Estimated Distribution of Benzene Annual Concentration, Based on Retrieved Primary Source Location and Wind Direction Frequency
One year ago this week, EDF, along with Air Alliance Houston (AAH), submitted comments to the Texas Commission on Environmental Quality (TCEQ) regarding its proposal to remove Texas City from the state’s Air Pollutant Watch List (APWL). We believe the agency’s proposal to remove Texas City from the Watch List for benzene and hydrogen sulfide, two lethal air pollutants, was premature.
To date, the TCEQ has not addressed our public comments on the Texas City proposal, though it has found time to analyze and recommend two other areas for removal from the APWL. We believe that this reflects TCEQ’s misplaced priorities. The agency seems to prefer removing areas from the APWL — thereby lifting a burden on industry— rather than ensuring adequate protection for public health.
What is the APWL?
The APWL is a list of areas in Texas where concentrations of harmful pollutants exceed the state’s own health-based guidelines. Inclusion on the list subjects facilities in the area to additional permitting and monitoring analysis. The goal is to reduce air pollution and protect public health, but some 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 and AAH have 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. In 2003, the agency added benzene after annual average benzene concentrations exceeded the long-term, health-based benchmark that TCEQ uses to protect human health and welfare. Later in 2004, hydrogen sulfide was added after data demonstrated that hydrogen sulfide levels exceeded the health-based threshold for the pollutant.
Why should Texas City remain on the APWL?
TCEQ’s proposal claims that recent air monitoring information justifies the removal of Texas City from the APWL. However, analyses completed by EDF and AAH and submitted to the agency indicated that the current monitoring network is 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. TCEQ failed to recognize that the existing monitoring network, a collection of monitors sited close to industrial facilities, does not capture the major downwind concentrations of pollutants in neighborhoods closest to the largest sources of pollution. As illustrated in the insert, our analysis shows that the largest concentration of benzene is outside the measuring range of the existing monitors.
The largest emitter in the area, the BP Texas City refinery, is the worst environmental performer in the region. BP Texas City is ranked as the largest benzene emitter in the five-state region. On March 23, 2005, an explosion killed 15 employees and injured 170 when workers at the BP refinery were restarting a unit that had been closed for repairs. Workers improperly filled a tank with 138 feet of flammable liquid that 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 that likely caused 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 incidents in the United States between 1989 and 2005.
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.
What happens now?
According to the TCEQ, Texas City will remain a listed APWL-area until a final determination can be made. We have been told that this determination will directly address our comments. We are glad that Texas City remains on the APWL for now, as this is preferable to the removal of the area, especially while comments are still pending. But our analyses indicate that neighborhoods located near the BP facility may be exposed to hazardous pollutants that exceed the state’s own guidelines. Additional actions should be taken now to reduce the health risks to those impacted residents.
We, therefore, recommend that the agency place additional monitoring equipment in the areas expected to have the highest concentration of pollutants. Without proper data collection and analysis, TCEQ cannot ensure that it is maintaining the Air Pollutant Watch List in a manner that protects public health.
Opinions expressed in this blog are those of the author, and do not necessarily represent the positions of the Moving Forward Network or its members. All errors are the responsibility of the author.