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Texas Environmental Almanac, Chapter 6, Air Quality, Page 7

MAJOR STATIONARY SOURCES

In 1993, 100 facilities in Texas emitted more than 18,000 tons of particulate matter, 924,000 tons of sulfur dioxide, 746,000 tons of nitrogen oxides, 169,000 tons of VOCs, and 455,000 tons of carbon monoxide into the atmosphere.(109) Together, these 100 facilities produced more criteria pollutants than the total produced by the remaining 5,900 facilities reporting to the state's "Emissions Inventory."(110) In 1990, the major industries in Texas also released more air toxics than any other state. By 1992, Louisiana had the highest amount of total toxic releases, but Texas had the highest amount of toxic air releases, totaling 157.5 million pounds of some 300 chemicals.(111) However, between 1987 and 1993, total releases of air toxics in Texas declined by 40 percent, from 236.8 to 141.9 million pounds.(112)

For these reasons - the emission of criteria air pollutants and toxics - these industrial facilities, which the Federal Clean Air Act calls "major stationary sources," are often the focus of state and citizen efforts to reduce air pollution. In fact, major industry bears the administrative burden of obtaining permits and, particularly in the non-attainment areas, must reduce emissions significantly. This section takes a look at three categories of major-stationary-source air pollution: manufacturing, combustion and mechanical facilities.

EMISSIONS INVENTORY - TOP 20 EMITTERS OF CRITERIA POLLUTANTS IN 1993 (IN TONS)
RANKCOMPANIESZIPCOUNTYPM10SO2NOXVOCCOTOTAL
1Texas Utilities Electric Company75201Titus71.487,006.725,704.6294.53,495.2116,572.4
2Texas Utilities Mining Company75201Rusk17.278,520.532,268.5449.23,847.3115,102.7
3Houston Lighting & Power Company77251Fort Bend501.061,352.333,226.4333.23,802.799,215.6
4Texas Utilities Generating Company75201Freestone0.075,270.817,387.7182.01,567.194,407.6
5Aluminum Company of America76567Milam10.067,566.217,365.51,353.17,868.694,163.4
6Phillips 66 Company Div. of Phillips79008Hutchinson0.014,065.04,835.15,461.254,924.879,286.1
7Cabot Corporation79066Gray83.7489.41,890.3519.563,232.466,215.3
8Southwestern Public Service Company79170Lamb0.030,577.130,838.0710.81,234.563,360.4
9Sid Richardson Carbon and Gasoline76102Howard0.01,412.6123.92,771.055,819.260,126.7
10JM Huber Corporation77521Harris94.92,848.3103.81,408.354,689.259,144.5
11Houston Lighting and Power Company77251Limestone360.922,275.024,603.8249.61,988.749,478.0
12Asarco Incorporated79999El Paso1,099.447,340.7632.94.533.449,110.9
13Southwestern Electric Power Company71156Titus305.827,571.716,618.4169.41,441.246,106.5
14Lower Colorado River Authority78767Fayette1,335.625,414.016,043.0185.11,573.044,550.7
15Texas Utilities Generating Company75201Milam2,071.328,411.38,904.6131.51,129.540,648.2
16Southwestern Public Service Company79170Potter0.023,170.214,791.0136.01,166.139,263.3
17Southwestern Electric Power Company71156Harrison638.816,946.420,240.3102.6868.038,796.1
18Chevron U.S.A., Inc.77641Jefferson0.015,500.213,639.05,804.51,502.936,446.6
19Mobil Oil Corporation77704Jefferson99.514,625.08,678.06,599.42,971.832,973.7
20Witco Corporation77242Moore0.0309.20.01,690.530,022.932,022.6
Source: Texas Air Control Board, 1993 Emissions Inventory

WHO MUST SUBMIT AN EMISSIONS INVENTORY?
STATEWIDE:
Any Stationary Source Emitting

  1. 100 Tons/year or more of VOC, NOX, CO, SO2 or PM10

  2. 10 tons/year of any individual Hazardous Air Pollutant (HAP) or 25 tons/year of any combination of Hazardous Air Pollutants
OZONE NON-ATTAINMENT AREAS:
Any Stationary Source Emitting

  1. 10 tons/year or greater of VOC

  2. 25 tons/year or greater of NOX

  3. 100 tons/year or greater of CO, SO2 or PM10

  4. 10 tons/year of any individual Hazardous Air Pollutant (HAP) or 25 tons/year of any combination of Hazardous Air Pollutants
Source: Texas Air Control Board, Rule 101.10

