions. - - - of their all Repair of any Cooling tower TCEQ has since Cooling towers are To reduceTo toxic emis Plants should use

121 . : pounds per year that Investigations by TCEQ

120 total owers 122 T Use of Best Available Technologies best available technologies and Set Repair Deadlines: exchanger leaks involving benzene, or other toxics for which an area ex ceeds an ESL, should be made within 48 hours. Improve Monitoring: monitoring should include speciation for benzene and any other toxics for which an area exceeds the state’s am toxicbient goals, or ESLs. ooling

• • Recommendations: sions from cooling towers, companies should expand TCEQ’s current cooling tower rules to include the following. • towers. These rules, together with increased enforcement, appear to have been successful at reducing emissions from cooling towers and should be expanded. pounds per year, almost half of the 4.9 million these facilities reported from emission sources. adopted rules requiring monitoring of highly reactive VOCs in cooling water is cooled in the Coolingtower. towers emit large quantities of toxics that have historically been largely unreported. in 2002, measured VOCs from nine cooling towers totaling 2.3 million gases in these tubes are typically at a high pressure and will leak into the cooling water if holes or cracks develop in the tubing. VOCs, including toxics that have leaked into the cooling water, are released to the atmosphere as the C used to transfer process waste heat to the atmosphere. Hot process gases are cooled in heat exchangers by running through tubes immersed in water. The 28 Houston, We Have a Problem

Houston that are unsafe. responsible, there ofare clearlyareas still where have regulators those targeted ent toxic levels and while some reduc ample totime voluntarily reduce ambi well documented. enjoyedhas Industry Houston’s toxic hotspot problem beenhas Eliminate Toxic Hotspots Support Reasonable Regulation to tions have been achieved, ommended by SC by ommended ing gases from blowdown systems, systems, blowdown from gases ing in the Refinery NSPS. Refinery the in rec been has and refinery California ata required currently is venting before 2psig to Depressurization venting. before 2psig to system, ablowdown via de-pressured, be should cokers and drum, coke the in of gases accumulation the ing minimiz for plans operational coker develop should Facilities systems. recovery gas fuel to routed be should For existing systems, gases, includ gases, systems, For existing A Q M 127

D for inclusion inclusion D for particularly particularly

- - - - - try to doto protect its try publicpart health economiescontrols through of scale. field,and reduce the price ofpollution technology innovation, level the playing panies money. serves Regulation to drive some toxic controls evencan save com predicts. dustry muchcontrols are usually lower in than showstudies of actual that costs pollution drive them outtions will of business, regula andthat environmental protests repeatedly decries regulation, industry the public about toxic hotspots. theagency environmental state to notify islation that would have merely required opposed toxicsstate legislation, even leg Texas Petrochemicals, Equistar, and BP, regulations to eliminate toxic to hotspots. eliminate regulations mental groups, to develop reasonable well health andas community environ work state and local with as regulators, toxicshould emissions. Industry dustrial enforceable requirements for reducing in concrete,by supporting measurable and companies, including Exxon It is fortime theindus petrochemical M any Houston area petrochemical 128

A s this report explains, explains, report s this M obil, Shell, Y et, while 129 -

------29 Houston, We Have a Problem ------R or similar A R programs by iden A dditional speciation requirements and routine flaring; tifying unknown sources leaks, of and storage supplement tank and wastewater monitoring programs; tanks with potentially large toxic emissions; for cooling tower monitoring and deadlines for leak repair; and and bestmanagement practices to reduce delayed coker emissions; Flare gas recovery to eliminate Passive Optical Gas Imaging to support LD toVenting controls for storage fuelUse of gas recovery systems ake toxic pollution reduction a com a Support reasonable regulatory pro posals, instead using of publicly unac countable lobbying firms and trade associations to fight toxic control requirements. the accuracy emissions of estimates through the use LID of facility-wide monitoring; Use current best available technolo gies and management practices to reduce toxic emissions, including:      implement programsimplement to protect resi dents from adverse health effects due totoxic air pollution. pany priority, second only to safety; Increase toxics monitoring and verify Encourage local governments to • • • Industry should: • m • - - - -

- xisting ambient air monitoring data confirms that toxic hot spots warrant immediate action dopt hotspots legislation requiring doptlegislation to identify and assist dopt enforceable ambient toxic stateor local governments to identify and clean local up areas with unsafe ambient air of levels toxics; and in the cleanup local of toxic hotspots. standards; health impacts chemicals of before they are released to the market; and ing requirements, including requiring the use technologies new of for mea suring facility-wide emissions; Consider aggregate and cumula tive impacts toxic of emissions in ­regulatory determinations; Require information regarding the Federal, state and local governments, Improve toxic monitoring and report • a • a • • The State Texas of should: • a these steps in order to protect people from the health threats posed by toxic air pollution. The federal government should: • mental regulators, and the absence of concerted remedial action by industry and government to reduce ambient ­toxics to safe levels. as well as industry, should implement in urban areas such as Houston. These hotspots are the result of inadequate public health consideration by environ Industrial Toxic Emissions Toxic Industrial E Conclusion: Conclusion: Reducing for A Roadmap 30 Houston, We Have a Problem 31 Houston, We Have a Problem -

