Sign onto Hydrogen Sulfide Petition to EPA

["Alex J. Sagady & Associates" <ajs@sagady.com>]

I wanted to pass this request from Neil Carman, Sierra Club 
in Texas, to the list (which I've not seen on air-mail or dioxin-l)

Please respond directly to neil_carman@greenbuilder.com

====================================

X-From_: notes@igc.org Wed Jan 13 13:35:35 1999
Date: 13 Jan 1999 09:22:19
Reply-To: Conference "env.justice" <ecojustice@igc.apc.org>
From: Neil_Carman@greenbuilder.com
Subject: SIGN ON to H2S letter to EPA
To: Recipients of conference <ecojustice@igc.apc.org>
X-Gateway: conf2mail@igc.apc.org
Errors-To: owner-ecojustice@igc.apc.org
Lines: 408

GROUPS TO SIGN LETTER TO EPA  ASKING THAT HYDROGEN SULFIDE (H2S smells like
rotten eggs!) BE LISTED AS A  HAZARDOUS AIR POLLUTANT


***************SIGN ON DEADLINE: JANUARY 25, 1999**********

Include your name, organization, city, and 
state and send to: neil_carman@greenbuilder.com

The Galveston-Houston Association for Smog Prevention (GHASP) and Neil Carman,
PhD, have drafted a letter to EPA's Carol Browner as a first step to seek that
an exceptionally toxic substance--Hydrogen Sulfide (H2S)--be formally listed
under section 112(b) of the CAA as a Hazardous Air Pollutant. Hydrogen sulfide
was left off the Title III list in 1990 due to pressures on Congress and EPA by
the oil & gas industry, among others.

Hydrogen sulfide is also called POISON GAS, SOUR GAS and ROTTEN EGG GAS. It is
one of the most commonly occurring toxic air pollutants and is instantly deadly
at or above 800 ppm. But its poorly regulated at much lower levels.

The EPA has ignored the chronic toxicity of H2S at low levels of the gas, and
new medical evidence supports that even low level exposures can cause
irreversible damage to the brain and central nervous system. And this is only
one example of damage from H2S.


############################################################################
##################################################

___

January 25, 1999

The Honorable Carol Browner
Administrator, U.S. EPA
401 M Street, SW
Washington, DC 20460

Dear Administrator Browner:

The many public health, environmental, and public interest organizations
named below join with the Galveston-Houston Association for Smog Prevention
in requesting that you act in your capacity as Administrator of the US
Environmental Protection Agency to list hydrogen sulfide (H2S) formally as a
hazardous air pollutant (HAP) as defined in Title III, section 112(b) of the
Clean Air Act Amendments (CAA) of 1990. 

Hydrogen sulfide, often referred to as "poison gas" because of its lethal
nature, is probably the most common toxic air pollutant in urban and rural
communities. It is easily identified by its distinct odor of rotten eggs. At
least 73 industry categories routinely emit hydrogen sulfide. A broad range
of chronic, adverse health effects are associated with hydrogen sulfide
exposure, including exposures at relatively low levels. Recently the gas has
become a controversial issue in confined animal feeding operations (CAFOs).


Congress and the 1990 CAA study—Hydrogen Sulfide Report to Congress 

As you know, Congress considered listing hydrogen sulfide in 1990 as a
hazardous air pollutant under CAA section 112(b), which regulates industrial
sources having routine emissions of HAPs. Listing was forestalled, however,
by intense lobbying led by the oil and gas industry. The EPA Administrator
was instead directed by Congress in 1990—under section 112(n)(5) of the
CAA—to carry out a study "to assess the hazards to public health and the
environment resulting from the emissions of H2S associated with the
extraction of oil and natural gas." This requirement to study hydrogen
sulfide was added to the CAA by the Senate Committee on Environment and
Public Works, chaired by the late Quentin N. Burdick of North Dakota,
because of concern about the health and environmental hazards associated
with H2S emissions from oil and gas wells. Witnesses testified before
Congress in 1990 that emissions related to the extraction and refining of
oil and natural gas had resulted in deterioration of air quality, death and
injury to livestock, and evacuation and hospitalization of residents located
near the release point of such emissions. 
 