*

WHO MUST OBTAIN A PERMIT IN TEXAS?
One way the state of Texas regulates air emissions is through a permitting process. Under the Texas Clean Air Act of 1971, most new or expanding industries that will emit air contaminants must obtain a permit from the Texas Natural Resource Conservation Commission before any construction is begun. Such permits require that the facility install "best available control technology." Some facilities are exempt from the pre-construction permit requirement if they meet conditions set out in the state's "standard exemption" list, which covers small businesses like dry cleaners, auto body shops and paint shops.

As of April 1994, Texas had issued 20,928 state permits in both attainment and non-attainment areas. Some 14,000 are still active.(114) This construction permitting process is divided into non-attainment review for sources located in non-attainment areas and prevention of significant deterioration (PSD) review in attainment areas. Permits in non-attainment areas are generally more stringent. It is important to note that air pollution sources which were operating before 1972 and have not expanded are not required to have a state permit; these are known as "grandfathered" facilities.

The 1990 Federal Clean Air Act created a new category of permits: operating permits. These permits are required of all major stationary sources which emit air pollutants. The purpose of federal operating permits is to codify all applicable requirements at a site and provide an enforcement and compliance tool. For example, a petroleum refinery operation may have 100 to 200 different rules, regulations, permits and variances governing the operation of their facility. A Title V permit would codify them all. Thus, construction permits would be incorporated into an operating permit. The TNRCC projects that there will be 8,100 federal operating permits issued at some 3,000 sites in Texas during the five years after the Texas program receives EPA approval.

MANUFACTURING INDUSTRIES

Texas' major industries are concentrated along the Gulf Coast and in major metropolitan areas like Dallas-Fort Worth, El Paso, Midland-Odessa, San Antonio and Austin. The amount and type of pollution varies widely by region. For example, Corpus Christi's major industries - oil and gas refineries, pipelines, and chemical companies - contribute an estimated 41 percent of total volatile organic compounds and 62 percent of nitrogen oxides emitted in the Corpus Christi area every day. In Austin, major industries - mainly electronics manufacturers - only contribute 1 percent of the area's total VOC emissions and 14 percent of nitrogen oxides emissions.(115) Not surprisingly, much of the concern over industrial air pollution has been along the Gulf Coast.

Toxic air emissions from these industries are a major concern of citizen groups around the state. Federal law requires manufacturing industries with more than nine employees to submit data on releases of more than 300 toxic chemicals and 20 chemical compounds. Harris, Jefferson and Galveston counties are among the top ten emitters of toxics per year in the country.(116)

Many of these toxics have been linked to both cancer and birth defects. In 1992, the chemicals known to cause, or suspected of causing birth defects - categorized as either developmental toxins or heritable mutagens by the EPA - which were released into the environment in the greatest amount included toluene, xylene, methyl ketone and trichloroethylene. Most of these releases were through the air.

There are, at present, no state or federal regulations specifying acceptable ambient concentrations for air toxics, as there are for the criteria pollutants. For example, only one of the top 15 toxic chemicals released in Texas, benzene, has been the subject of a national air quality standard. By comparison, five of these 15 toxic chemicals have maximum contaminent level standards established under the Safe Drinking Water Act.(117) However, the air permitting requirement that new permitted facilities use best available control technology (BACT) limits toxic emissions considerably. Also, the 1990 Clean Air Act will impose new standards on industries identified as sources of 189 major toxic compounds. In addition, the TNRCC has developed a system to evaluate concentrations of more than 1,500 chemicals, including the top 15 toxic chemicals, emitted by permitted facilities. Guideline concentrations called ESLs, previously described, are used to evaluate not only proposed emissions but also ambient air monitoring data.

Toxic air emissions reported to both the state's Emissions Inventory as well as under the Toxics Release Inventory Program do not include "upset" emissions. Defined as accidental, unplanned air pollution releases, thousands of upsets a year contribute pollutants to the state's atmosphere. Under state regulations, companies are required to report their upsets to the TNRCC. But the information in these reports is sketchy: a 1992 Sierra Club survey of upset emissions in nine Texas counties revealed that companies do not always report or even know in some cases how much or what type of chemical was emitted.(118) According to this study, of 8,857 upset reports in 1991, 80 percent did not list the quantity of compound released, and 38 percent did not report the type of chemical released.(119) Such accidents and failure or inability to report accurate upset emissions make it extremely difficult to assess the full impact of industrial toxic emissions on public health. In addition, because the state does not set levels or limits on upset emissions - by definition they are unplanned events - the data these reports do contain are not used to help set emission limits.

