Renewal of Permit for ExxonMobil Chemical Plant in Houston Area Under Review

The ExxonMobil Baytown complex, a major contributor to air pollution in Texas, is under heightened scrutiny as the federal operating permit for its olefins plant is up for renewal. Scheduled for a public notice and comment hearing on February 5, Baytown residents will have an opportunity to express their concerns about air pollution and associated health risks linked to the plant. The purpose of the hearing is to collect formal public comments, which will be considered by the Texas Commission on Environmental Quality (TCEQ) in their decision-making process regarding the permit's approval.

Situated within Exxon's largest petrochemical complex in the United States, the Baytown facility is responsible for the production of olefins, including ethylene, propylene, and butadiene. These olefins serve as crucial components in the manufacturing of various chemical and polymer products, such as plastic, rubber, and polyester. Exxon reports an annual production of approximately 10 billion pounds of petrochemical products from this complex.

The Baytown complex has a checkered history marked by numerous violations, including prolonged fires, significant explosions, and injuries to workers. Over the past decade, the Occupational Safety and Health Administration (OSHA) has fined ExxonMobil's Baytown complex for eight safety violations, with seven classified as serious. Lawsuits in Harris County have reported injuries ranging from exposure to Benzene to electrocutions. Notably, a lawsuit filed by Environment Texas and the Sierra Club found ExxonMobil guilty of emitting over ten million pounds of illegal air pollutants and committing more than 16,000 Clean Air Act violations.

In the fall of 2023, ExxonMobil applied to the TCEQ for the renewal and revision of its Federal Operating Permit for the Baytown Olefins Plant. The permit, if approved, would allow operations to continue for five years from the date of issuance. However, concerns have been raised regarding the deficiencies in Exxon's permit application. Air Alliance Houston, Environment Texas, and the Environmental Integrity Project outlined these concerns in a letter to the TCEQ. The letter points to shortcomings in monitoring methods, compliance certification, and reporting requirements, which could compromise the plant's adherence to environmental regulations if the current draft permit is approved.

One notable deficiency highlighted in the letter is the failure to adjust nitrous oxide (NOx) and volatile organic compound (VOC) limits in the proposal to reflect Harris County's designation as a severe ozone nonattainment area, as required by the State Implementation Plan and Clean Air Act's Nonattainment New Source Review requirements. The draft permit retains outdated limits based on the previous designation. Additionally, the plant-wide applicability limit (PAL) monitoring system in the draft permit fails to meet the minimum requirements established by Texas's federally-approved PAL permit rules, potentially leading to inaccurate emissions calculations during unexpected plant upsets.

The letter urges the TCEQ to demand greater transparency and precision in emission calculations from Exxon and strict adherence to regulatory requirements.

Simultaneously, ExxonMobil is seeking to expand its Baytown facilities by constructing a new ethylene unit, aiming to produce chemicals for plastic packaging and other products. This expansion could result in an increase in greenhouse gas emissions by up to 1.45 million tons per year, adding another layer of environmental impact and regulatory scrutiny to the complex's operations.