ENGINEERING ETHICS AND UNDER-REPORTED VOCS

By Alex Cuclis

(Cuclis has been a research scientist at the Houston Advanced Research Center since 2004. Prior to that, he spent two years performing air quality studies with the University of Houston and 13 years at Shell’s Deer Park Complex. He has degrees in chemical engineering (UT-Austin) and analytical chemistry (UI-Urbana). He was a Peace Corps Volunteer in Cameroon.)

Many universities require that their engineering students take Engineering Ethics. One of the scenarios in the textbook used at Texas A&M goes something like this:

“Mary discovers that her plant is discharging a substance into the (air) that is not regulated by the government… As an engineer, she believes she has an obligation to protect the public, but she also wants to be a loyal employee. The substance will probably be very expensive to remove, and her boss advises, ‘Forget about it until the government makes us do something. Then all the other plants will have to spend money too, and we will not be at a competitive disadvantage.’ What should Mary do?” (adapted from Engineering Ethics by Harris, Richard, and Rabins, 1999).

Data from Texas air quality field studies in 2000 and 2006 indicate that the concentration of many volatile organic compounds have dropped by 40 percent from 2000 to 2006, but levels of VOCs are still ten to fifty times higher than reported by the petrochemical facilities in the Houston Ship Channel. (Rapid Science Synthesis Report, August 2007).

However, the reported inventories for nitrogen oxides (NOx) are very similar to the amounts measured by aircraft that have taken samples of the atmosphere in the same areas.

The problem is not limited to Texas or the US. Similar VOC emission inventory discrepancies have been found at refineries in Europe that have employed complex analytical techniques such as Differential Absorption Light Detection and Ranging (DIAL) or Solar Occultation Flux (SOF). Most of the 30 studies performed in the past 20 years show that the European refiners are emitting more than 10 times the VOCs that they report.

Investigations by TCEQ indicate that the Ship Channel facilities are, for the most part, properly employing EPA approved emissions estimating techniques for VOCs. In Europe, the refineries are using standard, environmental agency approved estimating techniques similar to those used in the US.

Considering that the engineers are doing what they are told to do, how they are told to do it, is it really possible that engineers have been this far off for more than 20 years when estimating emissions? How legitimate is the data behind this assertion? If emissions are really that far off, what should be done about it? If the VOC inventory is incorrect, does that mean that the inventories for air toxics and greenhouse gases are incorrect as well? And if “Mary” has an idea about why the emissions are not correct, what should she do?

Some people believe that the way emissions are estimated need to be changed, but others question the data behind the assertion that there are discrepancies between the reported and actual levels of VOCs.

The 2006 air quality field measurement platforms included a variety of ground-based sites. The Houston area has more monitors than any other metropolitan area in the US. This very extensive monitoring program is designed to track emissions from various sources. The system can track trends; however single point monitors on the ground cannot measure the total amount of material or even tell which direction it comes from. One cannot get an accurate emissions inventory from the ground level monitors due to three problems:

1. Many of the pollutants react prior to reaching the monitors,
2. There are concerns about how to convert a measured amount at a point into an emission rate, and
3. Because of Houston’s frequent shifts in wind direction it is difficult to identify the main source of the emissions.

The DIAL and SOF analytical techniques used in Europe and now in Canada and the US can identify and quantify emission rates from various parts a plant (tanks, process area, cokers, flares, cooling water towers, etc.), however the plants that employ these techniques almost always require confidentiality agreements that prevent sharing the knowledge gained on a large scale. Also, since the vendors of these techniques reside in Europe, it is very expensive to perform these studies in the US.

If you are interested in more information and some lively discussion about these topics, join the Houston chapter of Engineers Without Borders in one of its seminars on Engineering Ethics. One seminar will be February 26, from 6 to 8:30 pm, at Upper Kirby Conference Room, 3015 Richmond. The second will be February 27, from 3 to 5 pm, at the HGAC Building, 3555 Timmons, Second Floor, Room A. Each seminar will have the same speakers. Alex Cuclis will discuss the VOC emissions under-reporting issues and Professor Lisa Gossett from the University of Houston-Clear Lake will discuss professional licensing and certification issues. The cost is $30 ($20 for EWB members). If interested, please RSVP to Alex at acuclis@harc.edu, indicating the date you intend to attend, by February 22. The seminar is a benefit for Engineers Without Borders projects to help poor communities in India, El Salvador and Bolivia.

Also, Mothers for Clean Air and GHASP monthly Clean Air Exchange meeting will feature Paulette Wolfson, city of Houston attorney, to discuss the city’s authority to conduct environmental inspections and require registration of emissions. The talk will be Thursday, February 21, at 7 pm at St. Andrew’s Presbyterian Church, 5308 Buffalo Speedway. For more information contact (713) 526-0110 or mfca@mothersforcleanair.org.

Correction: I included a note about Mothers for Clean Air and GHASP’s Clean Air Exchange meeting at the end of Alex Cuclis’ article on engineering ethics without making it clear that the meeting notice was not a part of his article. He is not associated with those groups and I added the notice without consulting him. I apologize.  Ella Tyler, editor