O - A

A Closer

(Sept. ir Toxics, Guidance on . VOCs are f O 06-669). A (Feb. 2007) 2–11. p. A Docket No. ayor’s Task Force on ir Pollution, EPA ShouldEPA Improve www.epa.gov/ttn/atw/ (June 2006), 18–19. p. ccountability Office, . f ir Quality Planning and ir Quality Planning and ir Quality Planning and (June 26, 2006), 36. p. (G ug. 31, 2007),ug. 31, Finding 7 p. A R-2003-0146). (July 3, 1997). Residual Risk Report to Congress Residual Risk Report to Congress, EmissionFactor Uncertainty ( A A does not even consider all emis -O A Technical Memorandum: Potential QS II Rapid Science Synthesis Team, , Office of A , , Office of A , Office of A , Science Policy Council, -H A http://www.esrl.noaa.gov/csd/2006/ arch 1999), U.S. ES-7. p. Government arch 1999), ES-11. p. A Office of Inspector General, A A A Workgroup on Integrated A A A A A Office of Inspector General, A . at 22. p. ccountability Office, M M EP ( A (June 26, 2006),( G 6–7. p. In fact, EP EP Look Pollution at Air in Houston: Identifying Priority Health Risks Id factfinder.census.gov. Id. Needed to Conduct Residual Risk Assessments (Oct. 2007), 31, (Report 17 p. 08-P-0020). No. Cumulative Risk Assessment. Part 1 Planning and Scoping Standards, the Management of its Toxics Air Program sions from the units it is reviewing. does It not include in its consideration impacts from non-routine events, such as unit startup, shutdown, or malfunction. ShouldEPA Improve the Management of its Air Toxics Program 06-669). RecommendedEPA Framework for State/ Local/Tribal Toxics Air Risk Reduction Program, Final Workgroup Report 2000), http:// 2.27. p. urban/facawg.pd Standards, Standards, Assessment Review Draft Improvements Toxics in Air Emissions Data Needed to Conduct Residual Risk Assessments (Oct. 2007), 31, (Report 18. p. No. 08-P-0020). Final Rapid Science Synthesis Report: Findings from Second Texas Quality Air Study (TexAQS II) C2. rss/rsstfinalreport083107.pd chemical compounds that have high enough vapor pressures under normal conditions to significantly vaporize and enter the atmo sphere or to participate in a photoreaction. Low Bias of Reported Emissions VOC from the Petroleum RefiningIndustry Improvements Toxics in Air Emissions Data ( U.S. Government A See, City of Houston, M the Health Effects of A (July 27, 2007),(July 27, (EP 1. p. EP EP 2000 US Decennial Census, http:// EP Tex EP EP EP EP

25 26 27 18 19 20 21 22 23 24 13 14 15 16 17

-

Air Air A , / Clean Air Air AA , (June 26, EPA CanEPA ssessment ct states A is required ir A A Office CT technology . (Oct. 29, 1993); l EPA ShouldEPA Improve Progress Made in ir Toxics A ct §112(d)(2) & (3). ccountability Office, ccounting Office, Improvements Toxics in Air (Oct. 2007). 31, (Nov. 29, 1994); (Nov. and . ir A www.epa.gov/ttn/atw/ l arch 22, 2006), (Report 1. p. . (June 26, 2006) (Report No. l AA §112(f). EP M ( ). http:// Air Pollution:Air Progress and Problems in A , Office of Inspector General, T O-06-669). ar. 2, 1995). See also, U.S. Government arch 2, 2005); A Office of Inspector General, A Office of Inspector General, A Office of Inspector General, A at 3–4. p. A A ccountability Office, M M try estimates were made using U.S. EP ­emission factors. ( A (June 26, 2006). See also, EP Improvements Toxics in Air Emissions Data Needed to Conduct Residual Risk Assessments (Oct. 2007), 31, (Report19. p. No. 08-P-0020). Improve Emission Factors Development and Management 2006-P-0017).No. Eighty percent of indus Id. EPA ShouldEPA Improve the Management of its Air Toxics Program Improvements Toxics in Air Emissions Data Needed to Conduct Residual Risk Assessments (Oct. 2007), 31, (Report19. p. 08-P-0020) No. of Inspector General, Monitoring Ambient Toxics, Air But Further Improvements Can Increase Effectiveness Emissions Data Needed to Conduct Residual Risk Assessments Act Amendments of 1990 Pollution:Reductions 1994Quality Air EPA’s in Program’s Budget Rulemaking:Air Tracking System Help Would Measure Progress of Streamlining Initiatives the Management of its Toxics Air Program Improvements Toxics in Air Emissions Data Needed to Conduct Residual Risk Assessments, Report 08-P-0020 No. (Oct. 2007), 3. p. Pollution: Strategy EPA’s and Resources May Be Inadequate to Control Toxics Air 1991); Implementing Selected Aspects of the Clean Air that the “ample margin of safety” standard requires lifetime excess cancer risks from the source-category to be less than one in one million. C determinations every eight years. C §112(d)(6). nata99faq.htm http://www.epa.gov/ttn/atw/nata1999/ limitations.htm to review and update its MA nata1999/risksum.htm EP G ( EP U.S. Government A EP See U.S. General A http://www.epa.gov/ttn/atw/nata1999 Federal Clean A carcinogensFor the Clean A EP 1999 National-Scale A (N

