Air Pollutant Watch List
Proposed Change
Removal of Texas City,
Hydrogen Sulfide
Texas Commission on
Environmental Quality
Air Permits Division
March 11, 2013
Summary
The Texas Commission on Environmental Quality (TCEQ) established the Air Pollutant
Watch List (APWL) to address areas of the state where air toxics were monitored at
levels of potential concern, and the TCEQ uses the APWL to reduce air toxic levels by
properly focusing limited state resources on areas with the greatest need. The TCEQ
added a portion of Texas City to the APWL to address persistent, elevated ambient
concentrations of air toxics, including the air toxic hydrogen sulfide. Since Texas City’s
inclusion on the APWL, the TCEQ has increased its monitoring, investigations,
enforcement, and air permitting efforts in the Texas City area.
Title 30 Texas Administrative Code (30TAC) Chapter 112, Control of Air Pollution From
Sulfur Compounds, codifies state ambient regulatory standards for hydrogen sulfide.
These state standards were established below levels that may cause adverse short-term
or long-term health effects. The TCEQ compares stationary ambient monitoring data in
Texas City with the state regulatory standard of 0.08 parts per million (ppm). Stationary
monitoring data demonstrate that exceedances of the standard are infrequent and
appear to be episodic in nature; however, monitored concentrations show a significant
improvement. Stationary monitoring data show that no exceedances of the state
hydrogen sulfide regulatory standard have occurred since April 2011 and that the
number of days that monitoring shows an exceedance of the state standard have
decreased since 2003 (decreasing from 11 different days in 2003, to 3 days in 2011, and
no exceedances in 2012).
Hydrogen sulfide emissions can be minimized with the proper maintenance and
operation of equipment and flaring systems. In response to the TCEQ and EPA
enforcement process, four of the primary hydrogen sulfide emitters in the Texas City
APWL area have taken corrective action to mitigate hydrogen sulfide emissions by
installing controls, which occurred from 2005 through 2011. Further, one of the
companies uses ambient monitors on its fence line to identify and address issues that
may result in elevated hydrogen sulfide concentrations. Because the primary companies
in Texas City that emit hydrogen sulfide have implemented significant equipment
improvements to minimize hydrogen sulfide emissions, the likelihood of experiencing
extended elevated hydrogen sulfide concentrations has been drastically reduced. As
such, the TCEQ has determined that monitored concentrations can reasonably be
expected to be maintained below the state standard and is proposing to remove
hydrogen sulfide in Texas City from the APWL.
2
Air Pollutant Watch List (APWL) Area
The TCEQ established the APWL to address areas of the state where air toxics were
monitored at a level of potential concern. Figure 1, Texas City APWL Area, illustrates
the portion of Texas City that the TCEQ has included on the APWL. The TCEQ added
this area to the APWL to address persistent, elevated ambient concentrations of air
toxics, including the air toxic hydrogen sulfide.
Figure 1: Texas City APWL Area
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Designated Land Use and Proximity to Residential Areas
and High-Traffic Roadways
The Texas City APWL area boundary encompasses the area south of Texas Avenue/State
Highway (SH) 348/Farm-to-Market Road (FM) 1765, east of Highway 146, and west of
Galveston Bay. The majority of this land area is industrial; however, there are some
residences located within the APWL boundary designation for the area. Some of these
homes are also located in close proximity to industrial equipment. Most of the
population density in the area is located north of SH 348 (approximately a quarter-mile
north of the industrial complexes) and west of Hwy 146. In some places, homes are
within one-tenth of a mile of industrial equipment.
The streets that define the APWL boundary are high-traffic roadways. Highway 197 is
also a high-traffic roadway, running between some of the industrial complexes in the
APWL area. In addition, the area around Swan Lake located within the APWL boundary
is designated as a waterfront conservation and recreational area.
Pollutant of Concern
Hydrogen sulfide is a colorless gas with a characteristic odor of rotten eggs, and it can be
detected through smell at very low concentrations. Hydrogen sulfide occurs naturally in
crude oil and natural gas and is also produced by anaerobic digestion of organic matter.
Many industrial processes emit hydrogen sulfide, including petroleum refining, food
processing, and paper milling.
Some individuals can smell hydrogen sulfide in concentrations as low as 0.005 ppm.
