My first blog post in April – 12-Step Program for TCEQ to Clean Up Air Pollutant “Hotspots” in Texas – critiqued the state environmental agency for inadequate protection of our health based on its 2009 Air Pollution Watch List report. The report outlined the history of several areas around the state with air pollution levels exceeding – some for more than a decade – the state’s own screening guidelines. Now, signs of improvement may be on the way with new guidance proposing better agency protocols and formal processes to list and delist polluted areas. While long overdue, this guidance is the result of an internal agency effort to prioritize the remediation of these areas and should be commended.
The draft report, Protocol for Notification and Work Group Functions for Evaluating Potential and Active Air Pollutant Watch List (APWL) Areas, outlines the framework that TCEQ plans to follow to remediate APWL areas, such as the formal listing and delisting procedures, and the formation of work groups assigned specifically to address emission sources within APWL areas (aka “hotspots” – see below for more information).
Why is this important? Because it’s the agency’s responsibility to protect our health to a risk level of 1 in 100,000 – a policy guideline adopted by TCEQ commissioners. Currently in APWL areas the risk levels for specific pollutants exceed this health-based guideline, meaning that TCEQ cannot offer a science-based assurance that the risk for adverse health effects from exposure to pollutants in these areas is at the health-protective level adopted by the state.
Even though TCEQ has long been mandated to offer such protection, this proposed protocol marks a formal step toward significantly improving the processes that could help Texas reduce hotspot air toxic risks.
A Citizen Call to Action
Because the proposal is still in draft form, your help is needed to help ensure that better processes become a reality. TCEQ is asking for public comments by Jan. 24, 2011. Simply follow these steps (also listed on the website):
- All comments should reference the APWL protocol and be addressed to Ms. Tara Capobianco;
- Send an email to APWL@tceq.state.tx.us; or
- Send via mail to Texas Commission on Environmental Quality, Office of the Chief Engineer, MC-168, P.O. Box 13087, Austin, Texas 78711-3087.
I’ll have more specific thoughts as we get closer to the comments deadline, but if you’re looking for comment suggestions, here are some ideas that you might want to encourage TCEQ to consider:
- Increase the number of air monitors in hotspots areas. (Monitor coverage in some of these areas can be too sparse, which is a problem in facility-dense areas like the Houston Ship Channel with hundreds of industrial facilities residing in a large area.)
- Include advanced monitoring techniques as part of the remediation process. (Some areas have already been removed from the APWL as a result of TCEQ redoubling efforts to require increased monitoring at facilities.)
- Work more effectively with city and county officials to help identify problems. (Although facilities are required to report emission events to their local authorities, this doesn’t always happen so local officials often remain unaware of emission events.)
- Incorporate emission reduction requirements more effectively into the air permitting process, especially between permit reviews. (Since permit renewals are reviewed only every 10 years, and because of the limited authority TCEQ believes it has in requiring reductions during the permit review process, the opportunity for TCEQ to require additional control measures is infrequent and insufficient to solve pollution problems in these hotspot areas.)
- Increase enforcement actions on facilities located in hotspots with emission events, especially when there are state standards for specific pollutants. (Only about half of the emission events that occur across the state are actually enforced by TCEQ.)
More Information About Hotspots
The APWL report outlines areas around the state where pollution levels for one or more toxic compounds exceed the state’s health-based levels of concern, referred to as “air monitoring comparison values” or AMCVs.
The term “AMCVs” is a collective term referring to all odor-, vegetative-, and health-based values used in reviewing air monitoring data. Similar to ESLs (effects screening levels), AMCVs are chemical-specific air concentrations set to protect human health and welfare.
Do you live in an APWL area? Find out if you live in a pollution hotspot by reviewing the most recent table of Air Pollution Watch List areas. More information on air toxics and AMCVs can also be found on the TCEQ site.