Public Citizen Testimony in Support of HB 1341 — Hydrogen Sulfide Limits
Public Citizen Testimony in Support of HB 1341 -- Hydrogen Sulfide Limits
To: Chairman Brooks Landgraf and the Members of the House Committee on Environmental Regulation
CC: Vice-Chair Claudia Ordaz, Rep. Rafael Anchía, Rep. Keith Bell, Rep. Ben Bumgarner, Rep. Penny Morales Shaw, Rep. Tom Oliverson, Rep. Ron Reynolds, Rep. Steve Toth
Via hand delivery and by email.
From: Adrian Shelley, Public Citizen, ashelley@citizen.org, 512-477-1155
Re: HB 1341, hydrogen sulfide limit – Public Citizen testimony in support
Dear Chairman Landgraf and Members of the Committee:
On behalf of our approximately 30,000 members in Texas, Public Citizen appreciates the opportunity to testify in support of HB 1341 relating to establishment of maximum allowable ground level concentrations of hydrogen sulfide by the Texas Commission on Environmental Quality.
Summary of our support for HB 1341:
- Hydrogen sulfide exposure is dangerous and has repeatedly killed in Texas.
- Many Texans live near wells high in H2S.
- The TCEQ’s current standard for H2S is too high.
- A new, lower standard would protect Texans and potentially save lives.
Hydrogen sulfide is deadly.
Simply put: hydrogen sulfide is deadly. It has killed people in Texas, repeatedly.
Hydrogen sulfide is dangerous to health and life at 100 parts per million (ppm). It is fatal in minutes at 500 ppm.1
On October 10, 2024, two contract workers at the Deer Park refinery now owned by Pemex were killed and 13 more were injured when 27,000 pounds of hydrogen sulfide leaked from a pipeline transporting the gas.2
On October 26, 2019, an oilfield worker and his wife were killed after he investigated a hydrogen sulfide leak and his wife followed to check on him.3 They left behind two children.
In 1975 a hydrogen sulfide leak in the oil field near Denver City led to the death of nine.4
A well blowout in Representative Reynolds’ district exposed his constituents to hydrogen sulfide.
In 2017 an oil well blowout in Missouri City outside of Houston led to an air pollution release that included hydrogen sulfide.5 Hydrogen sulfide smells strongly of rotten eggs and the odor threshold is between 0.0005 to 0.3 ppm.6 The well blowout caused people across the region to smell the distinctive odor of hydrogen sulfide. It was some time before air monitoring was done in the area, but it seems very likely that dangerous concentrations of H2S were present.
A 2024 analysis by the Houston Chronicle found that 78,000 Texans live within a half mile of an oil or gas well that is high in H2S.7
HB 1341 requires the TCEQ to develop maximum allowable ground level concentrations of hydrogen sulfide.
This bill directs the TCEQ to develop by rule maximum allowable ground level concentrations of hydrogen sulfide. The bill sets an upper bound for hydrogen sulfide releases in concentrations of 0.04 parts per million (ppm) for residential, recreational, business, or commercial properties and 0.06 ppm for all other land uses. These concentrations are appropriately fixed just below the minimal risk level for acute exposure (anything under 14 days) of 0.07 ppm, set by the Agency for Toxic Substances and Disease Registry (ATSDR).8
TCEQ currently has a state regulatory standard for hydrogen sulfide of 0.08 ppm for residential, business or commercial property.9 The agency currently uses this standard as its short-term effects screening level.10 According to the TCEQ, effects screening levels “are chemical-specific air concentrations set to protect human health and welfare and are used for air permitting.”11 TCEQ states that ESLs are intended to be 70 per cent lower than the safe level of a pollutant.
Given that the ATSDR level for H2S acute exposure is 0.07 ppm, we think the current state regulatory standard—which is serving as the ESL by default—is too high.
We recommend the committee pass HB 1341 so that the TCEQ can establish a more health-protective standard for hydrogen sulfide.