Exposure to somewhat higher concentrations of hydrogen sulfide may result in adverse
effects, such as eye, nose, and throat irritation. Exposure to extremely high levels of
hydrogen sulfide—greater than 500 ppm—may cause loss of consciousness and
potentially death. As a result, those industries that process hydrogen sulfide are
generally equipped with hydrogen sulfide safety monitors. The TCEQ regulates
hydrogen sulfide to concentrations very far below (over 6,000 times below) this basic
safety level.
The TCEQ established state ambient regulatory standards for hydrogen sulfide in
30TAC Chapter 112, Control of Air Pollution From Sulfur Compounds. These state
standards1 are well below levels that may cause adverse short-term or long-term health
effects. Specifically, the standard for residential, business, or commercial properties is
0.08 ppm averaged over any 30-minute period and the standard for property other than
residential, business, or commercial properties (typically industrial or vacant tracts and
range lands) is 0.12 ppm averaged over any 30-minute period.
State hydrogen sulfide standards are contained in 30 TAC §112.31, Allowable Emissions – Residential,
Business, or Commercial Property; and 30 TAC §112.32, Allowable Emissions – Other Property.
1
4
Companies Located in the Texas City APWL Area
Table 1, Companies in the Texas City APWL Area, lists 19 industrial companies located
within the APWL boundary.
Table 1: Companies in the Texas City APWL Area
Company Name
Regulated Entity (RN) Number
BP Products North America (BP)
RN102535077
Marathon Petroleum – Texas City Refinery
(Marathon)
RN100210608
Valero Refining Texas City Refinery (Valero)
RN100238385
Praxair Texas City (Praxair)
RN100220599
Praxair Texas City Hydrogen Complex (Praxair
HC)
RN104095435
Union Carbide Texas City (Union Carbide)
RN100219351
BP Texas City Chemical Plant B (BP Chem)
RN102536307
Eastman Chemical Texas City (Eastman)
RN100212620
INEOS Texas City Chemical Plant (INEOS)
RN104579487
Oiltanking Texas City Terminal (Oiltanking)
RN100217231
NuStar Texas City Terminal (NuStar)
RN100218767
Texas City Cogeneration (TX City Cogen)
RN100224245
South Houston Green Power (SH Green Power)
RN103934493
Enterprise Crude Pipeline, Seaway Texas City
Station (Enterprise)
RN102560182
Shell BP Texas City Compression Dehydration
Facility (Shell)
RN105644223
Marathon Pipe Line Texas City Pump Station
(Marathon Pipe Line)
RN104574918
Gulf Coast Waste Disposal Authority (GCWDA)
RN100212463
Bollinger Texas City (Bollinger)
RN100218627
Oxbow Marine Terminal Texas City (Oxbow)
RN102707049
As Table 1 illustrates, the Texas City APWL area is highly industrialized. The APWL area
contains three petroleum refineries (BP, Marathon, and Valero), six chemical plants
(two Praxair sites, Union Carbide, BP Chem, Eastman, and INEOS), three petroleum
and chemical terminals (Oiltanking, NuStar, and Enterprise), two power generation
plants (TX City Cogen and SH Green Power), two oil and gas support facilities (Shell and
5
Marathon Pipe Line), a wastewater treatment facility (GCWDA), a barge manufacturing
and repair facility (Bollinger), and a petroleum coke and coal material handling facility
(Oxbow). Figure 2, Texas City APWL Companies, shows the relative locations of the
industrial complexes within the APWL boundary.
Figure 2: Texas City APWL Companies
Emissions Inventory
Owners or operators of certain stationary sources are required by 30 TAC §101.10,
Emissions Inventory Requirements, to submit an annual emissions inventory to the
TCEQ. A company is required to report all of its actual air emissions each year,
including all authorized and unauthorized emissions. Unauthorized emissions may
include those emissions released as a result of emissions events or unauthorized
maintenance, startup, and shutdown activities. Companies located in APWL areas are
subject to this requirement.
6
Reviewing the emissions inventory information can be useful to identify the companies
that report the contaminant of concern. This section provides the emissions inventory
information that the APWL companies have submitted to the TCEQ from 2000 to 2010.
