Before its Port Arthur plant exploded, TPC Group had installed monitors
along the facility's fence line to detect fugitive air emissions of
butadiene — a highly flammable gas being produced there. The four
gas chromatographs and much of the settlement process was required to
complete the company's settlement with the U.S. federal officials
fined the plant in 2017 after an investigation found that the plant had
been releasing butadiene, a known human carcinogen, for more than three
years instead of burning it off.
Under the terms of the settlement agreement, TPC was required to monitor
butadiene levels outside of the 215-acre compound and post the results
every six months on a public website. If the readings exceeded the threshold
twice within an hour, TPC was expected to track down the pollution source
and take measures to reduce it. TPC implemented a similar monitoring program
at its Houston plant in the mid-2000s, which was part of an effort to
minimize butadiene emissions.
However, that is not the situation in Port Neches. The statements TPC posted
to its website, which are tucked away on a page that makes no notice of
the EPA arrangement and doesn't describe what the reports are. It
shows that the facility saw a notable addition last year in both the number
of butadiene emissions and the number of cases the company exceeded the
agreed-upon threshold. In many cases, the air toxicants exceeded the state's
recommended occupational standards for short-term exposure.
The surge in emissions emerged in the latter half of 2019 with the explosions
and fire at the plant a day before Thanksgiving that damaged multiple
workers, blew out windows in scores of nearby houses, and prompted extensive
evacuations during the holiday week. Despite the steps taken by the company
to lower the emissions to acceptable levels, they continued to escalate.
It is not established yet whether these increasing emissions are due to
the incident. This will not be known until investigators reveal the details.
The company identified the butadiene manufacturing component as the cause
of the initial explosion.
Air quality experts and scientists managing environmental groups who studied
the opinions said that the air monitoring data was alarming and should
have been a red flag for the EPA. The EPA said it had monitored the stories
but not conducted a trend analysis.
The levels they measured were high enough to appear shocking. This is an
indicator of the severity of difficulties at the plant. Since monitoring
for butadiene in the water started in February 2018, the company has not
consistently reported exceedances of the 25 parts per billion THMs thresholds
on its website until March 2019.
A spokesperson for the program said that a gap in the process led to confusion
about posting requirements and that the agency allowed the company to
extend the program to make up for the missing time. Recent studies were
conducted in October 2019. Overall, the eight months of statements from
March to October showed that butadiene concentrations exceeded average
levels of 4.5 hours a month.
The number and size of those failures began to rise during the summer months.
On July 22, two high levels were detected, one was 364 parts per billion
and 528 parts per billion. That is huge enough to produce health impacts
in people — state guidelines say that presentation to higher than
500 parts per billion of butadiene over 30 minutes to six hours may result
in symptoms that include irritation of the eyes and respiratory system.
(The state allows people to be exposed to 9.1 part per billion butadiene
for 70 years.
On August 9, the company reported 20 exceedances, with one reading reaching
223 parts per billion. This week, it said that the level of 805 parts
per billion was measured. The butadiene emissions peaked on September
27, which was a week after the factory reported ten exceedances. According
to the report, the spike occurred when a line of butadiene became isolated,
requiring workers to ventilate the gas. (Due to the predicament's
scope and nature, TPC was required to report the government's accident.)
Even though many exceedances did not decrease, they remained high throughout
September, the month before the fire and blast.
California-based air quality specialist Jim Tarr, a chemical engineer who
worked for TCEQ's predecessor agency in the 1970s, said the opinions
indicate the facility was experiencing an unusual number of fugitive emissions
— and that those leaks produced in an impressive amount of airborne
butadiene at the facility's fence line.
There has been numerous mechanical failure after mechanical failure after
mechanical failure, which suggests either that the machinery is not being
cared for or worn out. While many of the releases were high enough to
pose an explosion hazard, they were not large enough to pose a risk of
explosion to humans at a fenceline. Butadiene can disperse rapidly into
the air, leading to higher levels in the area once the leaks were discovered.
That the EPA or TCEQ, which is primarily responsible for enforcing federal
clean air laws in Texas, was responsible for recognizing the trend as
a warning sign and investigating further. In a statement, the EPA has
stated it reviewed TPC's interpretation of its fenceline monitoring
program, but EPA has not conducted trend analysis of the fenceline monitoring program.
Before the November 2019 incident, the EPA periodically evaluated individual
reports to determine whether they met the agreement's terms, specifically
whether the reports included identifying a root cause and corrective action.
The agency said it had found nothing in the information or the disciplinary
actions that have indicated an immediate safety concern.
The EPA and Texan authorities were scheduled to inspect the plant on December
9 but were forced to postpone it after major explosions and fire. The
event will be rescheduled when the airport operations resume.
According to the TCEQ, they are still investigating the incident and anticipate
that a lawsuit will arise. The director directed a further inquiry to
the Texas Attorney General, who has subsequently taken up the case.
In response to the investigation, TPC spokeswoman Sara Cronin says it is
too early in the product recall process to determine the cause. The U.S.
Coast Guard and Texas EPA are investigating the incident, and TPC Group
is cooperating fully with all federal and state agencies. The statement
explained that the investigation into the cause of the explosion is continuing.
TPC installed monitors on its Houston plant's fenceline after the facility
was identified as the source of high butadiene emissions that led to nearby
residents' health effects.
Then known as Texas Petrochemicals, TPC struck an agreement with the TCEQ
in June 2005, a year after it occurred from bankruptcy, amid strict media
coverage and pressure from city leaders to voluntarily lower butadiene
levels at the plant's fence line to 1 part per billion by the conclusion
of 2007 and zero soon after, according to a Houston Chronicle report.
The article explained that concentrations in fences, which border some
backyards, can be higher than three parts per billion and lower than ten
parts per billion.
The EPA's website shows that a company could reduce butadiene emissions
by 78% in 15 years and describes a fenceline monitoring system as an excellent
diagnostic tool. However, the fenceline reports are just one of many indications
about TPC's Port Neches facility problems. She is a senior director
at the Environmental Defense Fund and previously worked at the Environmental
Defense Fund.
State documents show TPC typically states emitting increased air pollution
than allowed under its government-issued operating permits, which happened
more than 50 times over the past ten years. The state has fined it after
finding some of the emissions events were avoidable. Federal agencies
fined the company for air pollution and safety violations.
According to Craft and others who closely track air quality in the region,
they were unaware of the TPC's air monitoring reports before the news
reporters pointed them out. These reports describe poor company performance.
The organization's track record indicates a significant risk of an
incident occurring, and the state agency should have acted preemptively,
and it didn't.
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