NUMBER OF PERMIT APPLICATIONS, APPLICATION AND ANNUAL COMPLIANCE PLANS, MONITORING PLANS EXPECTED IN TEXAS UNDER FIRST FIVE YEARS OF FEDERAL CLEAN AIR ACT FEDERAL OPERATING PERMITS (TITLE V).
1ST2ND3RD4TH5THTOTAL
Permit Applications4004002700230023008100
Compliance Plans1001006765765762028
Monitoring Quarterly Reports3,00011,00036,25087,250133,250 270,750
Other Monitoring Reports5,00025,00060,250138,250207,250 435,750
Annual Certifications03007002,8255,2259,050
Source: Texas Natural Resource Conservation Commission, System Requirements for the FCAA Integrated Management System, 35 -36.

TOXIC AIR RELEASES BY COUNTY, 1993
COUNTYTOTAL AIR RELEASES (LBS)
Harris42,526,385
Jefferson15,826,112
Brazoria12,316,711
Orange7,513,958
Galveston7,003,946
Nueces5,579,511
Harrison5,033,620
Dallas4,010,444
Ector2,910,291
Tarrant2,844,219
Calhoun2,788,182
Cass2,278,300
Hutchinson1,964,974
Wichita1,514,479
Gray1,408,824
Jasper1,317,875
Matagorda1,257,556
Howard1,239,274
Moore1,163,482
Brown1,085,845
Source: Toxics Release Inventory Program, Office of Pollution Prevention and Recycling, Texas Natural Resource Conservation Commission.

TOXIC AIR RELEASES BY INDUSTRY, 1993
Total Air Releases by Two-Digit SIC Codes
INDUSTRYTOTAL RELEASES (LBS)% OF TOTAL RELEASES
Food and Kindred Products1,284,6331%
Tobacco Products50,795
Textile Mill Products22,601
Apparel and Other Finished Products204,2153%
Lumber and Wood Products, Except Furniture1,385,0521%
Furniture and Fixtures383,483
Paper and Allied Products6,799,4615%
Printing, Publishing 597,114
Chemicals and Allied Products77,521,42755%
Petroleum Refining and Related Industries27,379,07719%
Rubber and Miscellaneous Plastics Products6,208,1834%
Leather and Leather Products297,493
Stone, Clay, Glass, and Concrete Products1,535,3831%
Primary Metal Industry3,435,4702%
Fabricated Metal Products4,492,0063%
Industrial and Commercial Machinery, including Computers925,6231%
Electronic and Other Electrical Equipment and Components, Except Computer Equipment1,513,2931%
Transportation Equipment4,640,9263%
Other1,532,0021%
Total141,869,302100%
Source: Toxics Release Inventory Program, Office of Pollution Prevention and Recycling, Texas Natural Resource Conservation Commission

TOP 10 TEXAS FACILITIES RANKED BY TOTAL AIR RELEASES, 1993 AND 1992.
FACILITY NAMECITYCOUNTYTOTAL AIR RELEASES (LBS)
19931992
1. Dow ChemicalFreeportBrazoria6,521,5478,268,917
2. Texas Eastman DivisionLongviewHarrison4,568,4634,360,004
3. Mobil Oil, Beaumont RefineryBeaumontJefferson4,286,3934,836,898
4. Shell Oil CompanyPasadenaHarris3,821,8864,470,687
5. Hoechst-Celanese ChemicalPasadenaHarris3,747,8333,143,860
6. Union Carbide Corp.Texas CityGalveston3,542,4154,170,148
7. Quantum Chemical CompanyLa PorteHarris3,470,0843,131,348
8. Exxon Chemical AmericasBaytownHarris2,509,0872,591,847
9. Union Carbide Corp.Port LavacaCalhoun2,481,1892,065,317
10. Chevron USA Prods.Port ArthurJefferson2,429,2442,924,159
Cumulative Total26.35%
Source: Toxics Release Inventory Program, Office of Pollution Prevention and Recycling, Texas Natural Resource Conservation Commission.

