Smog
Groups Sue Over Fracking Causing Rural Utah Smog Problem
Last week five groups, including Utah Physicians for a Healthy Environment, EarthJustice, and the Southern Utah Wilderness Alliance sued the EPA for not classifying the Uintah Basin as a "non-attainment area" for the new federal ozone standard despite having plenty of evidence that the gas mining region is routinely experiencing some of the worst smog in the country.
"It was once considered strictly a summertime problem in big cities. But winter pollution readings from the oil and gas fields of Wyoming and eastern Utah in the past seven years have shown the pollutants that create ozone— nitrogen oxides and volatile organic compounds — can also cause problems in snowy, rural areas.
Monitoring data in the Uintah Basin collected between 2009 and 2011 shows violations of federal health limits on ground-level ozone, which are set at 75 parts per billion. In 2010 and 2011, ozone levels rose as high as 121 parts per billion and 139 parts per billion, respectively."
To most of us this would mean the area is indeed due a non-attainment designation and should be required to draw up a plan to bring smog levels down. But to EPA, this only means the area is "unclassifiable," and it can put off that planning. That's why the groups are suing. And that's why it doesn't pay to think the EPA is taking care of everything.
But think about how this situation tests the claims of the gas industry operators.
In a previously pristine environment, without any cars or other kinds of heavy industry, they've now created smog on par with Los Angeles and Houston in the middle of extremely rural Utah…in the wintertime! They say they don't need new regulations; that they can voluntarily apply pollution controls. But in Utah, they either haven't done so in sufficient numbers, or those controls are clearly inadequate. Something more is needed than just voluntary controls.
Something like off-sets that require you to reduce as much air pollution as you spew.
The Next Big Dallas Environmental Fight? Garbage Burning
Many folks in the DFW environmental community think the battle over "flow control" at the McCommas Bluff landfill in Dallas is merely a prelude the the bigger goal of locating a large "materials recovery" operation there that will include a waste-to-energy power plant that can generate cash for City Hall as well as electricity. Once confined to the land-starved East Coast and Midwest, garbage burning is coming to Texas under the cover of recycling schemes that want to use it to make a buck instead of paying a landfill to take it.
A wave of garbage-burning permits have been approved across the country over the last 2-3 years at various cement plants, including the TXI kiln in Midlothian, south of Dallas, which can now burn plastic wastes and the non-steel parts of cars, including brake linings, electronic switches, vinyl covers, mats, and dashboards. Now the groundwork is being put in place to extend that practice into municipal garbage burning using power plants.
The sale pitch sounds great. The waste companies and city will be "completely committed" to recycling and reusing as much waste as possible. They'll only burn a "small percentage of leftover waste" that would otherwise go to a landfill. It has "significant BTU value" and it "reduces pollution" when you burn it! Why bury it when you can use it to make power that people need. It's really just like recycling!
Except it isn't. It's garbage burning. It's burning plastics. It's burning "fibers." It's burning teated lumber. It's burning "a small list of alternative fuels" and when there's not a enough of that stuff to generate the required power, the list expands. And it produces more air pollution, and distributes that air pollution over a much larger area, affecting many more people, than the same amount of garbage continuing to go to a landfill.
The 20-year fight over burning hazardous wastes at TXI and the other Midlothian cement plants began with the companies telling residents that they were "recycling flammable liquids" in kilns that reached almost 2000 degrees, and burned up 99.99% of all the waste. Soon, the cement kilns were mixing in non-flammable solids like toxic metals, and wastes with chlorine, and contaminated water that had little or no BTU value at all. And far from removing 99.99% of the bad stuff, the kilns added a toxic soup of chemicals to their already voluminous amounts of air pollution.
A landfill's toxic plume is usually slow-moving, flows only downhill, and can be tracked as it goes through soil. An incinerator's plume is blowing toxic air pollution wherever the wind is blowing, traveling as far the the wind will carry it, and changes from day to day, often eluding monitors if they're not in exactly the right place. Then, after all that, there's the problem of what to do with all the toxic ash. Send it to a landfill. Which practice puts more people in harm's way? Which one affects public health more? Which is the more sustainable alternative?
