Document pBZaV1gMn8b73wZE5yMJ715qE

WHO'S COUNTING? The Systematic Underreporting of Toxic Air Emissions June 2004 A joint study by the Environmental Integrity Project and the Galveston-Houston Association for Smog Prevention Photos courtesy of Kenneth Ford, St. Bernard Citizens for Environmental Quality THE ENVIRONMENTAL INTEGRITY PROJECT (EIP) is a non-profit, non-partisan organization dedicated to more effective enforcement of existing federal and state environmental laws and to the prevention of political interference with those laws. EIP's research and reports shed light on how enforcement and rulemaking affect public health. EIP also works closely with local communities seeking the enforcement of environmental laws. THE GALVESTION-HOUSTON ASSOCIATION FOR SMOG PREVENTION (GHASP) is a communitybased environmental organization dedicated to improving the quality of the Houston-Galveston region's hazardous air through public education, participation in the state and federal planning process, and active advocacy in appropriate venues. Comments and questions regarding this report can be directed to: Kelly Haragan Counsel, Equal Justice Works Fellow Environmental Integrity Project 919 18th St. NW Ste. 975 Washington, DC 20006 (202) 263-4449 kharagan@environmentalintegrity.org John Wilson Executive Director Galveston-Houston Assoc. for Smog Prevention 3015 Richmond, Suite 201 Houston, TX 77098 (713) 528-3779 wilson@ghasp.org II Texas measured ambient quantities of select hydrocarbons in the Houston area and compared ambient quantities to reported emissions of those hydrocarbons. Texas then identified the sources of the emissions and developed "adjustment factors" to account for underreporting. 3 See Appendix D. Texas officials limited their research to certain hydrocarbons believed to play a major role in causing rapid ozone formation in the Houston area. Ten of those hydrocarbons ethylene, toluene, n-hexane, xylene, propylene, styrene, benzene, cyclohexane, ethylbenzene and 1-3 butadiene - are chemicals that are reported to the TRI. In this report, we adjusted the 2001 TRI chemical plant and refinery emissions for those ten hydrocarbons based on the Texas methodology. See Appendix D. Emissions were adjusted for only chemical plants and refineries in four Standard Industrial Codes (SICs). It is likely that industrial sources are also underreporting many other toxic pollutant emissions. Studies similar to Texas', however, have not been conducted for the vast majority of the hundreds of pollutants reported to the TRI. This report, therefore, provides just a glimpse of a much broader problem. See Appendix E. Study Results Applying the Texas methodology to TRI emissions for the ten selected hydrocarbons dramatically increases the amounts of those chemicals known to be in the air. For example, according to company data reported to the 2001 TRI, nearly 6 million pounds of benzene were released into the nation's air. Adjusting the reported benzene emissions based on the Texas methodology shows the actual amount of benzene released to be more than 20 million pounds -- a 248 percent increase. Similarly, butadiene increases by 432 percent, ethylene by 417 percent, and propylene by 440 percent. See Table 1. Table 1: Air Pollution Releases, by Selected Toxic Pollutants (2001) Toxic Pollutant Ethylene Toluene n-Hexane Xylenes Propylene Styrene Benzene Cyclohexane Ethylbenzene 1,3-Butadiene Total Reported Releases 23,918,535 71,539,704 47,644,345 49,749,888 13,924,267 46,466,141 5,894,659 4,309,434 6,547,375 2,145,152 272,139,500 Adjusted Releases 123,641,512 117,462,423 94,415,125 75,269,958 75,216,162 57,932,698 20,530,291 18,112,831 11,893,226 11,419,479 605,893,705 Increase in Emissions 99,722,977 45,922,719 46,770,780 25,520,070 61,291,895 11,466,557 14,635,632 13,803,397 5,345,851 9,274,327 333,754,205 Percentage Increase 417% 64% 98% 51% 440% 25% 248% 320% 82% 432% 123% Source: See Appendix D. 3 Obviously, adjusting the TRI data for only ten pollutants, which are emitted primarily by petrochemical facilities, moves states such as Texas and Louisiana, which contain most of the nation's petrochemical facilities, higher in the TRI state ranking. (County rankings also shift markedly.) Texas moves from number three to number one in terms of overall quantity of air emissions. Louisiana moves from number nine to number two. The adjusted data also indicate at least five million pounds of unreported emissions in Illinois, Iowa, Kentucky, Oklahoma, Mississippi, Pennsylvania and Ohio. See Appendices A and C. Likewise, our analysis results in individual refineries and chemical plants moving up in the TRI facility rankings. As listed in Appendix B, 14 refineries and chemical plants which do not appear on a list of the 50 plants releasing the most air pollution based on industry-reported TRI data, appear on the top 50 list based on adjusted emissions. 