Commentary
Toxics Monitoring for Houston with Air Alliance Houston
Air Alliance Houston is excited to announce an incredible new opportunity for citizens of the City of Houston who have experienced problems with volatile organic compounds emanating from local businesses. In partnership with the City of Houston’s Bureau of Pollution Control and Prevention, Air Alliance Houston now has the ability to take samples of air toxics with a regulatory standard device – a SUMMA air canister.
SUMMA canisters take samples of the ambient air. The samples are then sent to a laboratory where theair is analyzed for the presence and concentration of over sixty different volatile organic compounds. The canisters do not sample well for semi-volatile organic compounds and are also not used for sampling particulate matter or ozone.
If you or someone you know has regularly smelled chemicals which you suspect to come from a local business within the City of Houston, then please contact Matthew Tejada or Cecilia Dykes at Air Alliance Houston (713-528-3779, tejada@airalliancehouston.org, cecilia@airalliancehouston.org) and we will work with you to take a sample of the pollution.
Businesses which would typically have the ability to release pollutants appropriate for SUMMA canister sampling include paint shops, gas stations, dry cleaners, print shops, refineries, chemical and petrochemical facilities and chemical storage facilities.
If you reside within the City of Houston and have experienced exposure to a pollutant that you suspect is a volatile organic compound, please get in touch with us. We are excited about this new opportunity afforded to us through the Bureau of Pollution Control and Prevention and would like to utilize these resources to their fullest potential.
A Note on Dr. Al
As many of you who receive Air Alliance Houston’s email blasts already know, the defense of health, environmental justice and clean air in Houston, in Texas and, really, throughout the entire nation suffered a blow last week. Due to an admittedly poor word choice, Dr. Al Armendariz tendered his resignation as Administrator for EPA’s Region VI.
There are two points that I would like to make concerning Dr. Al’s departure from the EPA.
First, Dr. Al’s time at EPA has, in my opinion, in no way been characterized by the metaphor he deployed while speaking in Dish, Texas in 2010. Dr. Al was foremost a listener at EPA. Rarely have we seen a regulator of his rank so regularly go out of their way to spend time with environmentalists, industry representatives and the communities he sought to serve. His boldest moves while Regional Administrator, such as disapproving the Texas flexible permitting program, did not lead to the destruction of industry in our state.
Instead, Dr. Al aggressively pursued companies to sit down with his staff and find a way to make the regulations work. Though not always done artfully or to the satisfaction of those of us in the environmental community, the region sought a middle path and pushed ahead. While some in industry decried his decisions and deployed their most bombastic rhetoric against his actions, I believe that many others in industry maintained their focus on what is most important to their companies – regulatory certainty. Through the public wars of words that have subsumed Texas environmental policy over the past several years, I believe some of that certainty was starting to be defined. With Dr. Al’s resignation, that progression has now been halted and possibly lost.
Second, I sincerely hope that Dr. Al’s exit from EPA will not be his exit from our world of air quality, environmental justice, public health and policy advancements. His knowledge and passion now coupled with his perspective from the last three years make him an invaluable resource. I would argue that EPA’s Region VI is by far the most difficult in the nation to understand, let alone regulate. That goes the same for the size and complexity of our industry as it does for the number and diversity of our at-risk communities. Dr. Al has held this region in his hands, and I sincerely hope that he finds a way not to let it slip through his fingers.
EPA Implements the “New” 2008 Ozone Standard
The Environmental Protection Agency (EPA) has just announced final designations of areas in the United States that meet or do not meet the 2008 air quality standards for ground-level ozone, known as smog. Ozone is one of the six pollutants considered harmful to public health and the environment for which the federal Clean Air Act requires the EPA to set national air quality standards. With the assistance of a Congressionally created scientific advisory board called the Clean Air Act Scientific Advisory Committee (CASAC), the EPA is also required to re-examine the science every five years and determine whether a standard needs to be revised.
Since first established in 1971, ozone standards have become increasingly more stringent as more scientific information has demonstrated that exposure to ozone, even at low concentrations, has adverse health effects,
including a range of serious respiratory illnesses and increased premature death from heart or lung disease.
Until 2008, the applicable 8-hour ozone standard, promulgated in 1997, was 85 parts per billion (ppb). Under that standard, the Houston-Galveston-Brazoria (HGB) area was classified as “moderate nonattainment” and
required to achieve attainment of the standard no later than June 15, 2010. In 2007, when it became apparent that the HGB area would not meet the standard by that date, Texas requested, and was granted, a voluntary
reclassification of the HGB area from “moderate” to “severe,” with a new attainment date set at no later than June 15, 2019.