For each calendar year, the amount of hydrogen sulfide reported is identified as annual
emissions (AE), emissions events (EE), and scheduled maintenance, startup, and
shutdown activities (SMSS). A company’s hydrogen sulfide emissions reported as AE
include all of the emissions reported for all facilities located at the site that are
authorized under an air New Source Review (NSR) permit or permit by rule, including
emissions from authorized SMSS. Because companies are required to report all actual
emissions, reports must include those emissions that are not authorized, including
emissions resulting from EE and all releases due to SMSS that are not authorized by a
NSR permit or permit by rule. Companies are required to report emissions from any
emissions event above 0 tons per year. Of the 19 companies located in the APWL area, 7
of them have reported hydrogen sulfide emissions, as the following tables illustrate.
Table 2: Tons of Hydrogen Sulfide Reported by BP Products North America Inc, RN
1025350077
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
3.9398
26.9061
91.9471
116.1105
107.7489
77.3449
6.3937
10.7152
16.2489
10.3464
10.9976
EE
2.0051*
0.5449*
0*
0
1.1322
2.3310
0.2448
0.2892
18.9108
15.1963
2.3295
*
*
*
0
0.4395
8.0132
2.5942
1.9747
0.4558
0.2034
0.0378
SMSS
* The EE and SMSS emissions are reported as one value.
Table 3: Tons of Hydrogen Sulfide Reported by Marathon Petroleum Company LLC,
RN 100210608
Year
2001
2002
—
0.0000
EE
—
0.0383*
SMSS
—
*
AE
2000
2003
2004
2005
2006
2007
2008
2009
2010
0.0000
—
0.0120*
—
0.0000
0.0000
0.8155
0.8158
0.8017
0.8077
—
—
0.0100
0.0000
0.0002
0.0000
0.0000
0.1036
*
—
—
0.0002
0.0028
0.0040
0.0000
0.0000
0.0000
Table 4: Tons of Hydrogen Sulfide Reported by Valero Refining-Texas LP, RN
100238385
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
18.9200
18.8780
12.6853
20.9775
16.8850
4.1538
13.2299
6.2580
7.2217
6.9069
2.2560
EE
0.3377*
1.3422*
2.8705*
0.9083*
0.6649
0.6153
1.1266
1.8930
0.1830
0.7448
0.4558
*
*
*
*
0.0031
0.5554
0.0822
0.4452
0.3041
0.7274
0.2130
SMSS
Table 5: Tons of Hydrogen Sulfide Reported by Union Carbide Corporation, RN
100219351
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
0.6828
0.9077
0.0642
0.8084
0.2860
0.0025
0.0015
0.0030
0.0015
0.0021
0.0019
EE
0*
0*
0*
0.0039*
0
0
0
0
0
0
0
SMSS
*
*
*
*
0
0
0
0
0
0
0
7
Table 6: Tons of Benzene Reported by BP Amoco Chemical Company, RN
102536307
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
—
0
—
—
—
—
0
—
—
—
0.0097
EE
—
0.0063*
—
—
—
—
0.0390
—
—
—
0
SMSS
—
*
—
—
—
—
0
—
—
—
0
Table 7: Tons of Hydrogen Sulfide Reported by Gulf Coast Waste Disposal
Authority, RN 100212463
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
0.0551
AE
—
29.6123
114.1457
80.2783
80.2783
4.1343
4.8450
2.9071
4.5682
0.3345
EE
—
0*
0*
0
0
0
1.8716
1.2353
0
0
0
SMSS
—
*
*
0
0
0
0
0
0
0
0
Table 8: Tons of Hydrogen Sulfide Reported by Texas City Cogeneration LP, RN
100220599
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
—
—
—
—
—
—
0.0008
0.0008
0.0008
0.0008
0.0008
EE
—
—
—
—
—
—
0
0
0
0
0
SMSS
—
—
—
—
—
—
0
0
0
0
0
Table 9: Total Tons of Hydrogen Sulfide Reported by Companies in the APWL Area
Year
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
AE
23.5426
76.3041
218.8420
218.1750
205.1980
85.6355
24.4709
20.6996
28.8569
18.3924
14.1288
EE
2.3428*
1.9317*
2.8825*
0.9122*
1.7971
2.9563
3.2820
3.4177
19.0938
15.9411
2.8889
0.4426
8.5688
2.6792
2.4239
0.7599
0.9308
0.2508
207.4379
97.1606
30.4321
26.5412
48.7106
35.2643
17.2685
SMSS
—
—
—
0
Total
25.8854
78.2358
221.7248
219.0869
Monitoring for Hydrogen Sulfide in Texas City
The TCEQ has conducted mobile monitoring projects in and around the industrial area
of Texas City since 1995. In addition, the TCEQ has operated a continuous, stationary
hydrogen sulfide2 monitor in Texas City since January 2002. The TCEQ initially
installed the monitor at the Texas City CAMS 10 station, previously located at 2700 ½
Total reduced sulfur is measured at the stationary monitors discussed in this document. Total reduced
sulfur at these monitors primarily consists of hydrogen sulfide. If total reduced sulfur compounds are
measured below the state standard, then hydrogen sulfide concentrations would, therefore, also be below
the state standard. Hence, the TCEQ determined that total reduced sulfur monitoring data is an
acceptable surrogate for hydrogen sulfide monitoring data. For simplicity, this document will refer to the
monitoring of hydrogen sulfide when the total reduced sulfur analyte is measured.