4 The changes in the state, county and facility rankings demonstrate the magnitude of the underreported toxic air pollution problem. While sources at refineries and chemical plants, such as flares, cooling towers and leaks, have been identified by several studies as sources of underreported emissions, the fundamental problem with reliance on emission calculations, rather than actual monitoring, is far more widespread and could affect many additional air pollutants reported to the TRI.5 Adjusting just the ten pollutants included in this report shows that 16% of all toxic air emissions have been kept "off the books." If additional chemicals were adjusted, this percentage would likely grow. See Figure 2. Figure 2: Toxic Air Pollution Releases Adjusted 2001 Toxics Release Inventory While numerous studies have made it clear that there is more toxic pollution in the air than is being reported, without sound monitoring and reporting methods, it is not possible to have confidence in any set of air pollution data. The widespread use of inaccurate pollution release estimates means that the public is unknowingly being exposed to far more toxic air pollution than is reported by EPA. Source: See Appendix D. 4 HEALTH EFFECTS OF UNDERREPORTED EMISSIONS The ten pollutants studied by Texas and adjusted in this report are volatile organic compounds (VOCs). VOCs react in the air to form ozone.6 A number of the VOCs are also carcinogenic and otherwise toxic to humans. See Table 3. The actual health impacts of toxic air pollution releases depend on the duration and concentration of exposure. The concentration depends on both the amount of pollution released and local conditions, such as topography and weather. In addition, some of the harmful effects from VOCs are caused by secondary pollutants, such as ozone and formaldehyde, formed after the VOCs are released. Short Term Exposure VOCs react with other chemicals in the air to form ozone. Ozone can cause acute health reactions such as respiratory distress and eye irritation, often almost immediately upon exposure. Ozone reduces breathing capacity, which is especially serious in persons with respiratory disease. Exposure to ozone also increases a person's susceptibility to allergens (such as pollen), respiratory infections and the effects of other air pollutants. Among asthmatics, exposure to ozone is associated with increased emergency room visits, hospital admissions and deaths.7 Acute health effects associated with benzene, styrene and toluene include reproductive, developmental, respiratory, central nervous system and eye problems.8 In addition, VOC emissions can lead to the secondary formation of formaldehyde, a human carcinogen, and similar chemicals, which themselves cause acute health reactions.9 Long Term Exposure Long-term exposure to the ten pollutants covered in this report is associated with serious health effects. Both benzene and 1,3-butadiene are carcinogens associated with cancers including leukemia. Benzene is ranked by EPA as one of two chemicals posing the greatest national cancer risk. Butadiene is listed by EPA as one of the two most significant probable carcinogens contributing to regional cancer risk.10 All ten pollutants are also associated with the risk of one or more non-cancer chronic diseases, especially respiratory and developmental diseases, as described in Table 2. 5 millions of pounds of harmful pollutants to the atmosphere each year, including over 80 million pounds of VOCs and over 15 million pounds of toxic pollutants.13 In 2001, the U.S. General Accounting Office (GAO) called on EPA to improve its oversight of emissions reporting from large facilities. The GAO study documented that only four percent of all emissions "determinations" used direct monitoring or testing. The other 96 percent were based on estimates calculated using emissions factors.14 Emissions factors were developed by EPA as a means of estimating the long-term average emissions for all facilities in a particular source category. These factors do not reflect the variations within a source category due to different processes, controls or operating systems at individual facilities. The factors, therefore, are often not accurate for calculating a particular facility's emissions. EPA itself developed a rating system for the accuracy of its emission factors. As of 1999, EPA had rated seventy-five percent of its emission factors. Twenty-nine percent of the emission factors were rated average or above. Forty-six percent were rated below average or poor.15 Despite this poor rating, these emission factors are still the basis for many facilities' toxic emission estimates. In 2004, the EPA's Office of Inspector General issued its own report regarding the agency's methods for calculating air toxic emissions. That report confirmed that toxic air emissions data submitted by the states is inconsistent and that EPA's emission factors for toxic emissions are not reliable.16 A number of state and local studies have likewise documented the problem of inaccurate air emission reporting. In addition to the Texas studies, the California Bay Area Air Quality Management District (BAAQMD), the University of California at Irvine (UCI), and the Mid-Atlantic Regional Air Management Association (MARAMA) have conducted studies of their own. The BAAQMD studies documented inadequacies in the reporting of emissions from pressure relief devices and from flares at petroleum refineries.17 The UCI study found ambient levels of alkane hydrocarbons in the Southwest to be higher than reported.18 The MARAMA study concluded that VOC pollution in Philadelphia area ambient air is greater than the emissions reported by industry. MARAMA found that emissions from refineries, in particular emissions from flares, cooling towers and non-routine operations, are likely underestimated.19 EPA's Response In spite of this evidence, EPA has failed to improve monitoring and reporting of toxic air