The conclusions of the EPA study became the Report to Congress on Hydrogen
Sulfide Air Emissions Associated with the Extraction of Oil and Natural Gas
(hereafter referred to as the Report to Congress), issued in October 1993 by
the EPA Office of Air Quality Planning and Standards (EPA-453/R-93-045). The
status since 1990 of H2S as a regulated air toxic is well described in the
Executive Summary of the Report to Congress:

[O]n the basis of information contained in accident records, it was
determined at the time that H2S is a chief concern from an accidental
release standpoint and it would be listed under the accidental release
provisions in section 112(r) of the CAA, but not under section 112(b).
Substances regulated under 112(r) are known or may be anticipated to cause
death, injury, or serious adverse effects to human health or the environment
upon accidental release.

The executive summary of the Report to Congress emphasizes that "the
[further] assessment of H2S must include a review of existing State and
industry control standards, techniques, and enforcement," but we are not
aware of an ongoing EPA effort in this area.

We agree that the 112(r) approach to H2S is necessary. Several deaths occur
each year in the U.S. from accidental exposure to instantaneously lethal
quantities of H2S. However, we also believe the weight of medical evidence
strongly indicts H2S as a serious human health hazard even at low levels of
exposure. Concerns about chronic, low-level emissions of H2S are founded on
its exceptional toxicity at low concentrations and its widespread occurrence
in the diverse industries that rely upon processes using sulfur, sulfur
compounds, or other substances (such as oil and natural gas) containing
significant sulfur as a natural contaminant. Since the EPA submitted the H2S
Report to Congress in October 1993, the agency has not—to our
knowledge—undertaken additional reviews or action to address widespread
public health concerns about exposure to H2S in low concentrations. 


Other Common Sources of H2S

The Report to Congress on Hydrogen Sulfide Air Emissions Associated with the
Extraction of Oil and Natural Gas did not compile data concerning H2S
emissions from other industrial source categories; however, common sources
of H2S include the following: 1) crude oil petroleum refineries (primarily sour
crude oil); 2) pulp and paper mills; 3) paper production; 4) municipal sewage
treatment plants; 5) large hog farms-livestock operations (CAFOs); 6) sour
natural gas processing plants; 7) sour crude oil/sour natural gas handling
stations/bulk petroleum terminals; 8) oil and gas production; 9) oil/gas
transmission
plants; 10) bulk storage and pipelines; 11) Portland cement kilns; 12)
municipal
waste landfills; 13) coke ovens; 14) coal gasification plants; 15) tanneries;
16)
slaughterhouses and rendering plants; 17) geothermal power plants; 18) sulfur
products and hydrogen sulfide production; 19) animal fat and oil processing;
20) asphalt storage facilities; 21) blast furnaces, breweries and fermentation 
processes; 22) fertilizer production; 23) glue making; and 24) metal processing
(gold
ore, lead ore, lead removal, copper ore sulfidizing and metallurgy); 25) barium
carbonate and
barium salt production; 26) - 46) miscellaneous manufacturing processes
including the
manufacture of carbon disulfide, dyemaking, textile printing, thiophene
production, sulfur production, soap production, phosphate purification,
hydrochloric acid purification, cellophane production, rubber and plastics
processing, soap making, silk making, rayon making, pyrite burning,
photoengraving, synthetic fibers, polysulfide caulking production,
bromide-bromine, artificial flavor making, and refrigerant making; and 47) -
50) fish,
sugar beet and sugar cane processing, as well as other miscellaneous sources.


