Last week, EDF, along with Air Alliance Houston (AAH), submitted comments to the Texas Commission for Environmental Quality (TCEQ) reflecting why we believe the proposed removal of Texas City for the pollutants benzene and hydrogen sulfide from the state’s Air Pollution Watch List (APWL) is premature.
The APWL is a list of areas in Texas where concentrations of harmful pollutants exceed the state’s own health-based screening level guidelines. While inclusion on the list indicates that additional scrutiny is given to permits issued to facilities in the area, some of the APWL areas have been listed for over a decade. This is significant because exposure to these toxics may impact human health and may lead to serious health outcomes, such as birth defects or cancer.
EDF has been actively engaged with TCEQ to improve management of the APWL program and to renew efforts to improve air quality in hotspot areas. TCEQ first added Texas City to the Air Pollutant Watch List in 2001 because of elevated concentrations of propionaldehyde. The organization added benzene in 2003 because the annual average concentration at the Ball Park Monitor exceeded the long-term health-based Air Monitoring Comparison Value (AMCV) of 1.0 ppb. Hydrogen sulfide was then added in 2004 based on mobile and stationary monitoring data showing exceedances of the 0.08 parts per million (ppm) threshold.
TCEQ’s proposal claims that recent air monitoring information justifies the removal of Texas City from the APWL. However, new analyses completed by EDF and AAH, indicate that data from the current monitoring network are not adequate in justifying the removal of Texas City from the APWL. Here are a few reasons why:
- Air monitoring information has not been correlated with wind direction, meaning that the existing monitoring network does not capture the predominant downwind concentrations of pollutants in neighborhoods closest to the largest sources. As illustrated in the insert, the largest concentration of benzene is expected in between the existing monitors.
- BP Texas City: The largest emitter in the area is also the worst environmental performer. BP Texas City is ranked as the largest benzene emitter in the region, not just the state. On March 23, 2005, an explosion killed 15 employees and injured 170 as a result of workers re-starting a unit at the BP refinery that had been closed for repairs. The problem started when workers filled a tank with 138 feet of flammable liquid, when it should have been filled with only 6.5 feet of liquid. Upon further investigation, it was discovered that BP had cut costs, resulting in risky working conditions, which were likely the cause of the catastrophic event. An investigation by the Chemical Safety Board found numerous problems, including out-of-date equipment, corroded pipes, and faulty safety alarms. This explosion has been characterized as one of the worst workplace incident in the U.S. between 1989 and 2005.
- BP Texas City II: More recently in November 2011, there were reports of gas leaks at the BP Texas City refinery. A concerned citizen initially reported a sulfur dioxide leak to the National Response Center. BP confirmed an ongoing leak of methyl mercaptan; the odor was so toxic that 30 workers from a neighboring plant downwind were taken to the hospital.
Bottom line: It is too early to remove Texas City from the APWL for benzene or hydrogen sulfide. While we appreciate the efforts that the state has made in working to improve air quality in the Texas City region, there is strong evidence that residents in Texas City continue to be at higher risk for health impacts from pollutants such as benzene.
We therefore recommend that the agency place additional monitoring equipment in the areas expected to have the highest concentration of pollutants. Only properly sited monitors with validated data can justify a delisting. Without proper data collection and analysis, the TCEQ cannot ensure that it is maintaining the Air Pollutant Watch List in a manner that protects public health.
 The long-term AMCV for benzene has since been made less health protective, with a revised AMCV of 1.4 ppb.