pollution. In fact, EPA has moved in the opposite direction and has weakened some federal monitoring requirements. In 2000, EPA proposed regulations that would have standardized the types of toxics data gathered by the states, as well as the methods used to calculate emissions. Despite the fact, however, that seventeen out of the twenty-two state and local 7 governments commenting on the proposed regulations favored toxics reporting requirements, the toxics provisions were dropped from the regulations.20 Likewise, EPA established an Emission Inventory Improvement Program (EIIP), which was designed to develop standard procedures for collecting and reporting emissions data. The EIIP workgroup officials, however, decided to eliminate toxics emissions estimation from their scope of work. The EIIP is no longer active due to lack of funding.21 Recently, the EPA's Emissions Factors and Policy Applications Group (EFPAG) held a workshop to discuss the use of emission factors. Its survey of various stakeholders suggested that: EPA appears to have disinvested from the emissions factors program; Emissions factors are being misused; Emissions factors and the associated information are sometimes difficult to find; and There are many sources with few, old, poor or no emissions factors, as well as many sources with factors of unknown quality. The EFPAG is expected to produce a "decision on options for further development" by April 2005, but does not have any specific goals for requiring improvements to emissions monitoring or reporting.22 Finally, in 2004 EPA adopted new rules that actually weakened air emission reporting requirements.23 Pursuant to Title V of the Clean Air Act, EPA's old rules required that major air pollution sources conduct monitoring sufficient to reveal whether or not the source was complying with federal pollution limits. This provision was used by states and EPA to add monitoring to Title V permits whenever additional monitoring was necessary to track facilities' compliance. In 2004, EPA revised these rules to only require monitoring that occurs more than once every five years. Such infrequent monitoring is clearly inadequate for tracking compliance and means that more sources will be using emission calculations and estimations, rather than actual monitoring, to report emissions. This is obviously a step in the wrong direction. EPA has shirked its responsibility to provide the public with accurate information regarding toxic emissions. Overwhelming evidence indicates that EPA's emission factors are inaccurate for developing emission estimates. Additional real monitoring of air emissions sources is clearly needed. Yet, instead of improving monitoring requirements, EPA appears to be moving in the opposite direction by weakening residual monitoring requirements. Unfortunately, most states have done little to pick up the slack.24 8 RECOMMENDATIONS The primary purpose of the Toxics Release Inventory is to provide members of the public with information regarding toxic releases in their communities. This information is intended to "empower citizens, through information, to hold companies and local governments accountable in terms of how toxic chemicals are managed."25 Instead, because EPA continues to knowingly allow industrial facilities to underreport toxic emissions, the public remains in the dark about the true extent of their exposure. In order to fulfill its mandate to protect public health and the environment and to make the TRI the useful tool it is intended to be, EPA should take the following steps: EPA should amend its Title V regulations to clearly require that all major sources conduct monitoring sufficient to demonstrate whether or not they are in compliance their federal emission limits. EPA should prioritize review of state-issued Title V permits to ensure that adequate monitoring is required. EPA should set a schedule to re-examine its emission factors within two years. Priority should be placed on emissions factors for toxic chemicals and on those that are known to be unreliable. These include flares, fugitives and cooling towers at refineries and chemical plants. EPA should clarify that its emission factors should not be used in the permitting process (for determining permit applicability or emission limits) or for permit fee calculations. Instead, actual emissions estimates based on plant-specific data should be used. Likewise, states should take independent action to ensure that state-issued Title V permits require adequate monitoring, and that emission factors are not the sole basis for emissions estimates used in other circumstances such as fee calculations. Industry and the government have known for years that the calculation methods used to report most emissions are inaccurate. It is time to significantly increase the number of air pollution sources that are actually monitored and to improve emission calculation methods for those that are not. The public deserves to know the true extent of toxic pollution in the air. 9 APPENDIX A: Toxic Air Pollution by State (pounds released in 2001) State Rank by TRI Air Releases Adjustment Facilities Unadjusted Adjusted Unadjusted Adjusted Total Adjusted Total 1,679,373,058 2,013,127,265 333,754,209 (20%) 17,579 817 Texas 3 1 102,748,862 262,349,318 159,600,455 (155%) 1,164 169 Louisiana 9 2 75,960,815 132,039,732 56,078,917 (74%) 303 72 Ohio 1 3 121,295,468 126,526,777 5,231,309 (4%) 1,243 