When Hurricane Harvey struck the Texas coast in August 2017, many industrial facilities had to shut down their operations before the storm arrived and restart once rainfall and flooding had subsided.
These shutdowns and startups, as well as accidents caused by the hurricane, led to a significant release of air pollutants
Industry Looks For Hurricane Lessons As Climate Changes
by Rebecca Hersher
August 31, 2018 - 12:57pm
The Houston Ship Channel has the rhythm of an ant colony. Barges and oil tankers lumber through the silty water, tangles of exposed pipe rise hundreds of feet above a sea of white tanks. Residents of the coastal plain between Houston and Galveston will tell you the plain is flatter than a regulation pool table. But if you can get up high enough you'll see trains and ships and trucks moving ceaselessly from dock to dock, terminal to terminal.
The vehicles carry the chemicals and oil for your car, your clothes, your hair gel and your eyeliner, your kid's soccer ball and your mother's hospital IV. And the entire system is sitting in the path of some future hurricane.
Last August, Hurricane Harvey dumped more than 60 inches of rain on this region and, in the year since, a lot of companies have been reassessing how they prepare for, and respond to, storms.
One big issue is how to keep gas and chemicals safely contained during big floods. Approximately 8 million pounds of extra air pollution are estimated to have been released as a result of Harvey, according to an analysis of public records that the companies themselves reported.
"They could have been better prepared than they were this time around," says Bakeyah Nelson, who runs the nonprofit Air Alliance Houston. Pollution was also released into waterways. The chemicals at one company north of Houston caught fire and burned for days.
"I think every facility should be taking stock of what happened during Harvey," Nelson says. "Are there even worse-case scenarios that have been predicted or could be predicted? And [firms need] to be very intentional about their efforts in terms of preparing for these situations, which will likely be more frequent in the future."
Many companies say they are doing just that.
"Where we've had the opportunity, we've been investing in improving resilience of our assets in light of more severe weather events that have been occurring," says Ron Gerrard, a senior vice president at the chemical company Huntsman, which shut down multiple facilities during Harvey.
For example, says Gerrard, electrical substations at some facilities were built at ground level 40 or 50 years ago. "Today, when we modernize and rebuild those, they now stand some 10 to 12 feet above ground level on piers," he says, "in order to ensure that they're well above any flood levels, whether its 100 year or 500 year flood levels."
Rod Herrick manages a plant owned by the chemical company Covestro in Baytown, east of Houston. He says he and his team at the plant reassess their hurricane plans after every storm.
"One thing I can say I've learned about hurricanes and tropical storms:There's never one that's the same," Herrick explains. Hurricane Ike, for example, slammed the area with heavy winds in 2008, whereas tropical storm Allison caused massive flooding in 2001.
Herrick's site didn't report releasing any additional pollution as a result of Hurricane Harvey, a fact he attributes in part to lessons they learned from Hurricane Ike. After that storm, Covestro moved critical computers and servers from a building next to the bayou to a building on higher ground.
As a result, although their site flooded during Harvey and they had to shut down, they were still able to communicate and monitor what was going on — and to reopen the plant less than two weeks later.
Herrick, who is on the board of a regional consortium of chemical plant managers, has also been gathering examples of things that worked well from other companies in the region, something he says hasn't necessarily happened in the past.
"Why should it be that that I have a good practice, and some of the other sites around this area here don't know what I know?" he says.
Some of the information companies are sharing with each other is technical, such as plans for how and when to shut down, or how to move generators to higher ground or install containers under tanks to catch leaks.
But there's also more mundane information — for example, which items should employers stock up on before a storm?
"Cleaning supplies — it can be mops, brooms, squeegees," lists Herrick. "It can be diapers. It can be feminine items that aren't available. You wouldn't even think about it, but women certainly would! The faster you can help [employees] take care of their personal items, the quicker they can come back to work."
"If employees are dislocated or there's a question of whether or not they are able even to work because of some disruption from a natural disaster, that's a problem for the firm," explains Howard Kunreuther, co-director of the Wharton Risk Management and Decision Process Center at the University of Pennsylvania.
Kunreuther co-authored a recent book about how companies assess disaster risk, and says executives are pretty good at short-term planning and responses to disasters, such as rebuilding employees' homes.
"There's a tendency for all of us — not just firms, but individuals — to be myopic," he says, "to want to get something back in in the short term to justify an investment. It often takes a disaster to get people to pay attention."
For example, Hurricane Harvey has drawn some attention to the tanks many companies use to store hazardous liquids. Many of the leaks during Harvey occurred when the roofs of storage tanks sank under the weight of rainwater, allowing the chemicals below to escape. Some companies are now covering those roofs with geodesic domes — a technology that has been around for years, but appears to be getting more popular as big rain storms get more common.