LEADING CHEMICALS LINKED TO BIRTH DEFECTS RELEASED IN AIR BY INDUSTRIES IN TEXAS , 1993
CHEMICALRANKTOTAL ONSITE RELEASES (LBS)TOTAL AIR RELEASES (LBS)
Toluene99,425,9929,168,513
Xylene (Mixed Isomers)126,416,9016,137,337
Acetonitrile136,136,390329,717
Methyl Ehtyl Ketone146,097,5425,785,956
Benzene154,515,8804,160,980
Styrene164,392,2064,125,208
1,1,1 Trichloroethane213,160,8813,160,632
Phenol222,873,954479,069
Acrylonitrile232,689,531162,740
1,3- Butadiene262,190,1772,186,182
Chloromethane301,856,6021,856,521
Chloroform311,788,5971,775,842
Cyanide Compounds321,629,50698,595
Ethylbenzene351,602,3031,317,493
Carbon Disulfide40901,587901,332
Napthalene41897,405812,827
Hydrogen Flouride43859,308849, 135
M-Xylene46720,050719,734
P-Xylene48695,710695,612
Trichloroethylene50662,701662,680
Source: List of chemicals found to be "developmental toxics" from Clement Associates, Inc., Support Documentation for the SARA TITLE III, Sections 313/322 Toxicity Matrix (Fairfax, Virginia: Clement Associates, Inc., August, 1988, prepared for Environmental Protection Agency). Pounds from Toxics Release Inventory Program, Office of Pollution Prevention and Recycling, Texas Natural Resource Conservation Commission.

COMBUSTION

A second category of major stationary sources is made up of facilities that burn material for energy, waste disposal or both. Utilities, waste incinerators, industrial boilers and cement kiln facilities are the major examples. Because these facilities burn materials at very high temperatures, they emit chemicals and gases that sometimes result in dangerous chemical reactions. For example, sulfur dioxide is one of the principal compounds emitted from electric utilities. When hot, a small portion of sulfur dioxide emissions can combine with oxygen to form sulfates, which in turn can combine with water particles to form sulfuric acid. This acid falls to the earth as acid rain.(120) Sulfur dioxide and nitrogen oxides, both of which contribute to the formation of acid rain, and carbon dioxide, a greenhouse gas, are the major pollutants resulting from combustion. Heavy metals are also emitted by some combustion facilities. Coal-burning facilities can emit mercury and cadmium. Cement kilns and incinerators for hazardous waste and municipal waste can all emit chromium, manganese and lead.

Texas has 27 major electric utilities operating 312 generating stations.(121) About half of the state's electricity is derived from coal, about 40 percent comes from natural gas, and the remainder comes from hydroelectric power, nuclear power and renewable energy sources.(122) Electric utilities that use coal as their combustible material pump millions more tons of carbon dioxide, sulfur dioxide and nitrogen oxides into the atmosphere than do those using natural gas or a combination of petroleum and natural gas.

In 1990, the generation of electric power produced 35 percent of all the carbon dioxide and 66 percent of all the sulfur dioxide emitted in the state.(123) In fact, the four facilities in Texas which released the largest volume of criteria pollutants are all coal-fired electric power plants.(124) Emissions from power plants contribute to the formation of smog and acid rain.

Under the 1990 Federal Clean Air Act, in order to combat acid rain formation, sulfur dioxide emissions must be reduced by 10 million tons below 1980 levels and nitrogen oxide emissions must be cut by 2 million tons by the year 2000. In a first phase, the nation's largest 110 utilities (none of them located in Texas) must achieve the greatest share of sulfur dioxide reduction by the end of 1995. In a second phase, all other major utilities, including those in Texas, must reduce sulfur dioxide emissions. The Clean Air Act also caps the amount of sulfur dioxide utilities can emit in 2000, and places controls on nitrogen oxide emissions as well. Major utilities in Texas will soon be required to continuously monitor and report their emissions and, like major industries, will also be required to obtain a federal operating permit.

Waste incinerators are another source of combustion-generated air pollutants. Both municipalities and industries sometimes incinerate a variety of waste as a means to reduce their volume and to generate energy. Public opposition to such facilities expressed at permit hearings has raised awareness about the air pollution that can result from these facilities, particularly hazardous waste incinerators, which burn waste that are defined as hazardous because they are toxic, flammable, corrosive and/or reactive. There are currently 32 permitted hazardous waste incinerators in Texas. Harris County, with 13 facilities, has more hazardous waste facili-ties than any other county in the United States. Jefferson County, with five, is among the top ten.(125) These facilities are operated by large corporations, chiefly to dispose of their own waste. Three of the facilities presently operating in Texas are commercial waste incinerators, accepting liquid waste from both in-state and out-of-state generators.