39 North Carolina 2 4 115,130,332 116,514,604 1,384,272 (1%) 625 19 Pennsylvania 5 5 89,034,059 94,684,007 5,649,948 (6%) 960 39 Georgia 4 6 91,834,154 94,289,528 2,455,374 (3%) 537 21 Florida 6 7 83,429,911 86,224,989 2,795,079 (3%) 485 12 Tennessee 7 8 79,573,558 83,868,544 4,294,986 (5%) 516 18 Indiana 8 9 77,828,675 80,763,882 2,935,208 (4%) 823 13 Alabama 10 10 75,567,809 79,601,088 4,033,278 (5%) 428 20 Illinois 12 11 59,411,352 76,969,827 17,558,475 (30%) 984 38 Kentucky 13 12 58,703,794 66,932,976 8,229,183 (14%) 365 21 West Virginia 11 13 59,430,131 62,491,478 3,061,347 (5%) 154 19 Virginia 14 14 57,216,768 59,650,979 2,434,211 (4%) 371 16 Michigan 15 15 56,656,492 59,521,413 2,864,921 (5%) 670 17 South Carolina 16 16 54,977,393 57,815,803 2,838,410 (5%) 414 24 Mississippi 17 17 37,063,726 42,760,494 5,696,768 (15%) 260 11 Maryland 18 18 36,076,213 36,472,618 396,405 (1%) 139 6 Missouri Iowa 19 19 34,177,643 34,474,563 296,921 (1%) 443 13 22 20 24,332,303 33,098,843 8,766,540 (36%) 301 6 New York 20 21 29,629,649 32,061,690 2,432,041 (8%) 534 10 Wisconsin 21 22 25,139,472 25,368,060 228,588 (1%) 659 13 Oklahoma 26 23 17,377,943 24,556,376 7,178,433 (41%) 231 9 California 24 24 20,020,008 23,197,253 3,177,245 (16%) 1,096 48 Arkansas 23 25 20,036,562 22,814,006 2,777,445 (14%) 294 10 Utah 25 26 19,220,667 20,227,815 1,007,148 (5%) 138 7 Kansas 27 27 14,768,804 18,402,787 3,633,983 (25%) 219 6 New Jersey 31 28 13,809,784 17,160,850 3,351,066 (24%) 447 31 Washington 29 29 14,295,076 16,901,772 2,606,696 (18%) 236 7 Puerto Rico 28 30 14,556,276 15,511,015 954,739 (7%) 115 7 Minnesota 30 31 14,252,131 15,436,857 1,184,726 (8%) 334 4 Oregon 32 32 12,914,088 13,272,687 358,598 (3%) 214 5 Nebraska Massachusetts 33 33 7,875,435 7,923,714 48,279 (1%) 136 3 34 34 7,447,906 7,626,692 178,786 (2%) 351 14 Delaware 35 35 6,651,525 7,163,816 512,291 (8%) 59 5 Connecticut 37 36 4,821,957 5,771,210 949,253 (20%) 247 9 North Dakota 41 37 4,328,230 5,620,782 1,292,551 (30%) 34 2 Idaho 36 38 5,000,464 5,446,812 446,348 (9%) 69 1 Montana 42 39 4,292,997 4,988,637 695,640 (16%) 40 4 Maine 38 40 4,657,404 4,657,404 - 85 - New Hampshire 40 41 4,496,284 4,653,904 157,620 (4%) 93 2 Arizona 39 42 4,600,105 4,606,964 6,859 (0%) 205 2 Colorado 43 43 3,629,554 3,916,102 286,548 (8%) 149 5 Alaska 44 44 3,201,013 3,550,343 349,330 (11%) 27 4 Hawaii 46 45 2,379,957 3,073,986 694,029 (29%) 33 2 Nevada Wyoming 45 46 2,728,933 2,755,236 26,304 (1%) 75 47 47 1,817,602 2,350,726 533,124 (29%) 37 1 5 New Mexico 49 48 1,072,357 2,139,926 1,067,569 (100%) 53 3 South Dakota 48 49 1,799,135 1,801,350 2,215 (0%) 52 2 Virgin Islands (US) 50 50 892,660 1,757,536 864,876 (97%) 5 1 Rhode Island 51 51 824,582 974,454 149,872 (18%) 92 2 Guam 52 52 192,898 192,898 - 6- Vermont 53 53 136,536 136,536 - 22 - District of Columbia 54 54 40,733 40,733 - 3- N. Mariana Islands 55 55 7,953 7,953 - 3- American Samoa 56 56 6,920 6,920 - 1- Source: US Environmental Protection Agency, 2001 Toxics Release Inventory. Adjustments calculated by Grassroots Connection. 10 Facility Rank by TRI Unadjusted Adjusted Calumet Lubricants Co. Shreveport Refy., Shreveport (Caddo County, LA) Shell Chemical Co. Deer Park, Deer Park (Harris County, TX) International Paper Co. Savannah Complex, Savannah (Chatham County, Ga) Shell Norco Chemical Plant East Site, Norco (St Charles County, LA) Union Carbide Corp. Texas City Plant, Texas City (Galveston County, TX) Lyondell-Citgo Refining L.P., Houston (Harris County, TX) Chevron Phillips Chemical Co. L.P., Baytown (Harris County, TX) Port Arthur A&O Plant Huntsman Corp., Port Arthur (Jefferson County, TX) Ciba Specialty Chemical Corp., McIntosh (Washington County, AL) Tesoro Petroleum - Mandan Refy., Mandan (Morton County, ND) Chalmette Refining L.L.C., Chalmette (St Bernard County, LA) Phillips 66 Co., Borger (Hutchinson County, TX) Crompton Mfg. Co. Inc., Geismar (Ascension County, LA) Union Carbide Corp. Taft/Star Mfg. Plant, Taft (St Charles County, LA) Baton Rouge Plastics Plant, Baton Rouge (East Baton Rouge County, LA) Lion Oil Co., El Dorado (Union County, AR) 374 84 376 93 118 98 485 99 305 102 468 103 515 105 508 107 356 115 169 116 466 117 464 119 458 1 22 492 1 25 413 1 26 430 127 GE Co., Ottawa (La Salle County, IL) DSM Copolymer Inc., Addis (West Baton Rouge County, LA) ExxonMobil Refining & Supply Baton Rouge Refy., Baton Rouge (East Baton Rouge County, LA) ExxonMobil Refining & Supply Baytown Refy., Baytown (Harris County, TX) BP Prods. N.A. Whiting Business Unit, Whiting (Lake County, IN) Valero Refining Co. Texas, Corpus Christi (Nueces County, TX) Chevron Phillips Chemical Co. Houston Chemical Complex, Pasadena (Harris County, TX) Tesoro Refining & Marketing Co., Anacortes (Skagit County, Wa) BP Amoco Polymers Deer Park Facility, Deer Park (Harris County, TX) Firestone Polymers L.L.C., Orange (Orange County, TX) Deer Park Refining Limited Partnership, Deer Park (Harris County, TX) ADM Corn Processing, Clinton (Clinton County, IA) Premcor Refining Group Inc., Hartford (Madison County, IL) Mobil Chemical Polyethylene Plant, Beaumont (Jefferson County, TX) Bayer Corp., Orange (Orange County, TX) 436 1 29 528 130 255 131 294 133 440 136 505 139 637 157 238 1 61 659 1 64 603 1 68 259 1 69 291 174 656 179 709 183 636 187 Air Releases Unadjusted Adjusted 971,567 3,975,557 968,943 3,715,946 2,557,027 3,589,487 680,609 3,580,461 1,172,001 3,466,909 712,210 3,449,994 