"You're starting to see them more, which is really good for us," says Juan Flores, whose town of Galena Park is surrounded by industrial sites. "Seeing these dome structures popping up tells you they are being proactive on it. So that's something. There's still pollution, but I can say it's gotten better since the '80s."
Flores says he wishes companies communicated more with the public about what they were doing.
"During the storm, we didn't know what was going on [or] what we were breathing," he remembers "We live so close, we can hear the alarms inside the plant going off sometimes." Among other things, he says, the companies nearby didn't tell residents whether they were planning to shut down their operations — which releases a lot of pollution — and didn't warn people about leaks until days, or even months, after they happened.
During Harvey, that type of information was available to others. Richard Wells, the vice president of Gulf Coast operations for the industrial giant Dow Chemical, says his company communicates closely with local officials during storms.
"The county knows our plan," Wells explains. "They know [when a storm is coming]; at a certain time we're going to be completely shut down, cleared of all chemicals and battening the hatches, if you will."
Companies also communicate with each other, because many plants rely on each other for raw materials. As a storm approaches, there can be a cascade of plants shutting down, and then restarting when the danger has passed.
But when large numbers of facilities shut down in a short period of time, as happened during Harvey, it releases a lot of pollution all at once. And that information doesn't necessarily make it to residents who live on the other side of a fence line from a refinery, or to public health officials who might be able to warn residents to stay inside or turn off air conditioners, because those machines draw in outdoor air.
Thornton Lee Medley, a longtime pipe fitter at refineries in the region and the president of the United Steelworkers Union Local 13-1 outside Houston, says people who live near refineries and chemical plants deserve to know such information. And not just because of risks from air pollution.
"The most dangerous time in a refinery or chemical plant [comes when] bringing it up bringing it down," he says. "I would be very interested in knowing, if I was the general public, when the company had decided to bring the units in the plant down. Because that is when I would be away from my home."
"Risk management is not just important for us that are working in the facility," Medley says, or for emergency workers nearby, "but for the entire community outside."
Hurricanes and Air Pollution
This research has been a continuing interest of the unit, funded by a mix of internal and external funds.Projects and Products
Hurricanes
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- Prestemon, J.P.; Pye, J.M. and Holmes, T.P. 2001. Timber economics of natural catastrophes. Pages 132-141. In: M. Pelkki (ed.) Proceedings of the 2000 Southern Forest Economics Workshop. Lexington, KY.
- Prestemon, J.P. and Holmes, T.P. 2000. Timber price dynamics following a natural catastrophe. American Journal of Agricultural Economics 82:145-160.
- Prestemon, J.P. and Holmes, T.P. 1998. Effects of Hurricane Hugo on South Carolina timber prices. Pages 93-100 In: R.A. Kluender, M.M. Corrigan, and N.B. Smith (eds.). Proceedings of the 1997 Southern Forest Economics Workshop. The School of Forest Resources, University of Arkansas, Monticello, AR.
Air pollution
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Climate change
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- Moulton, R.J. 1999. Forestry in U.S. climate change action plans: from the Arch to Kyoto. Pages 204-207 In: K.L. Abt and R.C. Abt (eds.). Proceedings of the 1998 Southern Forest Economics Workshop. Southern Research Station, Research Triangle Park, NC.
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When Hurricane Harvey struck the Texas coast in August 2017, many industrial facilities had to shut down their operations before the storm arrived and restart once rainfall and flooding had subsided.
These shutdowns and startups, as well as accidents caused by the hurricane, led to a significant release of air pollutants. Over a period of about two weeks, data we compiled from the Texas’ Air Emission Event Report Database indicates these sites released 2,000 tons of sulfur dioxide, carbon monoxide, nitrogen oxides, volatile organic compounds and other pollutants.
These types of emissions that result from startups, shutdowns or malfunctions are often referred to as “excess” or “upset” emissions and are particularly pronounced during times of natural disasters, as was the case with Hurricane Harvey.
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But, as we document in a newly published study in the journal Environmental Science & Technology, they also occur regularly during the routine operation of many industrial facilities, sometimes in large quantities.
And, even if unintended or unavoidable, the pollutants released during these events are in violation of the U.S. Clean Air Act (CAA).
With the EPA now revisiting the rules regarding these air toxics, our study shows how significant they are to public health – and how historically they have not been systematically tracked across the country or regulated comprehensively.
Excess emissions in Texas
Our study examines the occurrence of excess emissions in industrial facilities in Texas over the period from 2002 to 2016. We focused on Texas because, unlike nearly all other states, it has established comprehensive reporting requirements. Texas collects data on so-called hazardous air pollutants that cause harm to people exposed to them, such as benzene, as well as substances called criteria pollutants, such as nitrogen oxides that contribute to the formation of ozone.
