Toxicology/Air Permitting Update

1. Toxicology/Air Permitting Update Michael Honeycutt, Ph.D. Director, Toxicology, Risk Assessment, and Research Division

2. TCEQ Organizational Chart

3. Toxicology, Risk Assessment, and Research Division • 13 Ph.D., 4 M.S. or M.P.H., 2 Librarians, 2 Administrative support • 5 main areas – air monitoring, air permitting, remediation risk assessment, toxicity factor development (chemical risk assessment), research (3/4) • Other – emergency response, expert witnessing (legislative, judicial, administrative), risk communication (legislature, public, management, media), rule development and review, etc. (1/4) • Characterize and communicate human health risk • Provide objective data analysis for policymakers

4. Let’s start off with a few questions… • How do you think the cancer rate in Texas compares with neighboring states? With rest of the United States? • How do you think the cancer rate in Harris County compares with the rest Texas? With the rest of the United States? • How do you think the asthma rate in Texas compares with the rest of the United States?

5. Cancer Incidence

6. Age-Adjusted Cancer Rates and 95%CI, 2011 – 2015 Data All Ages, Sexes, Ethnicities, and Races

7. Cancer Incidence in the United States and Texas, 1999 - 2014 All cancer sites combined Lung and Bronchus Non-Hodgkin Lymphoma Leukemias

8. Adult Self-Reported Lifetime Asthma Prevalence Rate (%) by State < 12.3% 12.3 - < 13.4% 13.4 - < 14.0% 14.0 - < 15.0% 15.0%+

9. Environmental Health • Air quality is an important part of health as air pollution can result in reduced lung function and increases in chronic respiratory disease • Air quality is not the only determinant of respiratory function or disease • Genetics and lifestyle play a major role • Subpopulations of people are more sensitive to air pollution (asthmatics, COPD, emphysema, allergies, young and old)

10. Environmental Health(cont’d) • Health statistics and air quality data indicate the TCEQ is doing its job to protect air quality and public health • How do we evaluate air quality? - Monitoring • Example: Benzene • Emitted in relatively large quantities • Many sources (point, area, mobile) • Risk driver

11. 2018 Average Benzene Concentrations at Air Monitoring Sites in R12, Houston Benzene Long Term AMCV = 1.4 ppb 2018 Benzene Averages 2018 Benzene Averages

12. 2018 Average Benzene Concentrations at Air Monitoring Sites in Texas TCEQ Long Term AMCV = 1.4 ppb 2018 Benzene Averages 2018 Benzene Averages

13. Annual Average Benzene Concentration at R12, Houston, years 2000 and 2018 = TCEQ Long Term AMCV = 1.4 ppb = 2000 Benzene Average = 2018 Benzene Average

14. 1-Hour Benzene Data from Galena Park, 2018

15. Ambient Air Toxics Monitoring Sites – Houston Ship Channel Channelview Jacinto Port HRM#3 Haden Rd Baytown Lynchburg Ferry Galena Park Clinton Pasadena North Manchester/ Central Milby Park Goodyear GC HRM 3 Goodyear Houston Site #2 Houston Deer Park #2 Cesar Chavez

16. Air Quality • Air quality now by almost every metric is better than we’ve monitored in the past (2018 & 2019 not particularly good ozone years) • Despite significant increases in population • Mobile sources • Area sources • Despite significant industrial growth and expansion • Environmental health indicators overall look good

17. Air Monitoring • We do not have stationary air monitors at every facility and we do not monitor for every chemical emitted; however… • We permit the facilities with no off-site monitors in the same manner as those with off-site monitors • We monitor for representative chemicals emitted in high quantities • We conduct inspections and reconnaissance investigations • Consistent and effective air permitting is key to maintaining air quality in the presence of industrial development and population growth

18. Air Permitting is the Foundation • The work you do is extremely important • Issuing and complying with good quality air permits is the key to our current and continued success • TCEQ needs specific information to give applicants maximum flexibility, ensure the monitored air contaminant levels stay below levels of concern, and ensure those environmental health statistics stay “good” • Good quality air permits allow the agency to defend our collective work and we can back our work up with data

19. MERA Flowchart • Modeling and Effects Review Applicability (APDG 5874) https://www.tceq.texas.gov/assets/public/permitting/air/Guidance/NewSourceReview/mera.pdf • Updated March 2018 • No longer always required to request ESL if chemical of interest is not in ESL Database (searched by CAS# or chemical names) https://www.tceq.texas.gov/toxicology/database/tox • Exempt if:

20. TCEQ ESL Database Page

21. Effects Evaluation Procedure • A three-tiered approach is used to evaluate the potential health and welfare effects of emissions on a constituent-by-constituent basis • Tier I: GLCmax and GLCni below the ESLs • Tier II: GLCmax ≤ 2x ESL and GLCni < ESL • Tier III: Case-specific factors

22. Request for Comments • Tier III evaluation - APD permit writers use information from application and modeling report to fill out Request for Comments, sent to Toxicology • Two week turnaround, usually within a week, can be an afternoon if have all the information needed

23. Location of Impacts(Initial Research) • Remember to provide details • Maps and concentration grids help • Do your research ahead of time to prevent delays

24. Concentration Grid

25. Special Conditions • When modeling data indicates possible issues will arise if elements of operation are not controlled, special conditions may be applied to the permit. • Examples • If an odor issue arises, the company must immediately address it. • Hours of operation of a certain point source are limited to N number of hours per year.