Despite the required five-year-review, the Bush administration delayed revising the 1997 ozone standard until 2008. When the standard was finally reviewed and revised in March, 2008, the EPA proposed a standard of 75 ppb, which was less stringent than the 60-70 ppb range that the CASAC had recommended.
Soon after President Obama took office, the EPA withdrew the Bush administration standard and proceeded to promulgate a more stringent one. This action effectively left the outdated 1997 ozone standard in place since states were not required to implement the withdrawn standard. During this process, after being asked by the EPA to analyze the scientific information once more, the CASAC again recommended a standard in the 60-70 ppb range. After considering the relevant science and all comments submitted on that proposal, the EPA determined that an ozone standard of 70 ppb was necessary to protect public health and the environment.
Political, media and litigation firestorms immediately erupted over this proposal, coincidentally contemporaneous with the beginning of the 2012 national election cycle in which President Obama faces a possibly tough race for re-election. Perhaps with these circumstances in mind, and the wide-spread debate over regulatory reform and job creation, last September the President shocked environmentalists, public health advocates and even the EPA by ordering that any new ozone standard must wait until 2013.
As a result, the EPA reinstated the 2008 8-hour ozone standard of 75 ppb and proceeded with implementation of that standard. To determine nonattainment area designations for the 2008 standard, the EPA indicated that it planned to use the recommendations states had previously made in 2009, updated by the most current, certified air quality data. While the EPA did not request states to submit updated designation recommendations, it provided the opportunity to do so. In October, 2011, Texas submitted an updated designation recommendation for the HGB area based on the assessment of 2008-2010 air quality data, recommending that only Brazoria, Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery and Waller Counties, the currently designated HGB nonattainment area, continue to be designated.
After considering the ozone designation recommendations from Texas and other relevant technical information, including 2008-2010 air quality data, the EPA initially announced its intention to modify Texas’s recommended area designations and boundaries for the HGB area by including Matagorda County in the nonattainment area designation. Even though Matagorda County does not have monitors currently showing it in violation of the 2008 ozone standard, the EPA stated that its proposed inclusion into the nonattainment area was due to ozone-producing emissions in, and the wind-driven transport of such emissions from, the County that contribute to a violation of the standard in the nearby HGB area. The TCEQ, industry trade associations, and a number of Matagorda County officials, businesses, industries and other community groups opposed inclusion in the nonattainment designation, asserting that the County has no adverse air pollution effects on the HGB area.
In its May 1, 2012 announcement of final designations of non-attainment areas for the 2008 8-hour ozone standard, the EPA determined that 45 areas across the country are not meeting the 2008 standard based on the
most recent certified air quality data. Almost all of these areas already have programs in place to improve air quality because they did not meet the 1997 ozone standards, and the EPA expects that most areas will be able to meet the 2008 standard as a result of recent and pending regulations.
Despite initially announcing its intention to include Matagorda County in the HGB nonattainment area designation, the final designation did not do so. The currently designated HGB nonattainment area of Brazoria,
Chambers, Fort Bend, Galveston, Harris, Liberty, Montgomery and Waller Counties remained unchanged. Interestingly, the most significant impact of Matagorda County’s inclusion would have likely fallen on the
controversial and highly opposed White Stallion coal/coke-fired power plant proposed to be built near Bay City. As a new major source of ozone-producing emissions, the power plant would have been required to demonstrate that its pollutant emissions will not cause or contribute to increased ozone levels in the HGB area. Given that emissions from White Stallion will increase Matagorda County’s ozone-producing emissions by several factors, it was expected that this required demonstration would have been difficult for White Stallion to make.
As indicated above, in 2007 the HGB area had been granted a voluntary reclassification from “moderate” to “severe” nonattainment based on the 1997 standard, with a new attainment date set at no later than June 15,
2019. In implementing the 2008 standard, the EPA had initially indicated that it was considering classifying areas that had previously requested voluntary reclassification to a higher classification under the 1997 standard
at the same higher classification for the 2008 standard. However, Texas made it clear that it did not agree that the previous voluntary reclassification for the 1997 standard was appropriate for, or applied to, the 2008
standard, and planned to submit a formal request to designate the HGB area as "marginal" for the 2008 standard. The EPA’s May 1 announcement of final designations of non-attainment areas classified the HGB area as “marginal.” Each area that is designated as not meeting the 2008 standards is assigned a classification based on how close they are to meeting the standards. A “marginal” classification means that the HGB area is closest to meeting the standards. Most of the nonattainment areas (36 out of 45) for the 2008 standards are classified as “marginal,” and the EPA expects these areas should be able to meet the standards within three
years, usually as a result of recent and pending federal pollution control measures.