General information about the toxicity of hydrogen sulfide

Hydrogen sulfide is similar to cyanide in toxicity. It interferes with the
enzyme cytochrome oxidase, which is necessary for cells to make use of
oxygen (1, 2). How does H2S enter the body? There are three routes: (1)
inhalation: from breathing vapors absorbed through the lungs; (2) oral: from
ingestion of contaminated substances (especially water), absorbed through
the intestinal tract; and (3) skin: from contact with contaminated
substances (such as air), absorbed through the skin. The main route of
absorption of H2S is through inhalation. 

Animal studies of H2S show widespread distribution in the body after
inhalation exposures (3, 4), with a selective distribution to the brain stem
compared with other areas of the brain (5). Research in animals has
identified more than forty health effects of H2S. Data demonstrates that
numerous similar health effects occur in human exposure to H2S. Metabolism
takes place by three pathways: oxidation to sulfate, methylation, and
reaction with metallo- or disulfide- containing proteins. This last appears
to be the main pathway for toxicity (6). 

Human populations most sensitive to H2S are assumed to be the fetus (animal
data only), children (7), persons with heart disease (8), individuals with
asthma (9), individuals who metabolize organosulfides differently (10, 11,
as reviewed in 12), and persons consuming alcohol (13, 14). 


Medical information about H2S toxicity and chronic exposure at low level
concentrations

Hydrogen sulfide's toxicity at the 800-1,000 parts per million level (and
higher) is well documented as being instantaneously lethal to exposed human
beings. Hydrogen sulfide works by rapidly interfering with the brain's
respiratory command center (sending nerve signals to the lungs) and
poisoning the blood's oxygen carrying ability, but long-term, low-level or
chronic exposures have been generally considered to be less toxic and less
harmful. 
 
The driving regulatory assumption has been that if an exposure to H2S is not
fatal, there are few, if any, lasting health effects. But that assumption is
medically outdated. Four public health scientists—including Kaye Kilburn,
Ph.D., University of Southern California School of Medicine, and Marvin
Legator, Ph.D., University of Texas Medical Branch-Galveston—participated on
an H2S panel at the American Public Health Association's annual meetings
November 11, 1997, in Indianapolis, Indiana, to present and discuss
groundbreaking research findings demonstrating the extraordinarily toxic
nature of H2S at the chronic, low levels to which communities across the
nation are routinely exposed. This public health research supports the
thesis that exposure to hydrogen sulfide, even in extremely low
concentrations, can cause lasting damage to the nervous system.

Kaye Kilburn, PhD, is a public health scientist who has been conducting
research on the health effects of exposure to H2S for many years (18, 19,
20). Describing a new study, he unequivocally stated at the conference that
"H2S poisons the brain, and the poisoning is irreversible" (21, 23).
Demonstrable symptoms of chronic exposure include pronounced deficits in
balance and reaction time, as well as such ailments as dizziness, insomnia,
and overpowering fatigue. 

Marvin Legator, Ph.D., and his associate Chantele Singleton have used a
carefully designed "symptom survey" to evaluate adverse health effects
associated with H2S (1, 21). In one study, they administered the survey to
97 residents living within four miles of a large geothermal electric power
plant in Hawaii, the Puna Geothermal Venture (PGV). PGV produces electricity
from subsurface volcanic heat and releases hydrogen sulfide as a waste
byproduct. Eighty-six percent of the subjects indicated that they had
experienced central nervous system impairment of the sort described by Dr.
Kilburn's research. But only 26% of those in a control group—people who live
some 20 miles away from the plant—reported such problems (1, 21, 22). 

According to the several studies of these researchers, in chronic, low level
exposures, one may observe abnormal neurobehavioral functioning and altered
mood states (e.g., depression, fatigue, tension, vigor) (1). In addition,
numerous CNS-brain effects occur including: changes in brain density,
headache, memory loss, reduced sense of smell, loss of balance, dizziness,
sleep difficulties, and fatigue (1). Numerous cases reported in the
literature support the CNS toxicity of H2S (1). Many of the effects are
persistent (15, 16, 17). 