2
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13th Avenue North, and conducted monitoring at this location through February 2004,
when the hydrogen sulfide monitor was moved to its present location at the Texas City
Ball Park stationary monitoring site. The TCEQ has used data from its mobile
monitoring projects and from its stationary monitor for all of its evaluations relating to
the Texas City APWL area, including this proposal to delist hydrogen sulfide in Texas
City from the APWL.
Ambient hydrogen sulfide concentrations are measured at two stationary monitors
operated by BP, and BP also operates an on-site monitor. BP was required to operate the
three monitors through enforcement agreements with the TCEQ and/or the U.S. EPA
and U.S. Department of Justice and continues to operate these monitors. The hydrogen
sulfide data from the BP monitors is used by BP to ensure proper operation of the
refinery and to help quickly identify and fix equipment as necessary. The Texas City Ball
Park monitor and BP’s monitors are listed in Table 10, Stationary Hydrogen Sulfide
Monitors.
Table 10: Stationary Hydrogen Sulfide Monitors
Monitoring Site Name
AQS Number
Location
Owner
Texas City Ball Park monitor
481670005
2516 ½ Texas Avenue
TCEQ
Texas City BP Logan Street
monitor
481670621
303 Logan Street
BP
Texas City BP On-Site
monitor
481670616
BP property near
Highway 197
BP
Texas City BP 31st Street
monitor
481670615
BP property between
Texas Avenue and 5th
Avenue
BP
Ambient hydrogen sulfide concentrations are also measured at the 2nd Avenue
stationary monitor. The Texas City/La Marque Community Air Monitoring Network
operates the 2nd Avenue monitor. This network is supported by a financial agreement
between participating companies and an independent operator/contractor who
conducts and validates the monitoring data from the Texas City/La Marque Community
Air Monitoring Network. These data are then presented to the TCEQ on a periodic basis.
The TCEQ is providing the information on the 2nd Avenue monitor in this proposal
because many individuals will likely be interested in the results. Unlike the Texas City
Ball Park monitor and the BP monitors, the TCEQ does not prescribe data quality
standards for the community air monitoring network. Figure 3, Stationary Hydrogen
Sulfide Monitors in Texas City, shows the locations of the hydrogen sulfide monitors
discussed in this section.
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Figure 3: Stationary Hydrogen Sulfide Monitors in Texas City
Evaluating Ambient Hydrogen Sulfide Monitoring
Data
TCEQ’s mobile monitoring trips commonly include hydrogen sulfide monitoring that
involves taking measurements upwind and downwind of a source, enabling staff to
determine the 30-minute net concentration and, hence, determine compliance with the
state ambient regulatory standards. The stationary monitors discussed in this
document, however, measure the ambient concentration at that particular location. The
TCEQ compares ambient monitoring data (averaged for each 30-minute period) with
the state regulatory standard of 0.08 ppm. Although the state standard is a net
concentration, a downwind measurement at the monitor of 0.08 ppm or below would
indicate that ambient concentrations do not violate the state regulatory standard.
10
Meteorological data are also obtained from the stationary monitoring sites. The TCEQ
previously evaluated wind directional data for the periods of time in which there was an
exceedance of the standard. As expected, the winds have originated from the Texas City
industrial complex during those periods of time in which ambient concentrations
exceeded 0.08 ppm at the Texas City Ball Park monitoring site.