The Clean Air Act requires the EPA to review and, if necessary, revise air quality standards every five years to ensure that they protect public health with an adequate margin of safety. Thus, the EPA will be reviewing the
just-implemented 2008 ozone standard again in 2013.
More information about the 2008 ozone standard attainment designations can be found here.
Flares: Smoking or Non-smoking?
A common sight in heavily industrial East Harris County is the smoke and flames from flares at almost all the refineries and chemical plants along the Houston Ship Channel. Historically, it has been thought that if smoke is visible from a flare, the flare is not doing its job effectively and efficiently. However, a recent comprehensive study done by the Texas Commission on Environmental Quality (TCEQ), with the assistance of The University of Texas at Austin, has found that is not necessarily true.
Industrial flare systems are standard components of refining and petrochemical facilities, and are designed to, and if properly operated will, help reduce the amount of pollution released into the environment by collecting and eliminating unwanted gases in a safe, controlled manner instead of allowing them to vent directly to the atmosphere. Flares are generally considered necessary to the safe operation of these facilities and the safety of plant employees and the communities in which they operate.
Flares are used to burn and destroy waste gases generated over the entire range of plant operating conditions. Some flares operate almost continuously under normal plant operations, and are considered appropriate and acceptable means to control and minimize routine process emissions. These routine-operation flares typically process smaller volumes of waste gas and have smaller visible flames. On the other hand, some flares are authorized to operate under certain non-routine situations, such as power loss to the site, equipment failure, emergency conditions, or plant startup, shutdown, and maintenance activities. These non-routine flares typically operate only occasionally and may have extremely large, visible flames.
New remote sensing technologies have provided regulatory agencies and industry new methods to evaluate flare operations and emissions. Using this advancing technology, the 2010 TCEQ Flare Study revealed that long-standing flare operational standards that meet current regulatory requirements may not provide the level of flare destruction efficiency that has come to be expected under all operating scenarios. For example, the study found that flares sized for emergency flows, but which receive very low routine waste gas flows, may be at risk for lower destruction efficiencies depending on the amount and nature of the gas being routed to the flare. Importantly, even though industry has long been encouraged and has strived to eliminate smoke from flares, the study also found that under some conditions operating a flare near the point at which smoke is present helps maximize flare destruction efficiency. Also, flares with visible flames may be more efficient than flares with invisible flames.
With this new knowledge, both the TCEQ and industry are beginning to evaluate additional monitoring of flare operational parameters, flare minimization plans, flare gas recovery systems and other changes to flare operations to maximize destruction efficiency. The TCEQ is considering changes to its permitting program for flares, and actively pursuing public outreach on flare issues. Current federal regulations regarding smoke from flares provide that a flare cannot have visible emissions, including smoke, for more than five minutes during a two-hour period, and flames not accompanied by smoke are not considered visible emissions. However, given the recent findings, the Environmental Protection Agency (EPA) is considering new regulations that will require flare operators to more closely monitor flare conditions and establish an optimal range of operating conditions to improve flare destruction efficiency.
So, here are some things we now know about flares:
- A visible flame is a good indicator that a flare is effectively and efficiently burning and destroying waste gases, even if the flame occasionally has a small amount of smoke.
- A flare does not always have a visible flame; some flares are used only occasionally and will not have a constant visible flame, and some flares burn waste gases that do not produce visible flames, such as a flare that burns hydrogen.
- Flares operated under non-routine operations or emergency conditions may display extremely large, visible flames.
- In cases where too much steam or air is injected into the flare, the flame may become invisible and also less efficient at burning and destroying waste gases.
- Smoke can form when the flare’s flame does not have enough oxygen to completely burn the waste gases. Smoke can be reduced by injecting more steam or air at the flare tip.
- In some cases, steam can also be visible from flares and may look like white smoke even though it’s not.
- Thus, it is likely in the coming years that communities will see more flares with visible flames and more frequent short episodes of smoke from flares. The Flare Study indicates this should not be considered poor flare operation, but rather efforts to achieve the greatest flare destruction efficiency possible under various operating scenarios.
Further information on flares and the recent Flare Study can be obtained on the TCEQ website. You can also sign up to receive email updates regarding flare issues and the Flare Task Force efforts at the same site.