As a means of getting tuned up for the fight ahead, which some rumors put as near as this fall or winter, let's examine a little study partially sponsored by the American Chemical Council that was published the other day with the intent of setting the stage for widespread garbage, sorry, "refuse" burning.
It comes from UT – where another study on energy just got a lot of unfavorable publicity. This time It's Dr. Michael Webber who's Associate Director of the Center for International Energy and Environmental Policy in the Jackson School of Geosciences, Co-Director of the Clean Energy Incubator at the Austin Technology Incubator, Fellow of the Strauss Center for International Security and Law at the LBJ School of Public Affairs, and Assistant Professor of Mechanical Engineering at the University of Texas at Austin. Whew.
He's also a member of the "Pecan Street Project" in Austin, which is a "citywide, multi-institutional effort in Austin to create the electricity and water utilities of the future by the innovation and implementation of smart grids, smart meters, and smart appliances. The Pecan Street Project team includes UT, the City of Austin, Austin Energy, the Environmental Defense Fund, the Austin Technology Incubator, and eleven corporate partners."
See? Already the guy has impeccable credentials.
And what is Dr. Webber and the American Chemical council selling today?
"If 5% of residual waste from recycling facilities were diverted to energy recovery, it would generate enough power for around 700,000 American homes annually."
First, you understand that Dallas alone has more than 700,000 homes, and so we're talking about burning 5% of the entire nation's leftovers to get electrical energy for a city smaller than Dallas…for a year.
Second, does anyone know how many waste incinerators would have to be built and and what cost, or how they'd be financed? Nope. But we digress….
"The study found that while single-stream recycling has helped divert millions of tons of waste from landfills in the U.S. – where recycling rates for municipal solid waste are currently over 30% – Material Recycling Facilities (MRFs) currently landfill between 5% and 15% of total processed of the material treated as residue.
According to the researchers this residue is primarily composed of high energy content non-recycled plastics and fibre.
The report proposed that one possible end-of-life solution for these energy dense materials is to process the residue into Solid Recovered Fuel (SRF) that can be used as an alternative energy source capable of replacing or supplementing fuel sources such as coal, natural gas, petroleum coke, or biomass in many industrial and power production processes."
You will be unsurprised to learn that a cement kiln was involved in "testing" how well the garbage, sorry, SRF burned. Because it can reach temperatures of almost 2000 degrees!
But the results are not exactly spectacular in the way the Chemical Council probably anticipated.
Sulfur Dioxide (Sox) pollution was reportedly reduced over what coal alone would have emitted by some 20 to 44% (the study rounds this number up to "roughly 50%"). OK. but that's what SOx "scrubbers" are for. The study doesn't say whether the kiln used for the experiment had scrubbers on it. Not a lot of them do right now, but most power plants do and any new power plant or cement kiln would have to have them as well. Both the TXI and Holcim dry kilns have scrubbers already, and the new Ash Grove dry kiln will as well. These scrubbers can reduce SOx pollution by over 80%. So can we agree that we're better off just adding scrubbers to facilities instead of setting fire to plastic garbage to reduce this kind of air pollution?
On the other hand Nitrogen Oxide (NOx) pollution reportedly went up 25% to as much as 93%, when garbage was burned compared to coal. This spike was explained away by saying the kiln didn't have a proper delivery system for the garbage to reach the kiln. That's untested speculation by the authors that may or may not be true. Any increase in smog-forming NOx pollution would be hard to sell in an area like DFW that's been in violation of federal smog standards for over 20 years.
CO2 emissions were reportedly reduced by a paltry 1.5% – the equivalent to getting a million cars off the road! But that's another small number when you realize that just treating the CO2 from the three Midlothian cement plants here in North Texas would get you that number or something even bigger.
When you burn plastic you get dioxins – one of the most toxic substances in the world. The Chemical Council knows this. But there was no testing for dioxins, or phthalates, or any of the more exotic kinds of air pollution one would expect to see when you burn plastics and other kinds of garbage. This is one of the primary objections citizens would have about this practice, and yet there was no testing for it.
These results may not seem that great to you, but they impressed both the Chemical Council and Dr. Webber.
"In this case, one person's trash truly is another person's treasure. Americans send tons of waste to landfills each and every day, meaning that one of America's most abundant and affordable sources of energy ends up buried in landfills," commented Cal Dooley, president and CEO of ACC.
