Comments submitted to TCEQ regarding Pasadena Refining permit
We, Environment Texas, on behalf of our members in Harris County and Dr. Julie P. Katkin, Dr. Harold J. Farber, Dr. Ernestina Melicoff and Dr. Erin J. McDade, urge the TCEQ to deny the Title V permit and to delay the issuance of any additional permits to Pasadena Refinery System, Inc. until the facility is able to come into compliance with existing permits and reduce dangerous emission events that threaten public health and the environment.
Environment Texas is a citizen-based environmental organization with individual members who live and work close to the Pasadena Refining System facility. Environment Texas’ members breathe, and are exposed in other ways, to more harmful pollutants than they otherwise would be, as a direct result of the facilities excess air emissions that violate existing permit requirements and endanger the community.
Dr. Julie P. Katkin is a Medical Doctor based in in Houston, Texas with a specialty in Pulmonary Medicine.
Dr. Harold J. Farber is a Medical Doctor who specializes in Pediatric Pulmonology in Houston, Texas.
Dr. Ernestina Melicoff is a Medical Doctor who specializes in Pediatric Pulmonology in Houston, Texas.
Dr. Erin J. McDade is Doctor of Pharmacy specializing in Pediatric Pulmonology in Houston, Texas.
The PRSI facility frequently emits dangerous pollutants that serve as a significant public health threat to members of the Pasadena community, as well as other communities in the greater Houston region. These dangers include an increased risk of cancer, birth defects and conditions like chronic asthma.  In the United States, it is estimated that approximately 200,000 people die annually as a result of dangerous emissions from industrial facilities.  These emissions contain a toxic and uncontainable cocktail of carcinogens, neurotoxins, benzene, hydrogen cyanide, and lead. And based on estimates in the American Lung Association's 2015 State of the Air report, the Houston–The Woodlands–Sugar Land metropolitan area, which Pasadena is a part of, has a population of 6,508,323. Of that population, the following groups are considered by the American Lung Association to be at increased risk from exposure to air pollutants: 1,760,785 children, of whom 159,534 suffer from asthma; 631,535 adults over the age of 65; 344,952 adults with asthma; 250,336 people with COPD; and 343,681 people with cardiovascular disease.
If a refinery like PRSI does not comply with the regulations that are in place by state and federal regulators, the risk of suffering health consequences dramatically increases for the above noted vulnerable members of the community, as well as the Greater Houston region.
The Pasadena Refinery System is an old refinery with a clear history of dangerous emissions and has proven itself incapable of complying with the regulations that are in place. In 2014 alone, PRSI received 7 outstanding violations from the TCEQ for air quality violations, according to a report from the Texas Commission on Environmental Quality Investigation Report conducted on January 21, 2014. Prior to this, PSRI was fined $757,143 in 2010 for 10 air quality violations.  These violations are only a fraction of the violations that PRSI has encountered over the years, which includes 12 quarters of Clean Air Act violations, 4 quarters of Clean Water Act violations, and 12 quarters of Resource Conservation and Recovery Act violations through the Environmental Protection Agency. 
In addition to this, PRSI has consistently reported “upsets” of emissions over a few hours that have exceeded the annual limit. From 2003 to 2014, PRSI surpassed the 75th percentile every year for the release of particulate matter (PM), with some years having multiple reported “upsets” of emissions.  In terms of health, there is a direct link between the size of a particle and health problems. PM poses the greatest threat because of its size and can get deep inside the lungs and even the bloodstream. Every time PRSI fails to comply with emission regulations and allows these “upsets,” they are also allowing an increased risk of premature death, irregular heartbeat, aggravated asthma, and decreased lung function.
In addition to PM, the PRSI facility frequently emits pollutants that are known to cause a variety of problems: for example, some are carcinogenic, some cause and aggravate respiratory and other illnesses, and some contribute to the formation of ground-level ozone, a major constituent of smog.
Finally, Pasadena Refinery System let their Title V permit expire before they were reminded by TCEQ to re-apply for this, new, permit. Up until now, PRSI has proven how poorly run of a refinery it is, which acts not just as a threat to the facility’s employees but also as a threat to the surrounding community. Before PRSI is issued a new Title V permit, the facility must be held accountable to clear and enforceable permits and better monitoring to ensure the refinery is complying with the existing regulations.
Thank you for the opportunity to submit public comment regarding Draft Title V Permit Authorizing Operation of Pasadena Refinery System, Inc. (PRSI).
Sara E. Smith, JD
 The America Lung Association, 2015 State of the Air Report http://www.stateoftheair.org/2015/states/texas/harris.html
 Pasadena HL&P Monitor, STEERS-SSM Report 2003-2014