Refineries Greatly Underestimating TRI Emissions
From: Robina Suwol
Date: 09 Jul 2004
Remote Name: 188.8.131.52
Review of 10 Toxic Air Emissions Finds "Startlingly" Bad Data
Key Flaw: EPA's Failure to Act and New Steps to Undermine Accuracy of
WASHINGTON, D.C. and HOUSTON, TX.///June 22, 2004///The U.S. Environmental
Protection Agency (EPA) and state governments appear to be underreporting
refinery and chemical plant toxic air emissions - including known carcinogens
benzene and butadiene - on the "startling magnitude" of at least 330
million pounds per year, according to a new study released today by the
Washington, D.C.-based Environmental Integrity Project (EIP) and Galveston
Houston-Association for Smog Prevention (GHASP). The study is being released
ahead of EPA's release of the 2002 Toxic Release Inventory (TRI), expected to
come out this week. The EIP-GHASP analysis finds that the presence of the
carcinogens benzene and butadiene in the air in the United States may be four
to five times higher than the level the EPA reports to the public.
The study, which is based on findings by the Texas Commission on Environmental
Quality (TCEQ), applies the Commission's findings on the underreporting of
certain toxic emissions nationwide and concludes that at least 16 percent of
toxic air emissions from all sources "have been kept 'off the books'."
Additionally, the EIP-GHASP study notes that the EPA for years has knowingly
underreported the air pollution data in its annual TRI data. The study
concludes: ". 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 2004, EPA adopted new rules that
actually weakened air emission reporting requirements . 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 .
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."
Environmental Integrity Project Counsel and Equal Justice Works Fellow Kelly
Haragan said: "The public is being exposed to far more toxic air pollution
than the EPA acknowledges for the record. It is time that EPA and the states
deal with the problem of inaccurate and flawed reporting of toxic releases.
Systematic underreporting happens today because most air pollution is now
estimated - not monitored. To make matters worse, the 'guesswork' is being
done by the polluters who have the incentives to keep the numbers as low as
possible. Refineries and chemical plants report their toxic emissions under an
honor system that is based on calculations that are outdated and inaccurate.
Instead of cleaning up this problem, the EPA has further weakened monitoring
rules and continues to knowingly feed the public inaccurate data regarding
toxic air emissions."
GHASP Director John Wilson said: "We are tired of industry accounting tricks
that always seem to show pollution releases dropping rapidly, while air
quality improvements seem so slow. It is time for EPA and the states to
require real measurements from industry, and take forthright action to protect
the public from chemicals that cause cancer, respiratory, cardiovascular and
Louisiana Bucket Brigade Director Anne Rolfes of New Orleans, LA., said:
"Communities living around chemical plants and refineries have a right to know
what they are breathing. The chemicals released around them are known to be
toxic and cancer-causing. For EPA to knowingly report inaccurate toxic
pollution estimates is shocking."
Eboni Cochran, a member of the Rubbertown Emergency Action (REACT) in
Louisville, KY., said: "When one of the rubber plants shut down in my
community, butadiene levels dropped dramatically. We were surprised that the
so-called experts didn't expect the pollution to drop so much. Maybe they
believed the company's pollution reports. My neighborhood has high levels of
cancer and among the highest rates of asthma in Louisville, so maybe now we
can deal honestly the problems."
KEY STUDY FINDINGS
Entitled "Who's Counting: The Systematic Underreporting of Toxic Air
Emissions," the EIP-GHASP report finds:
· State pollution rankings change dramatically. Applying the Texas formula
nationwide results in states with chemical plants and refineries climbing up
the EPA's list of states with the most air pollution. The following six states
underwent the largest percentage adjustments in the report, in terms of pounds
of adjusted pollution: Texas 159.6 million pounds (155 percent); New Mexico 1
million pounds (100 percent); Louisiana 56 million pounds (74 percent);
Oklahoma 7.1 million pounds (41 percent); Iowa 8.7 million pounds (36
percent); and Illinois 17.5 million pounds (30 percent). The adjusted data
also reveal at least 5 million pounds
of unreported emissions in Kentucky, Mississippi, Pennsylvania and Ohio. Texas
moved from third to first place in the overall TRI rankings, with Louisiana
jumping from ninth place to second. The report notes that further studies are
needed to document the extent of underreporting for chemicals beyond the ten
included in the EIP/GHASP report. Factoring in the underreporting of
additional chemicals would likely further shift the state rankings.
· Major jump in carcinogens seen. The adjusted data show an increase of 432
percent for butadiene (a major carcinogen), 417 percent for ethylene, and 440
percent for propylene. According to polluter data reported to the 2001 TRI,
nearly six million pounds of benzene, another known carcinogen, were released
into the nation's air. The adjusted data show this number to be more than 20
million. Both benzene and butadiene are associated with cancers including
leukemia. All 10 pollutants are also associated with the risk of one or more
non-cancer chronic diseases, especially respiratory and developmental
· Current EPA reporting is deeply flawed and misses a great deal. In 2001, the
US General Accounting Office (GAO) called on EPA to improve its oversight of
emissions reporting from large facilities. The GAO study documented that only
4 percent of all emissions "determinations" were made using direct monitoring
or testing. The other 96 percent were made based on estimates calculated using
emissions factors. Emissions factors were developed by U.S. EPA as a means of
estimating the long-term average emissions for all facilities in a particular
source category. However, these factors often are not accurate for calculating
a particular facility's emissions. EPA acknowledges that its emission factors
are not accurate and yet, earlier this year, adopted a rule limiting the
amount of air monitoring large sources are required to conduct. This change
allows more facilities to rely on EPA's inaccurate emission factors.
To see a full PDF file copy of the report and a related news release go to the
Environmental Integrity Project Web site at
The EIP-GHASP report urges the follow steps by the U.S. Environmental
· EPA should amend its 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 permits under federal law 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 a nd
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. Actual emissions estimates based on
plant-specific data should be used.
The EIP-GHASP report also notes: "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."
Studies by the Texas Commission on Environmental Quality have actually
quantified the extent to which refineries and chemical plants in Texas
underreport certain toxic emissions. The new study reveals that, if Texas'
results are applied nationwide, refineries and chemical plants failed to
report at least 330 million pounds of toxic hydrocarbon emissions, including
known carcinogens like benzene and butadiene. Texas officials limited their
research to certain hydrocarbons believed to play a major role in causing
rapid ozone formation in the Houston area. Of these, 10 hydrocarbons -
ethylene, toluene, hexane, xylene, propylene, styrene,
benzene, cyclohexane, ethylbenzene and butadiene - are chemicals that are
reported to the TRI. In this report, the 2001 TRI levels reported for chemical
plant and refinery emissions of those 10 hydrocarbons are adjusted based on
the methodology developed by Texas. Emissions were adjusted for only chemical
plants and refineries in four Standard Industrial Codes (SICs).
ABOUT THE GROUPS
nonpartisan and nonprofit organization established in March of 2002 to
advocate for more effective enforcement of environmental laws. Schaeffer
directed the U.S. Environmental Protection Agency's Office of Regulatory
Enforcement until 2002, when he resigned after publicly expressing his
frustration with efforts of the Bush Administration to weaken enforcement of
the Clean Air Act and other laws.
The Galveston-Houston Association for Smog Prevention (http://www.ghasp.org
is a community-based environmental organization dedicated to improving the
quality of its region's hazardous air through public education, participation
in the state and federal planning process, and active advocacy in appropriate
Last changed: March 14, 2006