Reasons for Texas City’s Inclusion on the APWL
The TCEQ added an area of Texas City on the APWL in 2001 to address elevated
concentrations of the air toxic propionaldehyde. Subsequently, the TCEQ added
hydrogen sulfide to the Texas City APWL area in response to mobile and stationary
monitoring data. A 2004 mobile monitoring trip detected hydrogen sulfide levels
exceeding the 0.08 ppm standard downwind of GCWDA and Valero. Additionally,
stationary monitoring data from the Texas City Ball Park monitor indicated 69
exceedances of 0.08 ppm in 2004.
Monitored Hydrogen Sulfide Levels After Inclusion on
APWL
There were no exceedances of the 0.08 ppm standard at the Texas City Ball Park
stationary monitor in the years 2005 through 2008. The TCEQ conducted mobile
monitoring in 2008 and did not measure hydrogen sulfide concentrations above the
standard, including samples that were taken downwind of Oiltanking, GCWDA, Valero,
BP, and Marathon. In 2009, there were 16 monitored exceedances above the 0.08 ppm
standard at the Texas City Ball Park stationary monitor; however, no exceedances were
monitored at the Texas City Ball Park stationary monitor in 2010, 2011, or 2012.
Also, the Texas City/La Marque Air Monitoring Network reported to the TCEQ that
concentrations exceeded 0.08 ppm at its 2nd Avenue monitoring site on 11 days in 2003,
6 days in 2004, 4 days in 2005, 2 days in 2006, 1 day in 2008, and 2 days in 2011. No
exceedances above 0.08 ppm were monitored in 2007, 2009, or 2010.
In addition, since Texas City was included on the APWL for hydrogen sulfide, BP has
activated its hydrogen sulfide monitors. From the time that the Logan Street monitor
was activated in April 2010, exceedances of the 0.08 ppm standard occurred on one
day—April 17, 2011. Also, the TCEQ evaluated the available validated data from the 31st
Street monitor (from April 2010) and the data show no exceedances of the 0.08 ppm
standard.
TCEQ Actions to Reduce Hydrogen Sulfide
Emissions
The purpose of the APWL is to reduce ambient air toxic concentrations below levels of
potential concern. The TCEQ uses the APWL to properly focus limited state resources
on areas with the greatest need. The TCEQ also uses the APWL to heighten awareness of
elevated concentrations and to engage the companies in APWL areas to encourage
efforts to reduce emissions.
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The TCEQ has scrutinized air permit applications for those companies in the Texas City
APWL area requesting hydrogen sulfide increases and has conducted several mobile
monitoring projects in the area from 1995 to 2008. Since the area has been listed on the
APWL, the TCEQ has focused its compliance and enforcement resources to help ensure
that companies located in the APWL area are operating in compliance.
The increased efforts by TCEQ’s Region 12 staff have resulted in the issuance of multiple
Notices of Violation (NOVs) to several of the companies in the Texas City APWL area.
The commission has thusly been able to enter into Agreed Orders with several of the
companies to resolve its concerns. Through the enforcement process, several companies
in Texas City have agreed to conduct significant activities to reduce hydrogen sulfide
emissions in Texas City.
A 2001 TCEQ site inspection revealed that GCWDA, a Publicly Owned Treatment Works
located at 3500 Loop 197 South, had never obtained the appropriate air New Source
Review authorization for its industrial wastewater treatment systems. The TCEQ took
enforcement action against GCWDA, and GCWDA entered into an Agreed Order with
the TCEQ (2003-0187-AIR-E) to obtain an air permit. The TCEQ, through the permit
review process, required the installation of an oxygen activated sludge unit with
secondary clarifiers. The new control equipment, which was authorized in November
2005, reduced hydrogen sulfide emissions by more than 50 tons per year (and also
reduced volatile organic compound emissions by more than 1,500 tons per year). In
2008, the TCEQ conducted additional hydrogen sulfide monitoring downwind of
GCWDA and data demonstrated compliance with the state hydrogen sulfide standard.
In addition, the three Texas City refineries—BP, Marathon, and Valero—have agreed to
implement process improvements and install control equipment to significantly reduce
sulfur dioxide and/or hydrogen sulfide emissions through the TCEQ and/or EPA
enforcement process. Valero and BP entered into Agreed Orders with the TCEQ to
specifically address alleged violations with the state hydrogen sulfide regulatory
standard. Also, the EPA’s Petroleum Refinery Initiative resulted in emission reductions
from refineries across the country, including the three refineries located in Texas City.