26. Request for Comments Form • Time restriction? Rush? • Details regarding physical location (helps with Google Earth queries) • APWL? • If so, is there a net increase in emissions for watch list chemical?

27. Basic Information for a Project • What is the company doing? • Is the facility existing? • If this is a new permit for an existing facility, why? • Will project result in actual emission increase/decrease? • Does the facility operate only during the daytime? • Does modeling exercise include MSS?

28. Emission Calculations and Controls • This is not an area we approve or disapprove, just provides context. • Is the approach conservative? Why? • Are there new, better controls or systems being put in place on an existing facility?

29. Surrounding Land Use…Details • Where is the facility? • What is near it, particularly if receptors are sensitive? • What do we know about zoning? • Do receptors fall on open land? Could the land be developed? • Is there history of complaints (esp. if company is predicting ESL exceedances)? • If there were complaints, what became of the investigation (e.g., NOV)?

30. Modeling Summary

31. Modeling Approach • Is the approach conservative? • How realistic is the modeling (i.e., 24/7 when company actually is 40 h/week)? • Are there restrictions on actual operations (i.e., model shows all devices running at maximal emissions- a condition that is not achievable)? • How many hours per year were MSS modeled? How often do they actually happen?

32. Conservatism in Modeling • Most air dispersion modeling is not accurate. It is an estimate. • Modeling emissions impacts from industrial facilities is intended to be conservative. • Often worst case conditions are what we are actually reviewing. • Be able to communicate why model is conservative. Atmospheric conditions Atmospheric chemical reactions Wet deposition Diffusion Emission Dry deposition Concentration Terrain

33. Examples: Conservatism in Modeling • Model represents 8760 hours of operation, but actual hours of operation are significantly less • Model assumes highest possible emission rates from point sources • Point sources are assumed to be operating simultaneously (an action that cannot occur in reality) • Worst-case meteorological data results in highest impacts occurring in the middle of the night (a time when the facility is not operational) • Looking at concentration grid, highest concentrations rapidly decrease moving away from causal source

34. Location of Maximum Impacts • Direction and distance from property line • If GLCmax on vacant land, could it become a site of public exposure? • If GLCmax to occur on a transient receptor, then also provide non-transient receptor GLCmax • If over water, is it an industrial or recreational waterway? • Is there restricted access?

35. Location of Impacts • Open land: may be considered industrial or non-industrial • Is it possible the land could be developed for non-industrial purposes? • Pay attention to zoning • Non-industrial receptors • Transient vs. non-transient

36. Location of Impacts Example Open Land • Who owns the land? • Is it zoned? • Could it be developed? Who can help? • Regional Office • City

37. Transient Versus Non-Transient Receptors • Transient receptors should not be used as location for chemical-specific maximum ground level concentrations • Locations of transient exposure include: • Roadways • Railways • Airport runways • Right-of-ways • Transient receptors are considered less conservative because they are areas where exposure to impacts would occur for a short period of time • Non-transient are a more conservative way to evaluate impacts due to them being area where sustained exposure could occur

38. Transient Versus Non-Transient Receptors(Example) Transient • Right-of-way • Roadway Non-Transient • Home • Motel • Commercial business • Church • School

39. Mitigation of Impacts • Are there permit conditions to reduce impacts? • How would this impact the interpretation of the modeling results?

40. Impacts Summary • Give CAS number and check accuracy • Use most UTD ESL list on the TD website • If you are unsure about an ESL, contact the TD • If GLC ≥4x ESL, then add 4λMAX and 10λMAX • If unique circumstances, please explain.

41. Common Issues that Slow the Process of Review • Poor characterization of location of highest impacts • Use of places of transient exposure for the GLC receptors • Failure to separate MSS from Routine emissions • Description of conservative assumptions used for modeling: • Hours of operation (8760 vs actual hours) • Emission rates • Simultaneous activities • Time of day when worst impacts happen • Special conditions

42. Routine vs. MSS Emissions • It is important to model routine and MSS emissions separately. • MSS emissions often have higher modeled concentrations but much lower frequencies. • Give us information to help us understand nature of emissions (e.g. tank is only emptied once every five years).

43. Special conditions • When modeling data indicates possible issues will arise if elements of operation are not controlled, special conditions may be applied to the permit. • Examples • If an odor issue arises, the company must immediately address it. • Hours of operation of a certain point source are limited to N number of hours per year.

44. Example – Ethylene Oxide

45. Example - Distillates

46. Cases where flexibility is limited • In general, less flexibility for: • Pungent odorous constituents (styrene, aldehydes, reduced sulfurs) • Strong eye/nose/throat irritants (acrolein, formaldehyde) • Sensitizing chemicals (Isocyanates) • Highly toxic or carcinogenic constituents (benzene, Cr VI) • Constituents with high ambient monitoring levels (APWL) • Constituents excluded from using Step 9C/9D of the MERA Flowchart (Appendix B) • It depends on the circumstances

47. Help Us Help You Call us ahead of time • Jong-Song Lee • Jong-Song.Lee@tceq.Texas.gov • (512)239-1790 • Tiffany Bredfeldt • Tiffany.Bredfeldt@tceq.Texas.gov • (512)239-1799

48. Questions?