"It's time we got smart and made energy recovery a central part of America's energy strategy," he added.
Meanwhile Dr. Webber added: "The findings from our study demonstrate how engineered fuels can make a meaningful contribution to our nation's strategy while reducing carbon and sulfur emissions compared to some forms of energy,"
Let's translate: "Your trash is our potential treasure. We can't portray ourselves as "Green" if we don't find some way to make plastics more eco-friendly. Plus, we can make a buck packaging our garbage for you to burn it. Our findings show that under these very controlled circumstances, and with not too many questions asked, burning garbage can make some minimal pollution reductions that other readily available alternatives could make better, while also increasing the kind of pollution that most people don't want."
This fight over garbage burning will be as big, if not bigger than the fight over gas drilling. It will involve environmental justice issues, toxic pollution, private-public contracts, sustainability, and real recycling vs the fake kind. And lots and lots of doublespeak. Get your waders on.
What To Expect When You’re Expecting Gas Drilling
If you're a Dallas resident and you want to find out more about the kinds of new facilities that might be located near you if gas drilling is allowed in your city per the new ordinance the Council is debating on August 1st, here's a item of interest from West Virginia, where operators are already fracking.
"Sulfur dioxide, carbon monoxide and formaldehyde are some of the chemicals Chesapeake Energy is likely to pump into the air in Ohio County from its numerous drilling sites, company information states.
Earlier this year, Chesapeake officials confirmed plans to build local compressor stations that may release these and other chemicals into the atmosphere. Now, the company is identifying "potential to emit" levels for several potentially hazardous materials from its well drilling sites.
The amounts of the particulates that may be released at the four sites slightly vary. The carbon monoxide projections, for example, range from 40 tons per year to 61.5 tons per year to be released from a single site.
In addition to the pollution from the well sites, Chesapeake also will release emissions from its local compressor stations. Chesapeake, in a legal advertisement earlier this year, confirmed the "potential to discharge" the following amounts of these materials on an annual basis from the operations at the compressor stations: carbon dioxide – 93,800 tons; nitrogen oxides – 82.96 tons; carbon monoxide – 16.87 tons; methane – 86.64; carbon dioxide equivalent – 95,667 tons; benzene – 0.33 tons; and formaldehyde – 3.22 tons."
Formaldehyde and Benzene are both carcinogens. Carbon Dioxide is the primary greenhouse gas pollutant, and methane is right behind. Nitrogen Oxide is the primary component of smog in DFW. All this – 93,000 tons a year of air pollution – from just one gas compressor. Where in Dallas would you propose to put a facility that spews that much air pollution? And how would you keep it from adding to the chronic air quality problem the City already has? And then what about the fact that the operators might not need just one, but three, or five, or ten of these compressors in Dallas? It's not uncommon to build complexes that house as many as a dozen or more locomotive-size compressors in the Barnett Shale, which includes at least the western half of Dallas.
When you allow drilling, you're allowing everything else that follows drilling, including compressors and their pollution, storage tanks that leak copious amounts of the same kind of pollution, pipelines that can use eminent domain to run through your front yard, and a host of other hazards, some of which we know about, some of which we no doubt have not yet discovered. Gas mining is not conducive to neighborhoods or attracting new, non-polluting development. If Dallas City Hall doesn't know this now, it most certainly will learn it later.
Smog Update: On the Brink
Strong winds are usually among the most efficient smog-stoppers DFW has. Despite this last week's record-setting heat wave, ozone levels didn't go crazy like they did in June because the winds kept blowing. Only the Rockwall monitor recorded an "exceedance" of the 1997 85 parts per billion ozone standard on Saturday, it's first of the season.
That makes 17 out of 20 DFW monitors that have at least one such exceedance of the 85 ppb standard. 11 of 20 have at least two. 7 out of 20 have at least three. And 2 out of 20 already have the four exceedances they need to be registered as a violation of the standard (a "non-attainment area" ozone monitor gets three strikes before the fourth-highest reading gets counted against it).
That means we're just one bad air day away from seeing five more monitors record their fourth exceedance and become violators. Two bad days away from having nine – and August is traditionally much worse for ozone than July.
