Flint Hills Ingleside

One of three high-volume oil export terminals located on the Live Oak Peninsula next to Ingleside on the Bay, Flint Hills Resources bought part of the former Ingleside Navy Base in 2012. Flint Hills Terminal is currently out of compliance with the Clean Air Act and subject to an EPA enforcement action. Recent video taken by EarthWorks shows invisible emissions emanating from its tanks. Yet, they're getting permission from TCEQ to pollute even more!

HELP US STOP FLINT HILLS OIL EXPORT TERMINAL FROM POLLUTING EVEN MORE!

Using OGI thermography, this EarthWorks video shows leaking from the top of one of the Flint Hills tanks.

Viewing a Flint Hills tank using high contrasting black and white imagery from the EarthWorks FLIR camera reveals emissions invisible to the naked eye.

PUBLIC MEETING 7/14: Flint Hills Ingleside Air Quality Permit Amendment #6606

Background

Public Meeting on Flint Hills TCEQ amended air quality permit #6606
Thursday July 14th at 7pm
Portland Community Center
2000 Billy G. Webb, Portland, TX

See potential talking points below, but feel free to craft your own. If you cannot attend the meeting in person, please join our fight to stop harmful emissions by writing your own comments directly to TCEQ HERE. Alternatively, submit this QUICK FORM.

Documents

Application to increase pollution
Draft Permitted Emissions: MAERT (Maximum Allowable Emissions Rate Table)
Draft Permit Special Conditions
Submit Comments Online for Air Quality Permit "6606" (due 7/14 at end of public meeting)
Review Submitted Comments for TCEQ ID# "6606" (include all Filings and Correspondence)
Review data and records for Flint Hills Ingleside, "RN 100222744".

Possible Talking Points in Your Comments

Always feel free to ask your own questions or make your own points. But here are 6 different types of comments for challenging a TCEQ draft air permit: Deny Permit, Facility, TCEQ, Permitted Pollution (MAERT), Permitted Special Conditions, and Proposed New Conditions.

#1: Request that the permit be denied: 

As a resident/member of (list your city and/or any organizations you belong to), I request that TCEQ deny this permit for Flint Hills to increase hazardous air pollutants, carbon monoxide, hydrogen sulfide, nitrogen oxides, organic compounds, and particulate matter.

#2: Point out concerns about the facility, based on complaints, investigations, and EPA status:

Flint Hills Resources Ingleside is currently in "high priority violation" status with regard to the Clean Air Act, according to the EPA ECHO database. This situation needs to be remedied before additional emissions can be considered.
Optical Gas Imagery (OGI) video of Flint Hills, taken by EarthWorks in December 2021 (see https://youtu.be/E7V4bAtzyCw and https://youtu.be/DK9l_WF2m7Y) and shared with TCEQ, shows significant plumes arising from improperly maintained storage tanks. TCEQ has not yet scheduled our requested meeting to discuss the results of the investigations launched as a result of these complaints.
Additional EarthWorks OGI footage of two other nearby oil export terminals, Enbridge and Buckeye, also shows significant emissions. These videos were shared with TCEQ as well. The cumulative impacts of all three terminals on the Ingleside on the Bay, Ingleside, and the Corpus Christi Bay airshed have not been properly investigated, measured, or monitored.
Flint Hills is a serial violator; In 2021, the Environmental Integrity Project reported that their facility on Refinery Row was one of 13 refineries in the U.S. that released cancer causing Benzene above EPA Action Levels in 2020. They must be held accountable and reign in their emissions at all facilities.

#3: Express concerns about TCEQ's approach to protecting (or not) the Coastal Bend and the planet:

TCEQ has NO air monitoring stations in San Patricio County, where a huge amount of industrial development and expansion is occurring - as evidenced by the significant number of TCEQ operating, air quality, and even water quality permits in the County. Local communities are forced to conduct and fund their own air monitoring to protect themselves from air polluters like Flint Hills.
The cities of Ingleside and Ingleside on the Bay are particularly at risk of the cumulative amount of emissions from three oil export terminals located on the Live Oak Peninsula. Yet there are no TCEQ air monitors nearby. As a result, Ingleside on the Bay Coastal Watch Association has cobbled together a community air monitoring program, without any formal training and limited access to monitoring equipment and the ability to calibrate. Companies like Flint Hills, in partnership with other industries in the same airshed, should be more proactive in working with local communities to set up fenceline monitoring, provide calibration stations, and work with communities to establish/support their own air monitoring programs that make sense, given prevailing winds, geography, etc.
Increasing pollution levels is not only harmful for neighboring Ingleside on the Bay and the Corpus Christi Bay airshed, but also the planet. The 2022 IPCC Climate Change Report makes it clear that we must drastically reduce greenhouse gas emissions in order to avoid catastropic global warming. Given the dire warnings for our planet contained in this significant report, how can TCEQ justify issuing ANY permits allowing increased emissions that contribute to global warming? What steps are Flint Hills and TCEQ taking to mitigate climate change?

#4 Question the Amount of Emissions proposed to be increased:

According to the MAERT, the combined annual MVCU emission limits for nitrous oxides (NOx), sulfur dioxide (SO2), and VOCs seem quite high. Please tell me how public health will be protected? Why is this increase necessary? How do these levels compare with emissions from Enbridge and Buckeye, the two marine terminals adjacent to Flint Hills?

#5: Question the proposed Special Conditions on the Draft Permit:

Condition #9D states: "During loading, the owner or operator of the marine terminal or of the marine vessel shall conduct audio, olfactory, and visual checks for leaks once every 8 hours for on-shore equipment and on board the ship." This seems to be a very unsatisfactory and unscientific way to identify leaks, and checking every 8 hours is not frequent enough. Ship emissions during loading are one of the most noticeable impacts to nearby communities like Ingleside on the Bay. As soon as audio, olfactory, or visual signs of leaks are identified, loading operations should immediately cease.
Condition #10 states that "complying test results [for VOC collection efficiency] shall be obtained in accordance with the [TCEQ-approved] protocol for a minimum of one inerted ocean-going marine vessel per year for 3 years". Please provide a copy of the protocol. Because of the proximity to a residential community, the frequency of VOC collection efficiency testing does not sound sufficient. How can we access the testing records for ships? What happens when VOC collection efficiency drops below 99.9% for a vessel? Is it removed from operating until it passes?
In Condition 12, is leak testing once in a 12-month period sufficient?

#6: Propose NEW Special Conditions (this is where we are most likely to effect positive change):

Include funding to support third party air quality monitoring by local university personnel, such as Texas A&M University Corpus Christi's Physical and Environmental Science Department - perhaps as part of a broader internship opportunity, supported by industry.
Provide training and funding for a community air monitoring person. This could be granted through an area nonprofit organization, like Ingleside on the Bay Coastal Watch Association.
Implement a community communication, notification, and emergency response strategy to include regular data sharing and reporting, as well as alerts, developed in cooperation with the City of Ingleside on the Bay, City of Ingleside, and Ingleside on the Bay Coastal Watch Association.
Require that ships run on shore power when docked.
Include cumulative impact reporting from operations at all marine terminals located on the Live Oak Peninsula, including, but not limited to, Enbridge, Flint Hills, and South Texas Gateway Terminal.
Include Flint Hills' commitment to reduce its emissions to net zero.
Anything else that would protect communities, environment, wildlife, and human health. The Polluter should Pay!

Southern tip of Live Oak Peninsula occupied by the City of Ingleside on the Bay (left) and three prolific oil export terminals: MODA, Flint Hills, and Buckeye (right).