Cement plants are combustion facilities on a smaller scale. Some burn hazardous waste to fire their kilns. In 1991, citizen groups in Midlothian, near Dallas, expressed concerns about health effects from the burning of hazardous waste in cement kilns and the dumping of cement-kiln ash in quarries. Two of the three cement kiln plants in the Midlothian area were burning waste-derived fuels.(126) A third had previously burned tires to generate energy and was seeking a permit to continue burning them. Responding to citizen concerns, the Texas Air Control Board monitored community air for particulate matter, metals, sulfur compounds, air toxics and other compounds. Monitors were located downwind of the major facilities in the area. Tests conducted over a two-year period indicated that no adverse health effects are expected to result from exposure to the monitored levels.(127)

SULFUR DIOXIDE, NITROGEN OXIDE AND CARBON DIOXIDE EMISSIONS BY COAL, NATURAL GAS AND PETROLEUM POWERED ELECTRIC UTILITIES, 1991 (MILLIONS OF POUNDS)
SULFUR DIOXIDENITROGEN OXIDESCARBON DIOXIDE
Coal 6961122231,440
Petroleum & Gas00384
Natural Gas0460118,920
Other (hydro, nuclear)000
Total6961,582350,744
Source: Energy Information Agency, Electric Power Annual (Washington, DC: Department of Energy, February 1993).

PERMITTED HAZARDOUS WASTE INCINERATION FACILITIES IN TEXAS
FACILITYLOCATIONSTATUS
American Envirotech**HoustonNot Built
Atochem North AmericaBeaumontActive
Atochem North AmericaHoustonActive
BASF Corp.FreeportActive
BP ChemicalsPort LavacaClosed
Chemical Waste Management**Port ArthurActive
Dow Chemical La PorteActive
Dow Chemical FreeportActive
EI DuPont La PorteActive
EI DuPont*OrangeActive
EI DuPont BeaumontActive
Celanese Engineering ResinsBishopClosed
Hoechst Celanese PasadenaActive
Celanese ChemicalSeabrookActive
Houston Chemical Services**PasadenaBuilt, not operating
Nalco Chemical Sugar LandActive
Occidental Chemical* Deer ParkActive
Occidental Chemical GregoryActive
Parkans InternationalHoustonActive
Phillips PetroleumOld OceanUnder construction
Quantum USIDeer ParkActive
Rhone Poulenc** HoustonActive
Rollins Environmental** Deer ParkActive
Sandoz AgroBeaumontActive
Shell Chemical.Deer ParkActive
Sterling ChemicalTexas CityActive
Huntsman CorpConroeActive
Huntsman CorpPort NechesActive
Texas Eastman LongviewActive
Texas InstrumentsShermanNot Built
3. Union Carbide* Texas CityActive
U.T. Southwestern Medical CenterDallasInactive
*Accepts waste from other facilities owned by same company.
**Commercial
Source: Industrial and Hazardous Waste Division, Office of Waste Management, Texas Natural Resource Conservation Commission.

MECHANICAL

Industries that rely on mechanical processes include: metal smelters, grain elevators, foundries, steel manufacturers, wood processors, cotton gins, asphalt batching operations, concrete and cement batching operations, paper mills, sand blasting operations and oil and gas rigs. These industries are another major category of stationary sources that can pollute the air. Cotton gins, for example, may lead to heavy emissions of particulate matter. In 1990, air sampled around a cotton gin in the Lower Rio Grande Valley showed respirable particulate matter was being emitted in high levels, although not in violation of standards applicable to agricultural sources.(128) Lead smelters are of particular concern to citizens living near them and to environ- mental groups. As an air pollutant, lead is emitted in particles so small that 50 percent might remain in the lungs if breathed by humans.(129) However, tests conducted by the Texas Air Control Board in response to citizen complaints found that levels of lead in the ambient air near the smelters were below national air quality standards.(130) Any lead smelters built after 1987 must be at least 3,000 feet from the nearest residence.(131)

Texas Environmental Almanac, Chapter 6, Air Quality, Page 7
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