11 12 9 10 8 7 6 2 3 4 5 Notes 1 32 Houston, We Have a Problem 28 46 45 44 43 42 41 40 39 38 37 36 35 34 33 32 31 30 29

1995 survey by ST by survey a1995

A C L U.S. Government A Government U.S. See also, U.S. Government A Government U.S. also, See EP U.S. Government A Government U.S. p. 19. (G (2000) p. 2-5 to 2-6. to p. 2-5 (2000) Congress to Report Strategy Urban Integrated Safety Code, Div. 26, Part 6. 6. Div. Part 26, Code, Safety Implications Houston and Motivation Toxicology, Toxics: Galveston, at Branch M Texas of University the and Center Law Houston of University University, M of College Baylor University, Rice see programs, toxics state 06-669). Program Toxics Air its of Management the Improve EPA Should sources. existing and new both addressed which of 50% programs, toxics air risk-based had respondents of 60% that Standards, level.”) federal the than rather level, tribal] and local, [state, the at dressed ad appropriately more be can risks these cases many in risk, toxics air remaining the address to efforts national develop to urbandev.htm http://www.epa.gov/ttn/atw/urban/ p. 2–6. (2000) Congress to Report Strategy Urban Integrated 06-669). Program Toxics Air its of Management the Improve EPA Should Id. p. 9. Hur Can Chemicals Toxic about Know EPA Doesn’t What Why Gaps: Data Environmental Overcoming Reform, Progressive for Center Shudtz, http://monographs.iarc.fr prop65_list/files/032108list.pd http://www.oehha.org/Prop65/ Id Program Air Toxics its of Office, http://www.epa.gov/ttn/atw/orig189.htm G Louisville A Louisville ( Rena Steinzor, Katherine Baer, and M and Baer, Katherine Steinzor, Rena EP N.J. For detailed information regarding other other regarding information For detailed EP M A A A ssembly Bill 2588, Connelly 1987. & Health Connelly 2588, Bill ssembly .

A A A arch 1999), p. ES-2. 1999), arch C33:III.Chapter 51, Subchapter A 51, Subchapter C33:III.Chapter O 06-669, at p. 19. at O 06-669, A , , Office of A , Office , ssembly Bill 1807, C 1983. Bill Tanner ssembly National Air Toxics Program: The The Program: Air Toxics National The Program: Air Toxics National .C. 7:27–17..C. EPA Should Improve the Management Management the Improve EPA Should A O 06-669). Residual Risk Report to Congress to Report Risk Residual (Sept. 2006), p. 116-154. 2006), (Sept. PCD Regs. Part 5. 5. Part Regs. PCD l (“although EP (“although (June 26, 2006), p. 6–7. (G 2006), 26, (June p. 41 (G 2006), 26, (June ir Quality Planning and and Planning Quality ir t ccountability Office, Office, ccountability ccountability Office, Office, ccountability edicine, Texas Southern Southern Texas edicine, . White Paper No. 510, Paper White A The Control of Air of Control The PP (June 26, 2006), 2006), 26, (June A / . L ccountability ccountability will continue continue A will A f PCO found found PCO .

