Not all air pollution is an accident. Many of the large air pollution events in Houston that we track are the result of “upsets” that are essentially unforeseen events or accidents at a facility. A tank leaks, a valve fails to close, something is spilled. For example, the recent event at Shell Deer Park was due to a faulty valve.
But some air pollution events are planned–and even scheduled and announced beforehand–by companies. These events are known as Startup, Shutdown, and Maintenance (sometimes “Malfunction”) events. These so-called SSM events have been the subject of much legal wrangling over the years.
For example, in the recently released Refinery Rule, EPA finally closed a loophole that left SSM emissions from oil and gas “off the books” in many situations. By ending this practice, EPA is able to hold refineries accountable for all of the toxic air pollution they produce, regardless of its cause or foreseeability.
In Texas, there has been a point of contention for many years between the EPA and the Texas Commission on Environmental Quality about whether and how SSM events are permitted. EPA has long-maintained that routine or foreseeable SSM events must be authorized by permit. All companies in Texas are now required to include these SSM emissions in their TCEQ-issued permits.
Recently, the LyondellBasell Bayport Polymers facility in Pasadena, Texas reported on a planned maintenance events that would last for thirty-nine days, through November 26th. During this event, LyondellBasell plans to release the following amounts of air pollution:
- Propylene (Propene) 26000.0 lbs
- Propane 3000.0 lbs
- Nitrous Oxides 5000.0 lbs
- Ethylene (gaseous) 4000.0 lbs
- Carbon Monoxide 24100.0 lbs
- Propylene (Propene) 1300.0 lbs
- Propane 2000.0 lbs
- Nitrous Oxides 1000.0 lbs
- Ethylene (gaseous) 250.0 lbs
- Carbon Monoxide 5100.0 lbs
Information about this event can be found on the TCEQ’s Air Emissions Event Reporting Database. You’ll notice that the report explicitly states that these emissions are not authorized by permit. This means that the LyondellBasell Bayport Polymers facility has not authorized its SSM emissions as the EPA requires.
This planned maintenance event is just one example of the kinds of pollution events that happen every day in Houston. Although it can be daunting or even impossible for an individual to follow all of these events and information, that is what Air Alliance Houston is here for.
Environment Texas, based in Austin, is a strong partner of Air Alliance Houston in our efforts to track these events across the region and state. Environment Texas is creating tools for citizens who would like to do the same. I’ve seen some of what they are working on and it is exciting stuff. (Think houstoncleanairnetwork.com for pollution events.)
Together, we will be looking into this event and the issue of unauthorized SSM emissions at this facility. Thank you to Environment Texas for joining us in the fight against air pollution–planned and unplanned–in Houston.