624,977 3,361,867 631,247 3,304,435 1,008,255 3,206,380 1,901,355 3,191,056 715,262 3,163,745 717,659 3,107,656 729,601 3,088,127 668,712 2,998,733 861,053 818,559 797,181 605,985 2,997,527 2,991,403 2,930,301 2,926,720 1,338,339 2,916,713 1,206,646 786,182 637,709 2,871,359 2,819,086 2,801,616 491,543 2,626,737 1,439,176 471,822 524,800 1,307,873 1,211,266 473,648 434,883 493,851 2,571,997 2,561,347 2,527,200 2,480,479 2,426,563 2,397,245 2,352,590 2,310,981 Adjustment 3,003,990 (309%) 2,747,003 (284%) 1,032,460 (40%) 2,899,852 (426%) 2,294,908 (196%) 2,737,784 (384%) 2,736,890 (438%) 2,673,188 (423%) 2,198,125 (218%) 1,289,701 (68%) 2,448,483 (342%) 2,389,997 (333%) 2,358,526 (323%) 2,330,021 (348%) 2,136,474 (248%) 2,172,844 (265%) 2,133,120 (268%) 2,320,735 (383%) 1,578,374 (118%) 1,664,713 (138%) 2,032,904 (259%) 2,163,906 (339%) 2,135,194 (434%) 1,132,820 (79%) 2,089,525 (443%) 2,002,400 (382%) 1,172,606 (90%) 1,215,297 (100%) 1,923,597 (406%) 1,917,707 (441%) 1,817,130 (368%) 12 State Vermilion, IL Ottawa, MI Cook, IL Putnam, GA Charles, MD Muhlenberg, KY Ector, TX New Hanover, NC Ashtabula, OH Roane, TN Warrick, IN Clermont, OH Monroe, NY Georgetown, SC Floyd, GA Monongalia, WV Harrison, MS Coshocton, OH Macon, IL York, PA Marshall, KY Chesterfield, VA Lawrence, KY Montour, PA Chatham, GA Richmond, GA Morgan, AL Washington, AL Erie, NY Jackson, AL Putnam, FL Shelby, AL Carroll, KY Jefferson, IN Covington City, VA Osage, OK Richmond City, VA Anderson, TN Wood, WI New Castle, DE Lake, IN Allen, OH Caddo, LA De Soto, LA Polk, FL Elkhart, IN Montgomery, IL Grant, WV Union, AR St Bernard, LA Peoria, IL Vermillion, IN Contra Costa, CA Mc Curtain, OK Hutchinson, TX Kanawha, WV Bay, FL Rutherford, NC Giles, VA Hampton, SC Nassau, FL Saint Louis City, MO Rank by TRI Unadjusted Adjusted 42 59 44 60 45 61 46 62 47 63 48 64 292 65 63 66 53 67 54 68 55 69 56 70 57 71 59 72 58 73 60 74 61 75 62 76 64 77 65 78 109 79 67 80 68 81 70 82 92 83 85 84 76 85 197 86 72 87 73 88 74 89 75 90 80 91 77 92 78 93 414 94 84 95 81 96 82 97 94 98 175 99 103 100 296 101 83 102 88 103 89 104 86 105 87 106 222 107 383 108 90 109 91 110 146 111 96 112 351 113 119 114 128 115 97 116 124 117 98 118 99 119 102 120 Air Releases Unadjusted Adjusted 7,096,175 6,949,589 6,933,450 6,895,014 6,807,092 6,693,748 1,428,825 5,657,803 6,124,302 6,007,597 5,949,656 5,917,880 5,889,546 5,829,443 5,848,395 5,787,451 5,669,347 5,660,919 5,635,070 5,553,426 3,488,949 5,360,281 5,319,518 5,269,259 4,200,274 4,385,137 4,959,043 2,239,695 5,048,981 4,978,618 4,978,581 4,963,608 4,650,116 4,782,544 4,685,811 930,437 4,417,453 4,640,048 4,587,364 4,185,942 2,478,198 3,576,747 1,417,186 4,417,912 4,320,939 4,316,373 4,352,041 4,339,702 1,952,359 1,065,768 4,283,458 4,273,885 2,838,081 4,100,423 1,175,729 3,280,912 3,082,277 3,874,428 3,161,689 3,844,599 3,790,534 3,643,416 7,096,175 7,095,522 7,045,311 6,895,014 6,807,092 6,693,748 6,456,256 6,356,262 6,133,536 6,007,597 5,949,656 5,917,880 5,889,546 5,857,681 5,848,395 5,787,451 5,669,347 5,660,919 5,639,300 5,553,426 5,452,954 5,360,281 5,319,518 5,269,259 5,261,694 5,147,474 5,093,385 5,084,956 5,049,118 4,978,618 4,978,581 4,963,608 4,878,760 4,782,544 4,685,811 4,646,385 4,644,195 4,640,048 4,587,364 4,581,089 4,557,368 4,463,869 4,421,176 4,417,912 4,393,743 4,361,464 4,352,041 4,339,702 4,304,922 4,292,790 4,283,458 4,273,885 4,193,267 4,100,423 3,967,352 3,918,905 3,897,944 3,874,428 3,866,955 3,844,599 3,790,534 3,762,132 Adjustment 145,934 111,862 5,027,431 698,459 9,234 28,238 4,229 1,964,005 1,061,420 762,337 134,342 2,845,261 137 228,644 3,715,948 226,742 395,147 2,079,169 887,122 3,003,990 72,804 45,091 2,352,563 3,227,022 1,355,186 2,791,623 637,993 815,666 705,266 118,716 (0%) (2%) (2%) (0%) (0%) (0%) (352%) (12%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (0%) (56%) (0%) (0%) (0%) (25%) (17%) (3%) (127%) (0%) (0%) (0%) (0%) (5%) (0%) (0%) (399%) (5%) (0%) (0%) (9%) (84%) (25%) (212%) (0%) (2%) (1%) (0%) (0%) (120%) (303%) (0%) (0%) (48%) (0%) (237%) (19%) (26%) (0%) (22%) (0%) (0%) (3%) Facilities Total Adjusted 10 0 31 1 371 7 40 30 40 14 3 15 1 31 1 70 60 12 0 31 0 71 13 0 70 60 12 0 17 1 48 0 16 5 80 10 10 21 2 23 3 21 3 63 59 1 60 90 13 0 62 70 30 32 33 3 80 16 0 34 3 45 4 19 2 14 1 40 37 3 79 1 40 40 16 4 22 18 0 30 41 7 40 62 17 7 12 1 90 41 30 30 77 4 15 State Prince Georges, MD Cobb, GA York, SC Lake, OH Beaver, PA Mason, KY La Salle, IL Erie, PA Morton, ND Chatham, NC Lucas, OH Ingham, MI Hudson, NJ Warren, MS Jefferson, AL Lexington, SC Hamblen, TN Cowlitz, WA Rogers, OK St Charles, MO West Baton Rouge, LA Skagit, WA Dearborn, IN Walker, AL Will, IL St Clair, MI Licking, OH Lee, IA Posey, IN Pleasants, WV Pike, IN Loudon, TN Clay, MO Chautauqua, NY Columbus, NC Floyd, IN Franklin City, VA Coweta, GA Forrest, MS Chesapeake City, VA Merrimack, NH Clearfield, PA St Clair, IL Hardin, TN Lorain, OH Wayne, NC Ouachita, LA Northampton, PA Bay, MI Hancock, KY Plaquemines, LA Decatur, GA Haywood, NC Victoria, TX Buncombe, NC Orange, NY Oakland, MI Daviess, KY Manatee, FL Carter, MO Charleston, SC Middlesex, NJ Rank by TRI Unadjusted Adjusted 100 121 101 1 22 129 1 23 104 1 24 110 1 25 105 126 307 127 107 1 28 199 1 29 108 130 151 131 111 132 112 133 113 134 115 135 167 136 114 137 134 138 116 139 117 140 446 141 233 1 42 120 143 121 144 181 1 45 159 146 122 1 47 123 1 48 170 149 135 150 125 151 126 152 131 153 127 154 130 