.

edical edical att att A A

- O A

l

. O

52 51 50 49 48 47 61 60 59 58 57 56 55 54 53

m

Resources, Witness List for A for List Witness Resources, Natural on Committee Senate Texas TXOG Texas Senate Bill 1317 (80th Regular Regular 1317 (80th Bill Senate Texas TCEQ, TCEQ, Health Effects of A of Effects Health City of Houston, M Houston, of City OR Dept. Env. Quality Rules 340-246-0010 340-246-0010 Rules Env. Quality OR Dept. hearing on SB1855 and SB1924. SB1855 and on hearing A Clean Texas the of passage after decades three 2001, fully in facilities, fathered grand from reductions emission mandated finally legislature Texas the program, A air. Texas clean to order in controlled be to had sources grandfathered these that clear was it 1990s, the By requirements. control from sources existing 1971, in exempted it passed was p. 3–5. (Nov. 2006), Factors Risk Unit and Values, Reference Levels, toxics. ­including VOCs, in reductions however, require 0230. through Health, Health, Better from Gains Economic the Calculating 2005) (July Environment Energy Environment, Houston Implications Control of Air Toxics: Toxicology, Motivation and Texas Houston Law Center and the University of Texas Southern University, University of Risks Health Priority Identifying inHouston: Air at Pollution Look petrochemical.as http://www.houston.org/industryGuide/ Session). http://www.aect.net M line.” bottom and line top members’ our helping to solely dedicated is and industry nology txoga.org/categories/ http://www. companies. energy ­largest state’s the of 50 of executives are whom 13&Itemid=2 php?option=com_content&task=view&id= http://www.txchemcouncil.org/index. html/C5802007041713001.HT capitol.state.tx.us/tlodocs/80R/witlistmtg/ For example, when the Texas Clean A Clean Texas the when For example, The A The See, http:// See, implementation/tox/ A Rice Rice University, Baylor College of Some Texas rules for reducing ozone levels, levels, ozone reducing for rules Texas Some A e ir A ir PWL.htm emberListing.cf IT Laboratory for Energy and the the and Energy for Laboratory IT A ) “represents all segments of the tech the of segments all ) “represents ct. http://www.aeanet.org/ merican Electronics A Electronics merican Benefits of Environmental Regulation: Regulation: Environmental of Benefits M has 2,000 members, some 500 of of 500 some members, 2,000 A has Guidelines to Develop Effects Screening Screening Effects Develop to Guidelines p. 6. edical edical Branch at Galveston, l www.tceq.state.tx.us . 7 . p m fter a failed voluntary voluntary afailed fter . ayor’s Task Force on the the on Force Task ayor’s ir Pollution, Pollution, ir (Sept. 2006), at p. 181. . (June 2006), p. 13. 2006), (June / A A . irPollutant bout-Us/ ssociation (now ssociation pril 17, pril 2007 M M http://www. A Closer A Closer embers/ / M M edicine, The ain/ ir A ir - ct ct ­

33 Houston, We Have a Problem

- - - . f

- pplies (July 27, (July 27, VOC FugitiveVOC , pplies to chemical A Proper Monitoring Technical Memorandum: R Workshop (Oct. 24, lert, , A pril 12, 2005). A R studies. Coker toxic Comments on National A A ( Differential Absorption LIDAR (Oct 2006) 25-27, 20. p. dmin. (b) (9). Code § 115.781 dmin. Code §115.352. A D Rule 8-18-301 through 8-18-305. D Rule 8-18-301 through 8-18-305. D Rule A 1173(g). Sunoco LD VOC FugitiveVOC Loses: New Monitors, QM QM , QM A A A Enforcement A A has identified cokers as one of the larg lex Cuclis, pplies in the Houston area to equipment AA AA B EP EP Steven Krietenstein,Dow Chemical Co., SC City of Houston, Data from TCEQ’s 2004 Point Source plants and refineries. example, one facility may describe emis sions from a wastewater pond as wastewater system emissions, while another facility may describe them as fugitives. est sources of refinery benzene emissions, pursuant to LID emissions are not, reflected however, in the state data. U.S. EP Potential Low Bias of Reported Emissions VOC from Petroleum RefiningIndustry 2007), 4–5. p. Essential to Reducing ‘Fugitive Emissions’ Under Leak Detection and Repair Programs (Oct. 1999). http://www.epa.gov//compliance/resourc es/publications/assistance/ldarguide.pd at refineries and chemical plants in which highly reactive VOCs are a raw material, intermediate, or final, product, or in a waste stream. HRVOCs are VOCs that TCEQ has determined contribute significantly to rapid ozone formation. They are 1,3-butadiene, butanes, ethylene and propylene. in Houston and other areas to equipment at refineries and chemical plants not in HRVOC service. EmissionStandard for Hazardous Air Pollutants from Petroleum Refineries: Proposed Rule (Docket ID No. EPA-HQ-OAR-2003-0146) (Dec. 20, 2007), 25–26. p. Loses: New Monitors, Emission Losses, and Potential Policy Gaps 2006 International Workshop Emission Losses, and Potential Policy Gaps (2006 International Workshop, Oct 25–27, 2006), 19. p. Flare Minimization Strategy During Plant Upsets: Freeport (DIAL), 2007), slide 27. Emission Inventory. Industry reports emis sions to the inventory and describes the units responsible for such emissions. There is not, a uniform however, classification system for describing emissions units. For See, for example, U.S. EP 30 Tex. A A 30 Tex. A B EP