These health studies confirm the need for the EPA to list H2S under section
112(b) of the CAA and Title III, since more routine exposure effects—on a
daily basis—are not addressed under the accidental release provisions in
section 112(r) of the CAA where H2S is currently regulated. Section 112(r)
is not designed or intended to address daily exposures at sublethal
concentrations, but section 112(b) can bridge this gap.
 

Children and the EPA's new policy designed to set protective standards for our
youngest

As you know, President Clinton’s Executive Order of October 1995 puts a new
priority on the protection of children, since pollution standards are
generally not designed to protect our children from such environmental
insults as ambient H2S. Children are more vulnerable than adults to H2S,
first because they breathe more rapidly, taking in significantly more
pollution per pound of body weight than do adults. A resting infant, for
example, inhales twice as much air, relative to its size, as does a resting
adult. Second, national data show that children spend an average of about
50% more time outdoors than adults. Third, children are three times more
active while outdoors than adults, engaged in sports and other vigorous
activities; this increased activity raises breathing rates and significantly
increases inhalation and in some cases swallowing of pollutants. Fourth,
children are particularly vulnerable to toxic substances because their
bodies are immature and rapidly growing. Fifth, children are in their prime
learning years and H2S exposure causes brain damage. These are just a few
critical reasons why EPA needs to move on H2S and provide better protection
for the nation’s children. The impairment of mental faculties in a child
amounts to a lifetime of harm.


Environmental justice and hydrogen sulfide

We also wish to impress upon the EPA its obligation fully to comply with and
enforce Title VI of the Civil Rights Act of 1964, together with President
Clinton's February 11, 1994, Executive Order No. 12898 concerning
environmental justice. 

We specifically request that the EPA seriously consider that H2S exposure
frequently creates or contributes to a disproportionate air toxics burden
for people of color and low-income populations. The residents of many
neighborhoods surrounding at least one major H2S industrial source
category—the approximately one hundred and sixty-five petroleum refineries
throughout the US—are typically low income. A preliminary survey by the
Galveston-Houston Association for Smog Prevention also shows that in several
leading petroleum refining states in different EPA regional jurisdictions
(mainly in regions 2, 3, 4, 5, 6, 9 and 10), a majority of residents in
refinery neighborhoods are people of color. 

Environmental justice is a grave need and major issue for dozens of refinery
communities in Texas, Louisiana, California, Illinois, Pennsylvania, New
Jersey, Indiana, Ohio, Kentucky, Alabama, Tennessee, and Mississippi, which
contain the bulk of the nation's refineries, and where we stress that
residents in refinery communities are dispropor-tionately poor people of
color. But besides the petroleum refining sector, several other industrial
source categories are located in communities where people of color
disproportionately reside. 
 

Diurnal variation measured in hydrogen sulfide concentrations

Researchers have confirmed what citizens in impacted communities have known
for years: The odor of H2S in neighborhoods is significantly worse at night
(24). Tarver and Dasgupta conducted field studies on variation in H2S from
day to night. They observed:

At all locations, H2S concentrations consistently exhibited a strong diurnal
pattern, with nighttime maxima in the range of 1-5 ppbv followed by rapid
abatement at sunrise. By 10-11 AM, H2S levels fell below the instrument
detection limit of 200 pptv (24). 

Like other polluting gases, H2S does not generally disperse as efficiently
at night, with its cooler air temperatures. For residents in impacted
communities, this diurnal pattern carries the implication that by far the
worst H2S exposures are occurring when families are most likely to be at
home and windows may be open (often because many houses in low-income
communities lack air conditioning). Night also tends to be the time when
state and local regulatory agencies are least likely to be available to
verify nuisance conditions, conduct H2S ambient air sampling, and attempt to
track down the H2S source in efforts to obtain compliance. 