One of the goals of the EPA’s initiative was to reduce emissions of sulfur dioxide, a
criteria pollutant regulated by the Federal Clean Air Act. Among other things, the EPA
targeted sulfur dioxide emissions from fluidized catalytic cracking units and flaring. The
EPA’s initiative also addressed noncompliance with Title 40 Code of Federal
Regulations Part 60, Supbart J, Standards of Performance for Petroleum Refineries. All
three of the refineries located in Texas City entered into settlement agreements with the
EPA and TCEQ and agreed to implement improvements in the manner that refinery
gases are handled, treated, and controlled, decreasing the quantity of sulfur-laden gases
that are combusted, thus reducing sulfur dioxide emissions significantly and also
reducing hydrogen sulfide emissions.
Specifically, BP has entered into multiple Agreed Orders with the TCEQ since the mid90s regarding alleged violations at its petroleum refinery located at 2401 5th Avenue
South (including TCEQ Agreed Orders 2001-0329-AIR-E and 2005-0224-AIR-E). As a
result of the EPA’s Petroleum Refinery Initiative, BP entered into a Consent Decree
(Civil No. 2:96 CV 095 RL) with the EPA in 2001. BP agreed to re-route all emissions
from the sulfur recovery plant and control the transfer of sulfur from the refinery sulfur
12
loading racks. BP also agreed to operate flare gas recovery systems, which were installed
in June 2011 and minimize emissions from flares and other combustion devices.
Similarly, Valero committed to reduce the number and severity of major flaring events
(Civil Action No. SA05CA0569RF) from its petroleum refinery located at 1301 Loop 197
South. Valero also installed a flare gas recovery system, which was installed in April
2009 (TCEQ Agreed Order 2010-0390_AIR-E).
Marathon, who operates a petroleum refinery at 1320 Loop 197 South, has entered into
two agreements with the EPA, resulting in significant reductions in hydrogen sulfide
emissions. In May 2001, Marathon agreed (Civil Action No. 4:01-CV-40119-PVG) to
invest in controls and operating practices to minimize excess flaring of sulfur laden
gases during process upsets, which included the installation of a sulfur recovery unit in
May 2007. Marathon’s April 2012 agreement included the optimization of its flare
operations to reduce air pollution, which included implementing a waste gas
minimization plan, putting flaring limits in place, and automating the flare controls to
achieve high combustion efficiency. The EPA’s consent decree with Marathon indicates
that, between 2008 and 2011, emissions of hydrogen sulfide from the covered flares
have been appreciably reduced and that further reductions are very likely with the full
implementation of the controls required by the consent decree.
In addition, the TCEQ has recently worked with several companies, including two of the
refineries in the Texas City area, to better understand how to operate flares properly and
mitigate emissions. In response to the EPA’s Flaring Initiative, refineries and other
companies have been working over ten years to minimize the flaring of process gases. As
a result of TCEQ and EPA initiatives, refineries have worked and continue to strive to
minimize the emissions that are routed to a flare, and improving flare operation and
destruction efficiency of waste gases.
Monitored Decline in Ambient Hydrogen Sulfide
Concentrations
Mobile Monitoring
The TCEQ conducted mobile monitoring in Texas City most recently in 2001, 2004, and
2008. The TCEQ documented exceedances of the state ambient hydrogen sulfide
standard in 2001 and 2004, but mobile monitoring data collected in 2008 shows an
improvement. Specifically, the TCEQ took 54 concentrations during its 2001 mobile
monitoring project and detected 11 exceedances of the standard (the TCEQ identified BP
as the most likely source of 10 of the exceedances, and 1 of the exceedances was taken
downwind of Valero). Similarly, the 2004 mobile monitoring data shows that 5 of the 20
concentrations exceeded the standard (exceedances were downwind of GCWDA and
Valero). No exceedances of the standard were monitored in 2008, though sampling may
not have been entirely representative due to high and variable winds. Table 11,
Exceedances of 0.08 ppm Measured During Mobile Monitoring, lists all exceedances of
the state standard documented for each mobile monitoring trip, and Figure 4, Locations
of Mobile Monitoring Samples, shows the locations of the sampling taken on each trip
(concentrations are provided in parts per billion (ppb)). The portion of Figure 4 relating
13
to the 2008 mobile monitoring trip illustrates that the highest concentration monitored
was 57 ppb (or 0.057 ppm), which is below the 0.08 ppm state standard.