a

85 86 87 80 81 82 83 84 74 75 76 77 78 79 - - ,

PWL. A AA arch 19, M . l ( 1 and ain/ f Houston M http://images. arathonPetroleum, http://www.epa. M slide 24. irPollutant IR/2007/February/Day- A ir Quality Task Force A - . Houston Regional Benzene l A . (Feb. 2007). m http://www.tceq.state.tx.us/im ug. 31, 2007),ug. 31, Findings A http://www.chron.com/disp/story. A ( http://www.epa.gov/air/ozonepollu . l , . Sixel, Houston Chronicle, A recently adopteda mobile source air A Winds carry the emission plumes from M , at slide 25. 2 (The highest (i.e. > 125 ppbv) ozone L. Dow Chemical, Texas City (formerly Union EP Joost Carsten de Gouw, Warneke, NO Houston Region A The statistic is based on reported emission

plementation/tox/ Report (Sept. 2007) at 7. p. Texas City Refinery was the facility with the sixth greatest risk level. PollutionAir Reduction: A Voluntary Plan for Major Sources chron.com/content/news/photos/07/02/14/ benzenetoxplanmajorsource6.pd tion/health.htm Emission Inventory. Carbide) was the facility with the fourth greatestrisk level, and concentrated plumes, which originate from HRVOC and NOx co-emitted from petrochemical facilities. The Houston Ship Channel (HSC) is the origin of the plumes with the highest ozone concentrations. the ship channel throughout the Houston area.) Id TCEQ, Final Rapid Science Synthesis Report: Findings from the Second Texas Quality Air Study A concentrations in the Houston/Galveston/ Brazoria area result from rapid and efficient ozone formation in relatively narrow, htm Environmental System Research Laboratory and CIRES, University of Colorado, Emissions and Chemistry of Atmospheric VOCs: New Insights from Airborne and Ship- Based Measurements, 26/a2667a.ht inventory data, which, as explained above, likely underestimate industrial emissions. reductions in benzene levels beginning in Benzene2011. will be reduced through fuel standards and gas can specifications that will affect both exhaust emissions as well as evaporative emissions (which are a big problem in homes with attached garages). Likewise, programs to get older cars off the road will lead to decreases in mobile source toxic emissions. Lacks Pull With New College Grads 2008). mpl/business/sixel/5634211.htm toxics rule, which should lead to significant gov/fedrgstr/EP EP City of Houston, See maps at Data from TCEQ’s 2004 Point Source

73 72 69 70 71 67 68 66 64 65 62 63 34 Houston, We Have a Problem 88 100 99 98 97 96 95 94 93 92 91 90 89

Rule for Petroleum Refinery Flares, Env- Flares, Refinery Petroleum for Rule EP 30 Tex. A Tex. 30 The rules allow a 3–7 day extension for for extension day a3–7 allow rules The SC EP 30 Tex. 30 For pressure relief devices, repairs are are repairs devices, relief For pressure and chemical plants in which a HRVOC is a is aHRVOC which in plants chemical and refineries at equipment to area Houston the B xxx.03(a)(3). Releases Dioxide Sulfur Uncontrolled Excessive, Cause A EP flaring). routine all eliminate can recovery gas flare (noting 2000). (October 1. Table p. 2, 2004) Refineries at Operations Flaring from 19–22. pp. 2006), 25–27, Oct Workshop, International (2006 Gaps Policy Potential and Losses, Emission listed. tions condi the under controls to devices relief pressure of routing the requires and day per barrels 20,000 than greater throughput a with refineries to applies 1173(h)(6) SC device. relief pressure atmospheric an for ppm 200 than greater aleak (3) or ppm, 10,000 than greater leak a (2) minute, per drops three than greater leak liquid (1) alight for: 12-months within actions repair five to subject been has that component any for device, acontrol to or venting technology, retrofit available best or controls available best with ment Id. met. are conditions other tain cer if allowed also is delay The eliminate. would repair the than emissions more create would shutdown the and shutdown require repairs if shutdown process next compressors. and 1.0% pumps and devices relief 1.0% pressure valves, 0.30% to limited non the on day. Equipment 15 lbs/ than less is leak the unless valves for 45-days to limited is Delay equipment. “non-repairable” for repair of delay allows B The agency. by if 7days operator; by discovered if 15 days within required leaks. certain areas. other and Houston in plants chemical and ies refiner at service HRVOC in not equipment stream. awaste in or product final intermediate, material, raw SC B SC 72 Fed.Reg. 27178, 27195 ( Fed.Reg. 72 The rule allows a delay of repair until the the until repair of adelay allows rule The AA AA lert, Frequent, Frequent, lert, A A A A A QM QM QM , VOC Fugitive Loses: Loses: Fugitive , VOC QM QM Enforcement Alert, Enforcement A D Rule 1173(g)(2) requires replace requires 1173(g)(2) D Rule D Rule 1118;D Rule MA D, (October 2000). (October D Rule 12-12-301 and 12-12-401. and 12-12-301 D Rule D Regulation 12, Rule 12; 12; Rule 12, D Regulation dmin. Code §115.782. A Code dmin. dmin. Code §115.352. A §115.352. Code dmin. Evaluation Report on Emissions Emissions on Report Evaluation Routine Flaring May May Flaring Routine Enforcement A Enforcement Volume 3, Number 9 Volume Number 3, R A M M AMA New Monitors, Monitors, New QM - repairable list is is list repairable ay 14, 2007) 14,ay 2007) D Rule D Rule pplies in in pplies pplies to to pplies odel odel AA (Sept. 3, 3, (Sept. QM A - - - D - 108 107 106 105 104 103 102 101 118 117 116 115 114 113 112 111 110 109

