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Air Pollution From Industrial Shutdowns and Startups a Grave Danger to Public Health

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By Nikolaos Zirogiannis, Alex J. Hollingsworth and David Konisky

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.

However, 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 U.S. Environmental Protection Agency ( 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. The state 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.

Although 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.

Specifically, there are four important takeaways from our study.

First, excess emissions represent a sizable share of permitted (or routine) emissions. In the case of the natural gas liquids industry, excess emissions amounted to 77,000 tons over the period 2004-2015, representing 58 percent of the industry's routine emissions for that pollutant. Refineries emitted 23,000 tons of excess emissions (10 percent of their routine emissions of SO2) while oil and gas fields released 11,000 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.

Estimated damages from air toxics from excess emissions by county. Reprinted with permission. Copyright (2018) American Chemical Society. Figure compiled by the authors using data from TCEQ, EASIUR, QGIS and Manson et al (2017)

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.

Although 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 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.

Reposted with permission from our media associate The Conversation.

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By Sherry H-Y. Chou, Aarti Sarwal and Neha S. Dangayach

The patient in the case report (let's call him Tom) was 54 and in good health. For two days in May, he felt unwell and was too weak to get out of bed. When his family finally brought him to the hospital, doctors found that he had a fever and signs of a severe infection, or sepsis. He tested positive for SARS-CoV-2, the virus that causes COVID-19 infection. In addition to symptoms of COVID-19, he was also too weak to move his legs.

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We are neurologists specializing in intensive care and leading studies related to neurological complications from COVID-19. Given the occurrence of Guillain-Barre Syndrome in prior pandemics with other corona viruses like SARS and MERS, we are investigating a possible link between Guillain-Barre Syndrome and COVID-19 and tracking published reports to see if there is any link between Guillain-Barre Syndrome and COVID-19.

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What Is Guillain-Barre Syndrome?

Guillain-Barre syndrome occurs when the body's own immune system attacks and injures the nerves outside of the spinal cord or brain – the peripheral nervous system. Most commonly, the injury involves the protective sheath, or myelin, that wraps nerves and is essential to nerve function.

Without the myelin sheath, signals that go through a nerve are slowed or lost, which causes the nerve to malfunction.

To diagnose Guillain-Barre Syndrome, neurologists perform a detailed neurological exam. Due to the nerve injury, patients often may have loss of reflexes on examination. Doctors often need to perform a lumbar puncture, otherwise known as spinal tap, to sample spinal fluid and look for signs of inflammation and abnormal antibodies.

Studies have shown that giving patients an infusion of antibodies derived from donated blood or plasma exchange – a process that cleans patients' blood of harmful antibodies - can speed up recovery. A very small subset of patients may need these therapies long-term.

The majority of Guillain-Barre Syndrome patients improve within a few weeks and eventually can make a full recovery. However, some patients with Guillain-Barre Syndrome have lingering symptoms including weakness and abnormal sensations in arms and/or legs; rarely patients may be bedridden or disabled long-term.

Guillain-Barre Syndrome and Pandemics

As the COVID-19 pandemic sweeps across the globe, many neurologic specialists have been on the lookout for potentially serious nervous system complications such as Guillain-Barre Syndrome.

Though Guillain-Barre Syndrome is rare, it is well known to emerge following bacterial infections, such as Campylobacter jejuni, a common cause of food poisoning, and a multitude of viral infections including the flu virus, Zika virus and other coronaviruses.

Studies showed an increase in Guillain-Barre Syndrome cases following the 2009 H1N1 flu pandemic, suggesting a possible connection. The presumed cause for this link is that the body's own immune response to fight the infection turns on itself and attacks the peripheral nerves. This is called an "autoimmune" condition. When a pandemic affects as many people as our current COVID-19 crisis, even a rare complication can become a significant public health problem. That is especially true for one that causes neurological dysfunction where the recovery takes a long time and may be incomplete.

The first reports of Guillain-Barre Syndrome in COVID-19 pandemic originated from Italy, Spain and China, where the pandemic surged before the U.S. crisis.

Though there is clear clinical suspicion that COVID-19 can lead to Guillain-Barre Syndrome, many important questions remain. What are the chances that someone gets Guillain-Barre Syndrome during or following a COVID-19 infection? Does Guillain-Barre Syndrome happen more often in those who have been infected with COVID-19 compared to other types of infections, such as the flu?

The only way to get answers is through a prospective study where doctors perform systematic surveillance and collect data on a large group of patients. There are ongoing large research consortia hard at work to figure out answers to these questions.

Understanding the Association Between COVID-19 and Guillain-Barre Syndrome

While large research studies are underway, overall it appears that Guillain-Barre Syndrome is a rare but serious phenomenon possibly linked to COVID-19. Given that more than 10.7 million cases have been reported for COVID-19, there have been 10 reported cases of COVID-19 patients with Guillain-Barre Syndrome so far – only two reported cases in the U.S., five in Italy, two cases in Iran and one from Wuhan, China.

It is certainly possible that there are other cases that have not been reported. The Global Consortium Study of Neurological Dysfunctions in COVID-19 is actively underway to find out how often neurological problems like Guillain-Barre Syndrome is seen in hospitalized COVID-19 patients. Also, just because Guillain-Barre Syndrome occurs in a patient diagnosed with COVID-19, that does not imply that it was caused by the virus; this still may be a coincident occurrence. More research is needed to understand how the two events are related.

Due to the pandemic and infection-containment considerations, diagnostic tests, such as a nerve conduction study that used to be routine for patients with suspected Guillain-Barre Syndrome, are more difficult to do. In both U.S. cases, the initial diagnosis and treatment were all based on clinical examination by a neurological experts rather than any tests. Both patients survived but with significant residual weakness at the time these case reports came out, but that is not uncommon for Guillain-Barre Syndrome patients. The road to recovery may sometimes be long, but many patients can make a full recovery with time.

