Houston-area ExxonMobil chemical plant permit up for renewal

Hearing scheduled to consider public comments

Clean air

Staff | Used by permission
Flaring at ExxonMobil’s Baytown facility in February 2021
Andrea Laureano

Former Campaign Associate, Environment Texas

One of Texas’ largest sources of air pollution, ExxonMobil’s Baytown complex, is facing new scrutiny as the federal operating permit for its olefins plant is up for renewal. On February 5, Baytown residents will have an opportunity to voice their concerns about air pollution and health risks posed by the plant at a public notice and comment hearing. The purpose is to gather formal public comments for the Texas Commission on Environmental Quality to consider when deciding whether to approve the permit.

The facility, one of three in a larger complex described by Exxon as the largest petrochemical complex in the United States, produces olefins (ethylene, propylene and butadiene). Companies use olefins to create a lot of chemical and polymer products such as plastic, rubber and polyester. According to Exxon, the plant manufactures approximately 10 billion pounds of petrochemical products each year. 

The complex has a history of violations, from fires that burned for hours to multiple explosions – one of which was deemed “one of the largest industrial explosions on the Gulf Coast.” Various accidents there have harmed dozens of workers. Over the past 10 years, OSHA has fined ExxonMobil’s Baytown complex for eight safety violations, seven of which were classified as serious. Other injuries reported from lawsuits filed in Harris County against the company range from Benzene exposure to electrocutions. 

When Environment Texas and the Sierra Club filed a lawsuit against ExxonMobil, the court found that the company emitted more than ten million pounds of illegal air pollutants and committed more than 16,000 Clean Air Act violations. 

In the fall of 2023, ExxonMobil applied to the TCEQ for a renewal and revision of its Federal Operating Permit. Pending approval, the permit would allow ExxonMobil to continue operations at the Baytown Olefins Plant for five years from the date of issuance. However, Exxon’s permit application has significant deficiencies, as pointed out in a letter that Air Alliance Houston, Environment Texas, and Environmental Integrity Project wrote to the TCEQ. The letter highlights shortcomings in the draft permit including lapses in monitoring methods, compliance certification, and reporting requirements, which jeopardize the plant’s adherence to environmental regulations if TCEQ approves the current draft permit. 

For example, under the State Implementation Plan and Clean Air Act’s Nonattainment New Source Review requirements, Exxon should adjust the nitrous oxide (NOx) and volatile organic compound (VOC) limits in its proposal to reflect Harris County’s designation as a severe ozone nonattainment area. However, the draft permit does not adjust those limits. Instead, it uses outdated limits based on the previous designation. 

Furthermore, the plant-wide applicability limit (PAL) imposes an annual emission limitation in tons per year and is enforceable for all facilities. In the draft permit, ExxonMobil’s PAL monitoring system does not meet the minimum requirements established by Texas’s federally-approved PAL permit rules. The system fails to accurately determine emissions during plant upsets– unexpected and temporary situations where a facility experiences abnormal conditions that potentially lead to increased emissions. Instead, it relies on estimates of high destruction efficiencies during normal operations, potentially leading to an overestimation of the efficiency of pollution reduction measures.

The TCEQ should require Exxon to be more transparent and precise in emission calculations and strictly adhere to regulatory requirements. 

This permit renewal proposal comes as Exxon is trying to expand its Baytown facilities to build a new ethylene unit, which would produce chemicals used to produce plastic packaging and other products. The expansion would allow ExxonMobil to increase greenhouse gas emissions by up to 1.45 million tons per year

The February 5 hearing will grant the people who live in the shadow of the facility an opportunity to address the environmental and health concerns that have plagued the region. It will take place at Marriott SpringHill Suites Baytown, 5169 I-10 East, Baytown, Texas 77521 on Monday at 06:00 PM. Anyone can attend. The hearing will have a 30-minute registration and informal discussion period, where the public can ask questions about the application and draft permit. Then comes the formal notice and comment hearing, where individuals can present oral statements. Commission staff will be available for questions after the hearing. 


Andrea Laureano

Former Campaign Associate, Environment Texas

Luke Metzger

Executive Director, Environment Texas

As the executive director of Environment Texas, Luke is a leading voice in the state for clean air, clean water, clean energy and open space. Luke has led successful campaigns to win permanent protection for the Christmas Mountains of Big Bend; to compel Exxon, Shell and Chevron Phillips to cut air pollution at three Texas refineries and chemical plants; and to boost funding for water conservation, renewable energy and state parks. The San Antonio Current has called Luke "long one of the most energetic and dedicated defenders of environmental issues in the state." He has been named one of the "Top Lobbyists for Causes" by Capitol Inside, received the President's Award from the Texas Recreation and Parks Society for his work to protect Texas parks, and was chosen for the inaugural class of "Next Generation Fellows" by the Robert S. Strauss Center for International Security and Law at UT Austin. Luke, his wife, son and daughters are working to visit every state park in Texas.

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