Conclusion

Public health scientists now recognize that hydrogen sulfide is a potent
neurotoxin, and that chronic exposure to even low ambient levels causes
irreversible damage to the brain and central nervous system. Children are
among the most susceptible to this poison gas. It is unacceptable for
communities to have to continue suffering the ill effects of H2S when the
technology to control H2S emissions is available and affordable. As EPA has
learned, environmental justice is a significant fact of life for thousands
of communities in this nation and these residents all have a right to clean,
safe air.

It's past time for the EPA to take action to acknowledge hydrogen sulfide's
serious toxicity. As Administrator, you have discretionary authority under
the CAA to do the right thing based on the medical evidence. Please respond
to this request, made by the Galveston-Houston Association for Smog
Prevention on the behalf of the following organizations, with the good news
that the EPA will take action formally to list H2S under section 112(b) of
the CAA.


Respectfully yours,


Ronald J. Parry, Ph.D.
President, Galveston-Houston Association for Smog Prevention
& Professor of Chemistry, Rice University
 


Neil J. Carman, Ph.D.
Technical Consultant, Galveston-Houston Association for Smog Prevention
& Clean Air Program Director, Lone Star Chapter, Sierra Club



Ken Kramer, Ph.D.
Director, Lone Star Chapter, Sierra Club


[& additional cosigners]


 
REFERENCES
1.  Morris, DL, and MS Legator: Hydrogen Sulfide, October 1996, privately
circulated draft presentation.
2.  Smith, RP, and RE Gosselin: 1979, J Occupational Medicine 21:93-7.
3.  Nagata, T, et al: 1990, J Forensic Science 35:706-12.
4.  Voight, GE, and P Muller: 1955, Acta Histochem 1:223-39, as reviewed by 
Beauchamp, RP Jr, et al: 1984, CRC Crit Rev Toxicol 13:25-96.
  5.   Warenycia. MW, et al: 1989, Biochem Pharm 38:973-81.
  6.   Beauchamp, RP Jr, et al: op cit.
  7.   Dales, RE, et al: 1989, Am Rev Respir Dis 139:595-600.
  8.   Jappinen, P, and S Tola: 1990, Br J Ind Med 47:259-62.
  9.   Jappinen, P, et al: 1990, Br J Ind Med 47:824-8.
10.   Mitchell, SC, et al: 1984, Br J Clin Pharm 18:507-21.
11.   Harris, CM, et al: 1986, Lancet 1:492-3.
12.   Guidotti, TL: 1994, Int Arch Occup Env Health 66:153-60.
13.   Beck, JF, et al: 1979, Toxicol Lett 3:311-13.
14.   Poda, G,and SC Aiken: 1966, Arch Env Health 12:795-800.
15.   Wasch, et al: 1989, Arch Neurol 46:902-4.
16.   Tvedt, B, et al: 1991, Acta Neurol Scand 84:348-51.
17.   Tvedt, B, et al: 1991, Am J Ind Med 20:91-101.
18.   Kilburn, KH: 1997, Panel on Hydrogen Sulfide, American Public Health
Association's annual meetings, November 11, 1997, Indianapolis, Indiana.
19.   Kilburn, KH,:1993, Am J Med Sci 306:301-5.
20.   Kilburn, KH, and RH Warshaw: 1995, Tox Ind Health 11:185-96.
21.   Legator, MS, and C Singleton: 1997: Panel on Hydrogen Sulfide, American
Public Health Association's annual meetings, Indianapolis, Indiana.
22.    Morris, J: New alarm over hydrogen sulfide—Researchers document
lasting damage 
 to human nervous system. A three-part investigative report, Houston
 Chronicle, November 1997.
23.    Borda, B: 1997, Panel on Hydrogen Sulfide, American Public Health
Association's 
annual meetings, Indianapolis, Indiana.
24.   Tarver, GA, and PK Dasgupta: 1997, Environ Sci Tech 31:3669-3676.


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