Table 11: Exceedances of 0.08 ppm Measured During Mobile Monitoring
Date
Time of Sample
Collection
Measured 30-minute Average
Concentration (ppm)
November 4, 2001
14:55 – 15:25
0.186
November 4, 2001
18:30 – 19:00
0.285
November 4, 2001
18:30 – 19:00
0.324
November 4, 2001
18:35 – 19:05
0.277
November 6, 2001
18:10 – 18:40
0.323
November 6, 2001
18:45 – 19:15
0.100
November 6, 2001
19:50 – 20:20
3.187*
November 6, 2001
21:15 – 21:45
1.338*
November 7, 2001
08:40 – 09:10
0.086
November 8, 2001
03:10 – 03:40
2.051*
November 8, 2001
20:00 – 20:30
0.196
October 3, 2004
22:00 – 22:30
0.885*
October 4, 2004
04:05 – 04:35
1.420*
October 4, 2004
10:55 – 11:25
0.237*
October 5, 2004
07:05 – 07:35
0.155†
October 5, 2004
08:50 – 09:20
1.130*†
* Reported concentrations exceeded the upper limit of instrument calibration and are considered estimated.
†The analytical equipment detected the presence of reduced sulfur compounds other than hydrogen sulfide, which could bias the
data.
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Figure 4: Locations of Mobile Monitoring Samples
TCEQ’s Texas City Ball Park Monitor
A stationary hydrogen sulfide sampler was originally installed at the Texas City CAMS
10 monitor at 2700 ½ 13th Avenue North on January 9, 2002. In February 2004, the
hydrogen sulfide sampler was moved to its current location at the Texas City Ball Park
monitor, located at 2516 ½ Texas Avenue. Since the TCEQ installed its continuous
stationary monitor in Texas City in 2002, exceedances of the 0.08 ppm hydrogen sulfide
standard have been measured on seven different days, with a total of 128 30-minute
periods that exceeded the standard.
At the Texas City CAMS 10 location, one exceedance of the standard was monitored in
2002 (i.e., there was one 30-minute average that was above 0.080 ppm), and it occurred
on January 17. In 2003, there was one day with 42 exceedances of the standard, which
was January 28.
In 2004, no exceedances were monitored at the Texas City CAMS 10 monitor before the
hydrogen sulfide sampler was moved in February, but there were 69 exceedances of the
standard at the Texas City Ball Park monitor on April 17 – 18 and May 7. Two of the
exceedances occurred on May 7 and the other 67 occurred from April 17 – 18.
No exceedances of the standard were monitored in the years 2005 – 2008. In 2009, 16
exceedances occurred on two days—February 26 and November 15. Once again, no
exceedances have been monitored from 2010 through 2012.
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Table 12: Number of Exceedances at the Texas City Ball Park Monitor
Date
Number of
Exceedances
Time
Range of
Concentrations
Exceeding 0.08
ppm
February 26, 2009
5 exceedances
Continuously, between
05:30 and 05:50
0.0854 – 0.1161
November 15, 2009
11 exceedances
Non-continuously,
between 17:35 and
19:10
0.0807 – 0.1096
April 17, 2004
16 exceedances
Non-continuously,
between 02:20 and
03:30 and 23:25 and
23:55
0.0803 – 0.1144
April 18, 2004
51 exceedances
Non-continuously,
between 00:00 and
03:10, 04:10 and
04:20, and 22:45 and
23:25
0.0813 – 0.1207
May 7, 2004
2 exceedances
Non-continuous at
20:25 and 20:35
0.0804 – 0.0821
January 28, 2003
42 exceedances
Continuously, between
05:15 and 08:40
0.0883 – 0.2262
January 17, 2002
1 exceedance
07:25
0.0813
Industry and Community Monitors
The TCEQ has reviewed data that has been collected and validated from BP’s Logan
Street and 31st Street monitors since April 2010. During this time period, no
exceedances were monitored at BP’s 31st Street monitor, and exceedances of the 30minute standard were measured on one day at BP’s Logan Street monitor (April 17,
2011). The April 17, 2011, exceedances occurred during a unit startup at BP, and wind
directional data indicate that the emissions came from BP. BP uses its monitors to
initiate action and quickly minimize emissions. Hydrogen sulfide concentrations were
elevated for a short period of time (three 5-minute increments). BP had initiated action
to address the elevated levels, and the event was so brief that concentrations already
began to decrease below levels of concern before additional action was needed.