As a general rule, states set limits to industrial air emissions based on provisions in their State Implementation Plan (SIP), which is their strategy for meeting CAA requirements. The EPA in turn is responsible for ensuring that each state’s SIP is drafted in accordance with the CAA.
The CAA requires sources of air pollution to achieve continuous emissions reductions, which in essence means companies need to install and maintain equipment to limit the release of pollutants that happen during routine operations.
Excess emissions occur when pollution abatement systems, such as scrubbers, baghouses or flares that curtail emissions before they are released, fail to fully operate as the result of an unexpected malfunction, startup or shutdown. That is, a facility fails to maintain continuous emissions reductions, thereby exceeding its permit limits.
Though one might assume that such occurrences are rare, we found that excess emissions in Texas are frequent, sometimes large, and likely result in significant health damages for individuals living in communities near where these emissions are released.
Storage tanks in retention ponds are surrounded by floodwater left behind by Harvey at ExxonMobil's refinery in Baytown, Texas.
Photo: Tom Fox, MBR
Specifically, there are four important takeaways from our study.
First, excess emissions represent a sizeable share of permitted (or routine) emissions. In the case of the natural gas liquids industry, excess emissions amounted to 77 thousand tons over the period 2004-2015, representing 58 percent of the industry’s routine emissions for that pollutant.
Refineries emitted 23 thousand tons of excess emissions (10 percent of their routine emissions of SO2) while oil and gas fields released 11 thousand tons (17 percent of their routine emissions of SO2).
Second, the distribution of excess emissions is highly skewed. While thousands of excess emissions events occur every year in Texas, the top 5 percent of events release more pollutants than all the other events combined. In extreme cases, excess emissions events can release vast amounts of pollutants in a very short period of time.
In 2003, a Total oil refinery in Port Arthur emitted 1,296 tons of sulfur dioxide within 56 hours, due to a power outage caused by a lighting strike. That was almost twice the amount of the total sulfur dioxide that refinery emitted that year from its routine operations.
Third, several industrial sectors account for a disproportionate amount of excess emissions. Facilities in just five sectors – natural gas liquids, refineries, industrial organic chemicals, electric services and oil and natural gas fields – emit about 80 percent of all excess emissions from industrial facilities in Texas.
Moreover, a few facilities within each sector are responsible for the vast majority of excess emissions. For example, the top six oil refineries are responsible for 70 percent and 77 percent of the excess emissions of sulfur dioxide and carbon monoxide, respectively, released from all 30 Texas refineries.
Finally, excess emissions have important health effects. Using a model that links pollution to mortality, we estimate that the health damages attributable to excess emissions in Texas between 2004-2015 averaged $150 million annually. These estimates are certainly not comprehensive, as they only consider damages from premature mortality due to particulate matter (PM) emissions caused by the emission of sulfur dioxides and nitrogen oxides.
The model does not account for the direct damage from other pollutants or from nonfatal, acute health events such as asthma attacks. As such, our estimate can be considered a lower bound.
Beyond Texas
The data we analyzed in our study reveal the magnitude of the problem caused by excess emissions. Yet it is important to remember that they only capture the situation in Texas. We know very little about excess emissions and their trends over time at the national level. That’s because Texas is one of just a few states (the others being Louisiana and Oklahoma) that systematically track and make public information on these type of pollution releases.
The Texas Commission on Environmental Quality (TCEQ) has gone as far as to implement a system that requires facilities to publicly report excess emissions events within 24 hours of their occurrence, information that the TCEQ then makes available on its website.
Though Texas is unique in its reporting requirements, excess emissions events are common elsewhere, as the watchdog group the Environmental Integrity Project has documented in a series of reports.
Excess emissions are underregulated
The EPA, after decades of leaving excess emissions outside of its regulatory focus, made a concerted effort to update its approach during the final years of the Obama administration.
Prompted by a lawsuit brought by the Sierra Club, the EPA issued a State Implementation Plan (SIP) call in 2015, asking states to revisit the way they regulate excess emissions. The agency found that certain SIP provisions in 36 states were “substantially inadequate to meet Clean Air Act (CAA) requirements.”
This means that industrial facilities may have been regularly surpassing the limit of their permitted pollution limits, in part because of these excess emissions. But because of state agency exemption provisions, it could be the case that these facilities would not always be penalized. In other words, the EPA determined that many states had, as a matter of policy, often failed to treat excess emissions as violations and potentially shielded offending companies from paying fines.
The EPA is now revisiting its policy as part of the Trump administration’s broader efforts to scale back many of EPA regulations and decisions during the Obama era. Given the frequency, magnitude and important adverse effects for public health, the EPA’s ultimate decision on how states should treat excess emissions is consequential.
In addition, much is still to be learned about the magnitude of the excess emissions problem across the country. If an effective regulatory framework is to be designed to reduce them, it is imperative that more states begin tracking excess emissions events in a detailed and systematic way, following the example set by Texas.