155 132 156 133 157 136 158 513 159 139 160 137 161 138 162 325 163 140 164 141 165 142 166 147 167 143 168 144 169 145 170 212 171 148 172 149 173 465 174 150 175 152 176 154 177 173 178 153 179 155 180 156 181 240 182 Air Releases Unadjusted Adjusted 3,757,724 3,749,238 3,028,513 3,576,583 3,447,900 3,572,819 1,363,981 3,553,842 2,227,063 3,506,679 2,745,713 3,432,404 3,415,914 3,409,871 3,349,575 2,588,479 3,381,572 2,964,847 3,340,208 3,336,261 860,611 1,833,325 3,278,255 3,258,728 2,424,179 2,665,987 3,235,664 3,168,596 2,498,033 2,964,242 3,118,287 3,093,982 3,016,211 3,084,613 3,019,836 2,990,671 2,979,617 2,958,768 672,794 2,906,918 2,935,137 2,931,978 1,283,572 2,902,027 2,890,994 2,882,593 2,823,697 2,865,745 2,859,900 2,857,019 2,077,872 2,821,609 2,821,063 802,798 2,777,453 2,737,866 2,718,292 2,481,482 2,718,663 2,714,976 2,710,789 1,747,236 3,757,724 3,749,238 3,739,387 3,628,692 3,587,690 3,572,819 3,570,885 3,558,953 3,516,764 3,506,679 3,473,491 3,438,104 3,416,336 3,409,871 3,399,359 3,396,359 3,381,572 3,381,031 3,340,208 3,336,261 3,290,856 3,280,230 3,278,255 3,258,728 3,256,324 3,240,936 3,235,664 3,193,265 3,168,209 3,123,082 3,118,287 3,093,982 3,091,975 3,084,613 3,021,375 2,990,671 2,979,617 2,958,768 2,954,242 2,942,163 2,935,137 2,931,978 2,921,520 2,902,027 2,899,308 2,882,593 2,880,962 2,865,745 2,859,900 2,857,019 2,832,006 2,821,609 2,821,063 2,807,746 2,777,453 2,763,444 2,748,989 2,735,161 2,718,663 2,714,976 2,710,789 2,708,114 Adjustment 710,873 52,109 139,790 2,206,905 5,111 1,289,701 727,778 5,700 422 49,784 807,880 416,184 2,430,245 1,446,905 832,145 574,950 24,670 670,176 158,840 75,764 1,539 2,281,448 35,245 1,637,948 8,314 57,265 754,133 2,004,948 25,578 30,696 253,679 960,878 (0%) (0%) (23%) (1%) (4%) (0%) (162%) (0%) (58%) (0%) (27%) (0%) (0%) (0%) (1%) (31%) (0%) (14%) (0%) (0%) (282%) (79%) (0%) (0%) (34%) (22%) (0%) (1%) (27%) (5%) (0%) (0%) (3%) (0%) (0%) (0%) (0%) (0%) (339%) (1%) (0%) (0%) (128%) (0%) (0%) (0%) (2%) (0%) (0%) (0%) (36%) (0%) (0%) (250%) (0%) (1%) (1%) (10%) (0%) (0%) (0%) (55%) Facilities Total Adjusted 80 16 0 22 4 38 2 26 2 60 15 2 48 1 21 90 46 4 19 1 25 1 80 65 2 15 1 16 0 91 19 0 17 0 14 3 73 50 40 43 8 19 1 28 0 11 1 52 41 50 80 15 1 14 0 71 70 40 60 73 13 1 10 0 80 22 3 20 29 1 90 51 29 0 60 70 72 40 20 52 11 0 22 1 43 1 12 2 16 0 10 17 0 79 7 16 State Rank by TRI Unadjusted Adjusted Salt Lake, UT Chester, PA Hampden, MA Pierce, WA Whatcom, WA Dakota, MN Tyler, WV Chambers, TX Philadelphia, PA Butler, KS Solano, CA Albany, NY Carter, OK Washington, MN Tulsa, OK Independence, AR Tuscaloosa, AL Yellowstone, MT Boyd, KY Kent, MI Saratoga, NY Howard, TX Adams, CO Multnomah, OR Macomb, MI Salem, NJ Stark, OH Matagorda, TX Jefferson, LA Liberty, GA Marshall, IL Fairbanks North Star, Al Guilford, NC Knox, TN Douglas, IL El Paso, TX Warren, PA Davis, UT Rock Island, IL Smith, TX Eddy, NM Niagara, NY Columbia, AR Delaware, OH Laramie, WY Fort Bend, TX Crittenden, AR Live Oak, TX Montgomery, TX Boise, ID San Juan, NM Westmoreland, PA Garvin, OK Mc Kinley, NM Moore, TX Marinette, WI Bayamon, PR Essex, NJ Hancock, WV Kern, CA Worcester, MA Hillsborough, NH 409 303 291 302 462 484 559 734 420 595 453 479 712 499 531 357 516 538 709 388 511 826 460 437 444 426 525 886 448 587 648 470 452 459 716 544 565 643 518 609 1027 541 562 918 629 509 576 1020 550 1126 649 626 1156 1069 970 672 867 743 967 768 798 903 290 302 307 308 312 328 331 332 333 341 353 360 361 363 364 365 375 385 386 393 399 400 421 422 429 430 432 439 444 456 461 462 465 468 478 486 487 497 500 506 511 512 515 531 538 539 545 550 570 584 605 609 615 630 637 644 645 647 669 717 722 737 Air Releases Unadjusted Adjusted 957,054 1,399,327 1,429,679 1,401,953 807,703 754,294 569,824 343,766 922,140 518,751 839,845 765,029 376,032 707,874 621,758 1,143,296 664,849 613,681 380,013 1,053,665 677,149 270,477 823,756 875,779 861,971 913,241 647,973 231,985 854,306 529,896 436,884 790,387 843,011 824,237 369,098 609,177 563,673 440,346 658,982 500,787 158,496 611,487 566,710 207,581 458,552 682,952 544,189 161,550 591,065 117,460 436,841 465,037 107,863 138,591 183,666 407,586 244,077 335,814 184,025 315,008 287,700 217,877 1,599,657 1,533,847 1,485,699 1,484,877 1,468,387 1,383,318 1,374,882 1,371,385 1,370,776 1,335,808 1,276,276 1,243,525 1,243,092 1,236,919 1,232,619 1,232,371 1,184,275 1,160,666 1,157,105 1,132,389 1,113,916 1,108,089 1,055,443 1,051,350 1,016,935 1,016,778 1,014,730 986,844 979,872 924,336 908,160 901,575 893,490 882,484 863,278 836,140 835,775 800,552 785,879 779,807 773,604 763,810 756,862 712,085 688,763 684,168 653,591 638,915 593,261 563,808 532,827 528,026 517,603 495,066 477,711 466,061 465,910 464,398 433,035 389,394 382,507 363,147 Adjustment 642,603 134,520 56,020 82,924 660,684 629,024 805,058 1,027,619 448,636 817,057 436,430 478,496 867,060 529,045 610,862 89,076 519,426 546,985 777,092 78,725 436,767 837,612 231,686 175,571 154,964 103,537 366,757 754,860 125,566 394,440 471,276 111,188 50,479 58,246 494,180 226,963 272,102 360,206 126,897 279,020 615,108 152,323 190,152 504,503 230,211 1,216 109,402 477,365 2,196 446,348 95,986 62,989 409,740 356,475 294,045 58,474 221,833 128,584 249,010 74,386 94,806 145,270 (67%) (10%) (4%) (6%) (82%) (83%) (141%) (299%) (49%) (158%) (52%) (63%) (231%) (75%) (98%) (8%) (78%) (89%) (204%) (7%) (65%) (310%) (28%) (20%) (18%) (11%) (57%) (325%) (15%) (74%) (108%) (14%) (6%) (7%) (134%) (37%) (48%) (82%) (19%) (56%) (388%) (25%) (34%) (243%) (50%) (0%) (20%) (295%) (0%) (380%) (22%) (14%) (380%) (257%) (160%) (14%) (91%) (38%) (135%) (24%) (33%) (67%) Facilities Total Adjusted 48 3 33 1 32 3 32 1 14 2 19 1 21 85 40 5 51 13 1 14 1 51 81 50 2 61 20 2 93 61 67 2 81 21 30 2 53 2 39 1 14 2 44 2 22 20 2 71 31 92 46 3 20 1 61 23 2 12 2 18 3 15 1 12 1 31 35 3 81 71 31 11 2 10 1 11 13 1 11 61 40 1 11 21 51 13 1 10 2 46 4 41 27 4 62 6 34 1 18 State Rank by TRI Air Releases Adjustment Facilities Unadjusted Adjusted Unadjusted Adjusted Total Adjusted Cherokee, SC 1026 758 159,125 337,258 178,133 (112%) 9 1 Kent, DE 901 761 220,262 336,080 115,818 (53%) 11 1 Yabucoa, PR 1038 764 150,565 330,879 180,314 (120%) 2 1 Mayes, OK 914 765 211,779 330,042 118,264 (56%) 9 1 Darke, OH 1005 800 169,830 304,996 135,166 (80%) 7 1 Frederick, VA 1364 807 62,683 300,768 238,085 (380%) 4 1 Warren, VA 1085 808 130,746 300,226 169,480 (130%) 2 1 Kent, RI 1057 816 141,425 290,940 149,515 (106%) 16 1 St Landry, LA 1294 817 77,294 290,463 213,169 (276%) 3 1 Henderson, NC 870 821 242,626 288,226 45,600 (19%) 7 1 San Luis Obispo, CA 1225 823 90,853 286,536 195,683 (215%) 7 2 Miami, OH 942 866 193,635 260,215 66,580 (34%) 16 1 Harney, OR 1460 918 47,165 226,392 179,227 (380%) 1 1 Natrona, WY 1396 931 58,049 213,206 155,157 (267%) 4 1 Webster, LA 1106 932 122,522 213,095 90,573 (74%) 3 1 Cocke, TN 1229 955 90,096 197,712 107,616 (119%) 4 1 Cascade, MT 1498 971 41,925 190,579 148,654 (355%) 1 1 Ionia, MI 1108 980 122,260 186,860 64,600 (53%) 8 1 Wayne, WV 1352 1001 65,867 178,489 112,622 (171%) 3 1 Rhea, TN 1208 1043 95,013 160,476 65,463 (69%) 6 1 Carbon, WY 1325 1097 70,455 134,998 64,543 (92%) 3 1 Hardin, TX 1176 1152 104,081 115,557 11,476 (11%) 4 1 Walker, GA 1439 1182 50,119 105,792 55,673 (111%) 5 1 Liberty, TX 1213 1224 93,934 93,934 (0%) 4 0 Weston, WY 1698 1270 19,334 84,467 65,132 (337%) 2 1 Lafayette, MO 1608 1285 29,035 82,235 53,200 (183%) 2 1 Penuelas, PR 1707 1321 18,602 73,634 55,032 (296%) 4 1 Waller, TX 1645 1652 23,693 23,693 (0%) 3 0 Source: US Environmental Protection Agency, 2001 Toxics Release Inventory. Adjustments calculated by Grassroots Connection. 19 APPENDIX E: Questions & Answers Regarding Study Methodology Is it reasonable to adjust emissions from refineries and chemical plants outside Texas? Studies in various parts of the country have confirmed that hydrocarbon emissions are underreported in other states. While the extent of underreporting may vary, a common problem is that industry reports are based on federal emissions factors that are known to be inaccurate. Until other states conduct studies like those done in Texas to actually quantify underreporting, the Texas data is the best available. Is it reasonable to adjust emissions for plants in such a limited number of industrial classifications? While the lack of emissions monitoring is a problem for many other types of facilities, there are not studies available quantifying the accuracy (or inaccuracy) of emissions inventories for other major sources of air toxics. For example, findings from Europe suggest that large storage tank leaks (particularly older tanks) are a major source of unreported emissions, but similar studies have not been conducted in the US that would allow the findings to be applied to bulk storage facilities. The findings in Texas suggest that a somewhat broader group of industrial facilities may be responsible for unreported hydrocarbon emissions, but these findings have not been validated with field studies. Further studies clearly need to be conducted so that the public can know the true extent of toxic air pollution. Is it reasonable to apply uniform adjustments to individual plants? On-site monitoring would make this report obsolete by providing useful plant-specific data. Unfortunately, the findings from Texas remain quite general. The findings in this report indicate the potential size and nature of a systematic problem with reporting, but cannot be directly translated into accurate emissions estimates for specific facilities. Some plants may use more actual monitoring and, therefore, have fewer problems with underreporting. 22 ENDNOTES 1 The Texas studies include: (1) Estes, Mark, et al, "Analysis of Automated Gas Chromatograph Data from 1996-2001 to Determine VOCs with Largest Ozone Formation Potential" (Texas Commission on Environmental Quality, November 11, 2002); (2) Estes, Mark, et al, "Preliminary Emission Adjustment Factors Using Automated Gas Chromatography Data" (Texas Commission on Environmental Quality, November 5, 2002); (3) Smith, Jim, "HGB Modeling Update" (Texas Commission on Environmental Quality, April 1, 2004) and (4) Texas Commission on Environmental Quality, "Revisions to the State Implementation Plan (SIP) for the Control of Ozone Air Pollution Houston/Galveston/Brazoria Ozone Nonattainment Area" (Draft Appendix D, Tables D.4 and D.26, and Appendix GG, Table 2, May 26, 2004). 2 See notes 12-19. 3 See note 1. 4 The broad-scale, uniform adjustment to reported emissions is the only practical method of illustrating the size of the problem with industry's self-reported data. The errors in reporting are not however uniform across all facilities. In studies examining just four hydrocarbon species (see note 1), Texas environmental officials found that refineries and chemical plants in some areas of the Houston region appeared to be releasing 13-14 times more pollution than they were reporting, while in a few other areas, the emissions reporting error was significantly smaller, on the order of 20-90%. 