Additionally, the Texas City/La Marque Community Air Monitoring Network reported
to the TCEQ that the number of days with a 30-minute exceedance of 0.08 ppm has
decreased over the past 9 years at its 2nd Avenue monitoring site, with 11 days in 2003, 6
days in 2004, 4 days in 2005, 2 days in 2006, no exceedance in 2007, 1 day in 2008, no
exceedance in 2009 or 2010, and 2 days in 2011. As reported by the Texas City/La
Marque Air Monitoring Network and BP, the two days in 2011 in which ambient
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concentrations at the 2nd Avenue monitor exceeded 0.08 ppm occurred on April 25 – 26
and were caused by a power outage at BP, resulting in 30-minute averages that exceeded
the 0.08 ppm standard. No exceedances were observed at the Texas City Ball Park
monitor (or BP monitors) during the same time period.
TCEQ Determines that Monitored Concentrations
are Below State Standards
Monitoring data show that ambient hydrogen sulfide concentrations have historically
exceeded 0.080 ppm downwind of BP, Valero, and GCWDA. The Texas City Ball Park
monitoring data and other stationary monitoring data demonstrate that exceedances of
the standard are infrequent and appear to be episodic in nature. In response to the
TCEQ and EPA enforcement process, the four primary hydrogen sulfide contributors,
including the three refineries and GCWDA, have taken corrective action to install
controls beginning in 2005 and through 2011, mitigating hydrogen sulfide emissions.
Further, BP uses its ambient monitors to identify and address issues that may result in
elevated hydrogen sulfide concentrations. The TCEQ determined that the monitored air
concentrations show a significant improvement overall as demonstrated by the
monitoring data, which show that no exceedances of the state hydrogen sulfide
regulatory standard have occurred since April 2011 and that the number of days that
exceed the state standard have decreased since 2003, as is illustrated in the following
figure.
Number of Days with a 30-minute Exceedance
of 0.08 ppm (for each monitor)
Figure 5: Number of Days with an Exceedance
14
12
10
8
Logan Street
6
Ball Park
2nd Avenue
4
2
0
2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012
Year
Hydrogen sulfide emissions can be minimized with the proper maintenance and
operation of equipment and flaring systems. Because the primary companies in Texas
City that emit hydrogen sulfide have installed flare gas recovery systems and other
significant equipment improvements to minimize hydrogen sulfide emissions, the
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likelihood of experiencing extended elevated hydrogen sulfide concentrations has been
drastically reduced. As such, the TCEQ has determined that monitored concentrations
can reasonably be expected to be maintained below the state standard and is proposing
to remove hydrogen sulfide in Texas City from the APWL.
Public Comment Period
The TCEQ will accept comments on the proposed delisting of Texas City from the APWL
for the air toxic hydrogen sulfide. Interested persons may send comments to
APWL@tceq.texas.gov or may send comments to the APWL coordinator at the following
mailing address:
Ms. Tara Capobianco, P.E.
Air Pollutant Watch List Coordinator
Texas Commission on Environmental Quality
Air Permits Division
MC-163
P.O. Box 13087
Austin, Texas 78711-3087
The comment period began on March 11, 2013, and the TCEQ will accept comments
through April 26, 2013. Any questions regarding the proposed delisting or the APWL
process may be forwarded to Ms. Capobianco at (512) 239-1117.
Public Meeting
The TCEQ will conduct a public meeting to receive comments on the proposed delistings
of Texas City from the APWL for the air toxics benzene and hydrogen sulfide. The
public meeting will be held on Thursday, April 11, 2013, at 6:00 p.m. at the Nessler
Center Wings of Heritage Room, located at 2010 5th Avenue North, Texas City, Texas.
The TCEQ will give a short presentation of the delisting of both benzene and hydrogen
sulfide at 6:00 p.m. After a short question and answer session, the TCEQ will officially
open the public meeting. The public meeting will be structured for the receipt of oral or
written comments by interested persons.
Individuals may present statements when called upon in order of registration. Open
discussion within the audience will not occur during the public meeting; however, the
TCEQ staff will be available to discuss the proposed delistings and answer any
additional questions after the meeting.
Persons who have special communication or other accommodation needs who are
planning to attend the meeting should contact the Office of the Chief Clerk at (512) 2393300 or 1-800-RELAY-TX (TDD) at least one week prior to the meeting.
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