a

m

minimization plans for startup, shutdown, shutdown, startup, for plans ­minimization See, for example, example, for See, SC B 40 CFR §61.342(a). CFR 40 SC SC A Tex. 30 at included are exemptions These SC National Petroleum Refinery Initiative Refinery Petroleum National also, See Corporation events). malfunction 27182 ( 27178, Fed.Reg. 72 and 12-12-401; Rule EnvironmentalStewardship.ht http://www.valero.com/Environment/ 1-3. Table 1118 Rule Amended Proposed for Refineries Petroleum at Flares 12, Rule Performance, of Standards Miscellaneous 12, Regulation Major Sources Sources Major for Plan AVoluntary Reduction: Air Pollution Refineries at Sources II(a). roofs. domed 1178 requiring inter an to it converting otherwise or tank the on roof domed a installing first require Industry Refining Petroleum from VOC Emissions Reported of Bias Low Potential Memorandum: Technical EP U.S. factors. emission using calculated emissions reported the than higher, times 100 were emissions benzene and higher, times 30 were tanks from emissions VOC p. 1. 1983), (July Inc. Science, Engineering Study. Efficiency &(E). 1178(c)(1)(D) SC combusted. gas vent of feet cubic standard 5,000 than more in resulting event any for or VOCs of more or pounds 100 in resulting turnarounds, or startups shutdowns, planned than other events, 30 Tex. A Tex. 30 B SC EP 2005) (EP 2005) (EP City of Houston, Houston, of City SC nal floating roof tank. See, SC See, tank. roof floating nal 30 Tex. A Tex. 30 For external floating roof tanks, this would would this tanks, roof floating For external AA AA ccording to the A the to ccording dmin. Code §115.147(1) Code &(2). dmin. arc M arc A A A A A A A A QM QM QM QM QM QM , QM QM -HQ-O Memorandum: Review of VOC Emissions VOC of Emissions Review Memorandum: M cDaniel, EP cDaniel, D Rule 1118(c)(1)(D) and (e); (e); and 1118(c)(1)(D) D Rule D Rule 1118.D Rule D Rule 1118(c)(2); B 1118(c)(2); D Rule D requires root cause analyses for for analyses cause root D requires D, D Rule 1178(g). D Rule D Rule 12-12-406. D Rule D, U.S. EP U.S. ay 14, 2007)(proposing flare flare 14,ay 2007)(proposing dmin. Code 115.112 Code and I(a) Tables dmin. dmin. Code §115.725(d). Code dmin. (July 8, 2005) p. 1. 2005) 8, (July A Final Environmental Assessment Assessment Environmental Final Staff Report, Proposed Regulation, Regulation, Proposed Report, Staff -HQ-O A , Consent Decree p. 80. p. 80. Decree , Consent R-2007-0011-0112). (Feb. 2007), p. 4. p. 4. 2007), (Feb. A Houston Regional Benzene Benzene Regional Houston (July 27, 2007) at 5-6. at 27,(July 2007) , A U.S. v. ExxonMobil v.U.S. ExxonMobil EPA Enforcement: EPA Enforcement: lberta LID lberta R-2007-0011-0043). A at 2, Table 1 (Dec. 14, 1(Dec. Table 2, at -600/2-83/052, Flare Flare -600/2-83/052, AA A A m A R study, R study, QM QM (Oct. 2005), 2005), (Oct. QM . D D Rule D Rule D Rule D Rule

A - , 35 Houston, We Have a Problem . f D, D, . QM c http:// A R-2007-0011- A Falling Prices: OGC.do M -HQ-O www.casaconsulting.