Though the reported cases of Guillain-Barre Syndrome so far all have severe symptoms, this is not uncommon in a pandemic situation where the less sick patients may stay home and not present for medical care for fear of being exposed to the virus. This, plus the limited COVID-19 testing capability across the U.S., may skew our current detection of Guillain-Barre Syndrome cases toward the sicker patients who have to go to a hospital. In general, the majority of Guillain-Barre Syndrome patients do recover, given enough time. We do not yet know whether this is true for COVID-19-related cases at this stage of the pandemic. We and colleagues around the world are working around the clock to find answers to these critical questions.

Sherry H-Y. Chou is an Associate Professor of Critical Care Medicine, Neurology, and Neurosurgery, University of Pittsburgh.

Aarti Sarwal is an Associate Professor, Neurology, Wake Forest University.

Neha S. Dangayach is an Assistant Professor of Neurology and Neurosurgery, Icahn School of Medicine at Mount Sinai.

Disclosure statement: Sherry H-Y. Chou receives funding from The University of Pittsburgh Clinical Translational Science Institute (CTSI), the National Institute of Health, and the University of Pittsburgh School of Medicine Dean's Faculty Advancement Award. Sherry H-Y. Chou is a member of Board of Directors for the Neurocritical Care Society. Neha S. Dangayach receives funding from the Bee Foundation, the Friedman Brain Institute, the Neurocritical Care Society, InCHIP-UConn Center for mHealth and Social Media Seed Grant. She is faculty for emcrit.org and for AiSinai. Aarti Sarwal does not work for, consult, own shares in or receive funding from any company or organization that would benefit from this article, and has disclosed no relevant affiliations beyond their academic appointment.

Reposted with permission from The Conversation.


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"We've moved the needle a lot, especially on environmental justice and upping Biden's ambition," said Sunrise Movement co-founder and executive director Varshini Prakash, a member of the Biden-Sanders Climate Task Force. "But there's still more work to do to push Democrats to act at the scale of the climate crisis."

The climate panel—co-chaired by Rep. Alexandria Ocasio-Cortez (D-N.Y.) and former Secretary of State John Kerry—recommended that the Democratic Party commit to "eliminating carbon pollution from power plants by 2035," massively expanding investments in clean energy sources, and "achieving net-zero greenhouse gas emissions for all new buildings by 2030."

In a series of tweets Wednesday night, Ocasio-Cortez—the lead sponsor of the House Green New Deal resolution—noted that the Climate Task Force "shaved 15 years off Biden's previous target for 100% clean energy."

"Of course, like in any collaborative effort, there are areas of negotiation and compromise," said the New York Democrat. "But I do believe that the Climate Task Force effort meaningfully and substantively improved Biden's positions."

 

The 110 pages of policy recommendations from the six eight-person Unity Task Forces on education, the economy, criminal justice, immigration, climate change, and healthcare are aimed at shaping negotiations over the 2020 Democratic platform at the party's convention next month.

Sanders said that while the "end result isn't what I or my supporters would've written alone, the task forces have created a good policy blueprint that will move this country in a much-needed progressive direction and substantially improve the lives of working families throughout our country."

"I look forward to working with Vice President Biden to help him win this campaign," the Vermont senator added, "and to move this country forward toward economic, racial, social, and environmental justice."

Biden, for his part, applauded the task forces "for helping build a bold, transformative platform for our party and for our country."

"I am deeply grateful to Bernie Sanders for working with us to unite our party and deliver real, lasting change for generations to come," said the former vice president.

On the life-or-death matter of reforming America's dysfunctional private health insurance system—a subject on which Sanders and Biden clashed repeatedly throughout the Democratic primary process—the Unity Task Force affirmed healthcare as "a right" but did not embrace Medicare for All, the signature policy plank of the Vermont senator's presidential bid.

Instead, the panel recommended building on the Affordable Care Act by establishing a public option, investing in community health centers, and lowering prescription drug costs by allowing the federal government to negotiate prices. The task force also endorsed making all Covid-19 testing, treatments, and potential vaccines free and expanding Medicaid for the duration of the pandemic.

"It has always been a crisis that tens of millions of Americans have no or inadequate health insurance—but in a pandemic, it's potentially catastrophic for public health," the task force wrote.

Dr. Abdul El-Sayed, a former Michigan gubernatorial candidate and Sanders-appointed member of the Healthcare Task Force, said that despite major disagreements, the panel "came to recommendations that will yield one of the most progressive Democratic campaign platforms in history—though we have further yet to go."

 

Observers and advocacy groups also applauded the Unity Task Forces for recommending the creation of a postal banking system, endorsing a ban on for-profit charter schools, ending the use of private prisons, and imposing a 100-day moratorium on deportations "while conducting a full-scale study on current practices to develop recommendations for transforming enforcement policies and practices at ICE and CBP."

Marisa Franco, director of immigrant rights group Mijente, said in a statement that "going into these task force negotiations, we knew we were going to have to push Biden past his comfort zone, both to reconcile with past offenses and to carve a new path forward."

"That is exactly what we did, unapologetically," said Franco, a member of the Immigration Task Force. "For years, Mijente, along with the broader immigrant rights movement, has fought to reshape the narrative around immigration towards racial justice and to focus these very demands. We expect Biden and the Democratic Party to implement them in their entirety."

"There is no going back," Franco added. "Not an inch, not a step. We must only move forward from here."

Reposted with permission from Common Dreams.