State Smog Plans Needs to be Stronger
Brandt MannchenThe Houston Sierra Club (HSC) urges you to contact the
Texas Commission on Environmental Quality (TCEQ) and demand stronger Houston smog plans.
TCEQ has proposed two State Implementation Plans (SIPs) for the Houston-Galveston-Brazoria
Non-attainment Area for the 8-Hour, health-based, Ozone (smog) standard.
The TCEQ prepared two weak SIPs that will not meet the ozone standard by the mandated
2010 deadline. TCEQ wants to extend the deadline to meet the ozone standard until 2018!
Contact TCEQ by February 12, 2007. State that you are responding to Rule Project
Numbers 2006-038-115-EN; 2006-027-SIP-NR; and 2006-030- SIP-NR. Tell TCEQ to:
1) Withdraw the 8-hour and Reasonable Further Progress (RFP) Ozone SIPs because they
will not meet the ozone standard by the mandated clean-up deadlines.
2) Not seek a "bump up" which will extend the smog clean-up deadline to 2018.
3) End the TCEQ policy of incrementalism/minimalism and adopt as many CM as necessary
to meet the ozone standard including: California vehicle emission standards; increase the
reduction of nitrogen oxides (NOx) from large industrial sources from 80% to 95%; increase
the reduction of volatile organic compounds (VOC) from large industrial sources by 95% or
more.
4) Make all SIP air pollution regulations/rules apply statewide.
5) Hire, properly train, and fund additional investigators for TCEQ/local air pollution
agencies.
6) Strengthen the VOC storage tank/degassing regulations/rules by:
a. Require installation of CM for storage tanks with VOC of 0.5 psia or greater
b. Control storage tank/degassing VOC from all storage tanks 10,000 gallons or larger
c. Require at least 95% control efficiency for VOC storage tank CM
d. Control VOC flash emissions from all storage tanks 10,000 gallons or larger
e. Require venting to a control device for degassing storage tanks until a 10,000 ppm
concentration is reached
f. Require the installation of all storage tank CM by January 1, 2009 and not January
1, 2017
Contact TCEQ at: Ms. Joyce Spencer, MC 205, TCEQ, P.O. Box 13087, Austin, Texas
78711-3087; or
Fax: 512-239-4808; or
Email: http://www.5.tceq.state.tx.us.rules/ecomments
For more information contact Brandt Mannchen at 713-664-5962 or brandtshnfbt@juno.com.
February 2007 |