A ug. 24, 2007). Delayed Coking, an A ( ohsen Nazemi, SC (November 1997) p.2. emorandum: Review of VOC M , “ A , at 9–12. p. Id Letter from M com/events/speeches/ Emissions Sources at Refineries” at 2, Table 1 (Dec. 2005) 14, (EP 0043), at 4–5. Ehrhardt, Franz, Attractive Alternative. Subject: proposed New Source Performance Standard for Petroleum Refineries in 40 CFR part 60, Subpart [Docket Ja ID No. EPA-HQ- OAR-2007-0011] Economic Policy Institute, Cost of Complying with Environmental Regulations Almost Always Less than Advertised www.epi.org/briefingpapers/bp69.pd EP

125 126 127 128 129

). P, 40 CFR P, A A (Feb. 2004), (July 27, 2007)(July 27, Refinery D 1176(e)(6)( ss’n for Smog ss’n for Smog QM A (Nov. 1, 2006), 1, (Nov. 13. p. Cooling Off: State Investigations Smokein the Water Technical Memorandum: Potential dmin. Code §115.781. , A iscellaneous Organic NESH 30 Tex. A U.S. EP Environment Canada, Ninety-five percent efficiency is required by the M Galveston-Houston A Prevention, Show Reductions in Cooling Tower Emissions, (Jan. 2007). Demonstration off Optical Technologies for Measurement of Fugitive Emissions and for Leak Detection, Low Bias of Reported Emissions VOC from Petroleum RefiningIndustry at 4. Prevention, 1. p. Part 63, Sub FFFF, as well as by other state’s rules, such as SC Galveston-Houston A

124 122 123 119 120 121 APPENDIX

TEXAS GULF COAST TOXIC HOTSPOTS Source: Texas Commission on Environmental Quality (http://www.tceq.state.tx.us/implementation/tox/AirPollutantMain/APWL.html) APAPWL1201WL 1201 (Freeport) (Freeport) – AAr rsenic,senic, CobCobalt,alt, N Nickel,ickel, Van Vanadiadiumum

1

1

2 3 1 4

6

5 6

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 The Dow Chemical Company 100225945 2 Freeport Welding and Fabricating 105097513 3 Nalco Company 102185717 4 Gulf Chemical & Metallurgical Corporation 100210129 5 Conoco-Phillips Company 100221134 6 Freeport LNG Development, LP 103196689

APWL1202 (Texas City) – Acrolein, Butyraldehyde, Propionaldehyde, Valeraldehyde, Benzene, and Hydrogen Sulfide

5

3 1 3 4 6 11

7 2 8

9

10 9

9

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 BP Products North America, Inc. 102535077 2 Praxair, Inc. 104095435 3 Marathon Ashland Petroleum Company 100210608 4 Union Carbide Corporation 100219351 5 Sterling Chemicals Inc. 100212620 6 Valero Refining Company 100238385 7 BP Amoco Chemical Company 102536307 8 Oiltanking Texas City, LP 100217231 9 Gulf Coast Waste Disposal Authority 100212463 10 TEPPCO Crude Pipeline Co. 102560182 11 Applied Industrial Materials Corporation 102707049

APWL1204 (Lynchburg Ferry Area) – Benzene and Styrene

1

3 2

4 5 13 11 9 10 7 6 8 14 17 12 16 18 20 21 19 15 15 45 26 22 43 23 44 25 24 27 25 28 25 29 37

39 33 30 38 31 35 34 42 40 32 36 41

- Facility Within APWL - APWL Area of Concern

Number Company Name RN Number Company Name RN 1 Southwest Shipyard LP 100248749 24 Oiltanking Houston LP 100224740 2 Owens Corning 100210483 25 Stolthaven Terminals Inc. 100210475 3 Sneed Shipbuilding, Inc. 100867498 26 Vopak Industrial Services USA, Inc. 100223007 4 Buffalo Bunker Express N/A 27 Intercontinental Terminals 100210806 5 K-Solv LP 104963897 28 Air Liquide 102287448 6 Solar Turbines Incorporated 100214477 29 Global Octanes 100542331 7 Flex Tanks Systems LLC 100542489 30 Matlack 101643088 8 DTX Oil LLC 105052500 31 Clean Harbors Environmental Services 102184173 9 Stolt-Nielsen Transportation Group, Inc. 102562063 32 Hampshire Chemical Corp. 100219070 10 Stolt-Nielsen Transportation Group, Inc. 104267133 33 Rohm and Hass Texas Inc. 100223205 11 Boasso America Corp. 103934170 34 Praxair Inc. 102684974 12 Kirby Inland Marine 104352265 35 Lubrizol Corp. 104026950 13 Channel Shipyard 100218429 36 Lubrizol Corp. Deer Park Plant 100221589 14 Delta Engineering Corp. 102574936 37 OxyVinyl Corp. Deer Park 100224674 15 Houston Fuel Oil Terminal Co. 100223445 38 Oxy Vinyl LP - Caustic 100542265 16 Powell Industries 100582352 39 Shell Chemical Inc. 100211879 17 Slay Transportation Company, Inc. 100558600 40 Hexion Specialty Chemicals - Deer Park 102590775 18 Duco, Inc. 100587237 41 Delta Chemical Services 100924042 19 Johann Halterman LLC 100219237 42 Calpine Corporation 100222033 20 Johann Halterman LTD 102610912 43 Valvoline - First Recovery 101719342 21 Precoat Metals (Sequa Corp.) 100217926 44 Valvoline Inc. 102802493 22 GE Packaging Power Inc. 100217959 45 Techcote Industrial Coating LTD 101078210 23 Mosaic Crop Nutrition LLC 102056777

