Air Pollution Permitting
and the Texas Commission on
Environmental Quality
Neil Carman, PhD
February 20, 2017
Texas Commission on
Environmental Quality
• Air permits regulate air pollutants.
• Criteria air pollutants: particles,
sulfur dioxide, nitrogen oxides, lead,
carbon monoxide, ozone.
• Air toxics: benzene and others.
Texas Commission on
Environmental Quality
• Flaws in air permits - 100%
• Flaws in plant air monitoring- 100%
• Flaws in complaint investigations
• Flaws in enforcement - common
Texas Commission on
Environmental Quality
• Flaws in air permits – require a
Flare Gas Recovery System?
• $15 million – cost of 1 new FGRS
• Exxon - Ground Multi-Point Flare
Texas Commission on
Environmental Quality
• Ground flares emit smoke? Quantity?
• It’s possible to measure and calculate
all the soot particles.
• Will Exxon monitor its soot particles?
• Tiny soot particles are regulated.
• Ethane cracker - C2H6 hydrocarbon
• Ethane  Ethylene
• Ethylene C2H4 – forms rings if it’s
burned without sufficient oxygen,
time, temperature, turbulence.
flares can easily smoke.
Health Effects of Air Pollution
• Smoke, soot – tiny particles PM2.5
• Soot particles are released by flares
and burning fossil fuels.
• PM2.5 particles made of unburned
chemical toxins called PAHs.
Health Effects of Air Pollution
• PAHs – Polycyclic Aromatic
Hydrocarbons in smoke particles.
• Dozens of PAHs – 40 by CARB are
human cancer-causing substances.
• PAHs are carcinogens – Benzo-apyrene (BAP) – benzene toxin
Health Effects of Air Pollution
• PAHs are in the visible & invisible
smoke from industrial plants.
• Soot particles and PAHs are not
monitored continuously in stacks.
• Air permits place limits on PM2.5
Health Effects of Air Pollution
Benzene
Benzene
Health Effects of Air Pollution
Texas Commission on
Environmental Quality
• Flaws in air permits - 100%
• Permits list criteria pollutants & a
few air toxics (benzene NESHAPS).
• No mention of Benzo-a-pyrene or
other PAHs.
• No specific limit for Benzo-a-pyrene
Texas Commission on
Environmental Quality
• Flaws in plant air monitoring- 100%
• No precise monitoring and tracking
of all PM2.5, benzo-a-pyrene, PAHs.
• Flares tend to be poorly monitored.
Technology exists to measure
benzene from flares if required.
Texas Commission on
Environmental Quality
• Flaws in complaint investigations
• Timeliness in responding – critical
to confirm violations. Tardiness!
• Must confirm a violation at your
home, but winds can shift plume.
• TCEQ tends to favor industry.
Texas Commission on
Environmental Quality
• Flaws in enforcement cases.
• Many violations are not counted or
cited in the violation letters. I saw
this in many cases, even now.
• Penalties are negotiated down.
• Too few large plants sued by Tx AG.
First, Do No Harm: Air Pollution