5 Reports documenting emissions estimation problems with flares, cooling towers and leaks include: (1) Environ International, "Measurement and Assessment of Equipment Leak Fugitives and Vent Emissions in Industrial Ethylene and Other Chemical Sources" (Texas Environmental Research Consortium, June 2003) and (2)Galveston-Houston Association for Smog Prevention, "Smoke in the Water: Air Pollution Hidden in the Water Vapor from Cooling Towers - Agencies Fail to Enforce Against Polluters" (February 2004) . See also reports referenced in notes 17 and 19. 6 The relative contribution to ozone formation among the ten VOCs varies. Ethylene, propylene and butadiene are considered by Texas to be "highly reactive." For example, ethylene has the potential to form ten times more ozone than benzene. 7 Brunekreef, B and Holgate, S T, "Air Pollution and Health," Lancet (Oct 19, 2002). 8 California Environmental Protection Agency, "The Determination of Acute Reference Exposure Levels for Airborne Toxicants," March 1999. 9 See note 8. 10 EPA "National Air Toxics Assessment" at http://www.epa.gov/ttn/atw/nata/risksum.html. See also, California Environmental Protection Agency, "Toxicity Criteria Database - OEHHA Cancer Potency Values" (Office of Environmental Health Hazard Assessment, December 2002). 11 u"OEHHA-CREL" refers to the California EPA, Office of Environmental Health Hazard Assessment. Air Toxics Hot Spots Program Risk Assessment Guidelines, Part III: Technical Support Document "Determination of Noncancer Chronic Reference Exposure Levels," adopted and draft proposed Chronic Reference Exposure Levels (CRELs), http://www.oehha.ca.gov/air/chronic rels/index.html, September 2002. "TRI" refers to the US EPA, Office of Pollution Prevention and Toxics. TRI Risk-Screening Environmental Indicators Version 2.0, Technical Appendix A - Available Toxicity Data for TRI Chemicals of the RSEI User's Manual, http://www.epa.gov/opptintr/rsei/, February 2002. These data were used as compiled by Environmental Defense at www.scorecard.org/chemical-profiles/def/rav edf.html. For endpoints, see Scorecard at http://www.scorecard.org/health-effects/. 23 12 Several studies in Europe have also concluded that emissions are under reported by a large factor. For instance, a 1993 study using aircraft measurements around the Rijnmond (The Netherlands) area suggested that emissions of ethane, propane, n-butane, i-butane, n-pentane, i-pentane, 1,1,1trichloroethene, tetrachloromethane, tetrachloroethene were under reported by industrial sources. The study cited earlier work in support of its findings, going back as early as 1988. Michiel Roemer, "Aircraft Measurements around the Rijnmond Area" (TNO Institute of Environmental Sciences, Delft, The Netherlands, January 1993). 13 U.S. House of Representatives, Minority Staff, Special Investigations Division, Committee on Government Reform, "Oil Refineries Fail to Report Millions of Pounds of Harmful Emissions" (Prepared for Rep. Henry A. Waxman, November 10, 1999). 14 United States General Accounting Office, "Air Pollution: EPA Should Improve Oversight of Emissions Reporting by Large Facilities (GAO-01-46, April 2001). 15 See note 14. 16 United States Environmental Protection Agency, Office of Inspector General, "EPA's Method for Calculating Air Toxics Emissions for Reporting Results Needs Improvement" (Report No. 2004-P-00012, March 31,2004). 17 Bay Area Air Quality Management District, "Technical Assessment Document: Further Study Measure 8, Flares" (Draft Revision 2, December 2002), "Technical Assessment Document: Further Study Measure 8, Pressure Relief Devices" (Draft Revision 2, December 2002), and "Proposed Regulation 12, Rule 11: Flare Monitoring at Petroleum Refineries" (Draft Staff Report, March 2003). 18 Katzenstein, Doezema, Simpson, Blake and Rowland, "Extensive Regional Atmospheric Hydrocarbon Pollution in the Southwestern United States" (August 2003). 19 Mid-Atlantic Regional Air Management Association, "Evaluating Petroleum Industry VOC Emissions in Delaware, New Jersey and Southeastern Pennsylvania" (October 2003). 20 See note 16. 21 See note 16. 22 Driscoll, Tom, "Emissions Factors Program Fact Finding Survey" (US Environmental Protection Agency, Emissions Factors and Policy Applications Group (EFPAG), June 2004). 23 69 Fed. Reg. 3201 (Jan. 22, 2004). 24 Most states have not acted to improve monitoring or reporting of toxic air pollution. Texas has adopted regulations requiring increased monitoring of cooling towers for leaks and better monitoring of the gases sent to flares, but only for equipment related to ethylene, propylene, butadiene and butenes. In addition, for the past two years, the Texas Commission on Environmental Quality has used a "top-down" emissions inventory for certain hydrocarbons rather than the unadjusted data submitted by industry. The California Bay Area Air Quality Management District has adopted a rule requiring better monitoring of flares and is considering rules adopting control requirements for flares. Bay Area Air Quality Management District, "Proposed Regulation 12, Rule 11: Flare Monitoring at Petroleum Refineries" (Draft Staff Report, March 2003). 25 US Environmental Protection Agency website (www.epa.gov/tri/whatis.htm). 24