APWL1206 (Galena Park) - Benzene

2

1

2 4 2

5 22 2 5 3 2

7 9 6 14 10 11

7 8 12 7 8 15 13

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 TEPPCO Crude Pipeline LP 101921781 2 Kinder Morgan Liquid Terminals, LP 100237452 3 Vopak Terminal Galena Park Terminals Inc. 102753670 4 Texmark Chemicals 100238740 5 National Oilwell, LP 102309150 6 Arrow Terminals 100870237 7 Valero Refining Texas LP 100219310 8 Houston Refining LP 100218130 9 Gulf Coast Waste Disposal Authority 100219500 10 Pasadena Paper Co. 100224609 11 Pasadena Refining Systems Inc. 100716661 12 Motiva Enterprises LLC 100211259 13 Matlack Inc./Brite-Sol Services 100894773 14 United States Gypsum Company 100212281 15 Channel Energy Center LP 100213107

APWL1207 (Milby( y Park)) – 1,3-Butadiene,

1 2

3 5

6 4

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 The Goodyear Tire & Rubber Co. 100870898 2 PL Propylene LLC 102576063 3 Kemiron Gulf Inc. 102510104 4 Texas Petrochemical LP 100219526 5 Sims Bayou South Wastewater Treatment 102949013 6 Kemiron Gulf/Texas Petrochemical Wastewater N/A

APWL1003 (Port Arthur) - Benzene

2

9 1

6 10 4

4 4 3 2 5 4 11 7

8

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 Motiva Enterprises, LLC 100209451 2 Huntsman Peterochemical Corporation 100217389 3 Chevron Phillips Chemical Company 100209857 4 The Premcor Refining Group, Inc. 102584026 5 Chevron USA 102197385 6 INEOS America LLC 104620083 7 Signal International Texas, LP 102509676 8 KMCO , LP DBA KMTEX 100640283 9 Transit Mix Concrete & Materials Corp. 102755667 10 Neofuel USA LLC 105158281 11 Great Lakes Carbon LLC 100209287

APWL1002 (Beaumont) – Benzene, Hydrogen Sulfide, and Sulfur Dioxide

1 5 3

2

6 4

7

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 Kinder Morgan Petcoke, LP 103080883 2 Exxon Mobil Oil Corporatioin 102450756 3 Exxon Mobil Chemicals 100542844 4 Equistar Chemicals, LP 100825413 5 Shawcor Pipe Protection LLC 105230023 6 Arkema Inc. 100216373 7 Chemtrade Refinery Services, inc. 100218392

APWL1402 (Corpus Christi) - Benzene

4 2

1 7 2 8 6 2 5 4

3 6

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 American Chrome & Chemicals LP 100210814 2 Valero Refining - Texas LP 100211663 3 Citgo Refining and Chemicals Company LP 102612488 4 Megellan Terminals Holdings LP 102536836 5 Citgo Refining and Chemicals Company LP 102555166 6 Flint Hills Resources LP 102534138 7 Corpus Christi Congeneration LP 100224302 8 Nueces Bay Energy LLC N/A

APWL1004 (Port Neches) – 1,3-Butadiene

5

3

2 4 1

3

2 2

- Facility Within APWL - APWL Area of Concern

Number Company Name RN 1 Calabrian Corporation 101645018 2 Huntsman Petrochemical Corp 100219252 3 ISP Synthetic Elastomers LP 100224799 4 Texas Petrochemical LP 104964267 5 Port Neches Towing, Inc. 102881208

APWL1001 (Evadale) – Hydrogen Sulfide

Mead Westvaco Texas, LP (RN102157609)

- Facility Within APWL - APWL Area of Concern

Area of Concern: $South of FM-2246 $East of FM-105

Explanation of why this location and pollutant are on the APWL: Mobile air monitoring trips were conducted within TCEQ Region 10 in 2003, 2004, 2005, and 2006. Several measured hydrogen sulfide (H2S) levels measured downwind of Mead Westvaco in Evadale, TX were in excess of the 30-minute H2S TCEQ regulation standard.

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