In 2010, there were two monitors in violation of the 85 ppb standard. Last year there were seven. Industry and state government have been trying to tell the public DFW is still making air quality progress despite these numbers – that last year was just an anomaly because of the drought. Not sure how they'll spin another year of seven or more monitors out of whack with a 15-year old smog standard
Let's remind everyone again that according to Governor Perry's three TCEQ Commissioners, there were going to be no violations of the 85 ppb standard this year, that this is the second state plan in a row to fail to meet the 85 ppb standard, and that the new EPA smog standard is 75 ppb. Heck of a job TCEQ.
Another Day, Another White House Retreat on Clean Air
In an election year, apparently no environmental initiative is safe from the Obama White House.
You may have missed this because it was one of those late Friday government announcments that officials like to use to bury bad news, but the EPA is going to consider softening those much-ballyhooed coal plant Mercury emissions rules that it fought so hard to get only last year. And because "consider" in this case means "we're going to do it," you can add these rules to the growing list of those clean air efforts in this supposedly environmentally-friendly administration that have bitten the dust because of political interfernce.
One of the reasons this rule is being rewritten is to satisfy the less-than-state-of-the-art White Stallion coal and pet coke-fired power plant being proposed for Matgorda Bay, whose owners have campaigned against the new rules since Day One. They say the rules are too strict and can't be met, despite being based on the track record of top performers in the utility industry. You will be unsurprised to learn that the Texas Commission on Environmental Quality is a co-facilitator in that campaign, up to the point of being so enthusiastic in its unquestioned support that it had to be ordered by a state judge to reconsider the first air permit it gave the plant because of the lack of any public participation.
White Stallion is going to be built less than 20 miles from the boundary of the eight-county Houston "non-attainment area" for ozone, or smog. Regulations on new sources of industrail pollution are tighter inside such areas than outside. That's pretty much all you need to know about the owner's commitment to using best technology. It's the same problem DFW used to face with the Midlothian cement plants and Ellis County until Donwiwnders petitioned, and EPA agreed, to include them in the North Texas non-attainment area.
Anything that makes it harder for Houston to meet clean air standards, also makes it harder for DFW to do the same. But this rollback is also a shame because of this administration's gap between promise and performance when it comes to critical upgrades in national polluiton standards – ozone, particulate matter, cement kilns and now coal plants. When push comes to shove, there seemingly isn't any polluter this White House won't do a favor for between now and November.
Rejected Smog Standard Would Have Saved 4100 Lives Annually – including DFW Residents
The EPA-proposed ozone/smog standard of 70 parts per billion the White House rejected at the last minute in 2011 would have saved almost twice as many lives per year over and above the Bush-era standard of 75 ppb that was eventually adopted, according to a new study by John Hopkins University scientists.
Most of those new leases on life would have come in large cities like New York, Chicago, and Los Angeles, where smog levels are historically high. But researcher say the standard would also have saved a significant number of DFW lives as well.
The lower standard was rejected by the Office of Management and Budget, and Executive Branch agency that has grown to have veto power over almost all EPA regulatory decisions based on their economic impact – a variable specifically excluded from consideration in the Clean Air Act.
The John Hopkins team also concluded that the lower 60 ppb standard that was in the lower range of what was recommended by EPA's own science advisory would have saved up to 8000 lives per year, compared with the 2500 annual lives estimated to be saved under the more lenient 75 ppb standard.
In addition to more lives saved, the study concluded that millions of asthma attacks and acute respiratory problems would be prevented with a lower ozone standard.
“We contend that a more stringent standard would prevent a substantial number of adverse health outcomes,” wrote the researchers, led by senior scientist Frank Curriero of the Johns Hopkins Bloomberg School of Public Health.
They calculated the reduced deaths by incorporating data from a variety of health studies around the country that have found that whenever ozone levels rise, deaths and hospitalizations from cardiovascular and respiratory problems rise, too.
There was also a warning that climate change would make higher ozone levels more likely, as seems to be in play this year with much of the country experiencing the kind of drought and heat Texas had last summer, and with national ozone level spiking.
EPA officials estimated that achieving the rejected 70 ppb standard would cost between $19 billion and $25 billion per year, including the estimated $8 billion for meeting the current standard set by the Bush administration in 2008. However, the agency estimated the health benefits would be worth $11 billion to $37 billion per year. Based on new evidence of medical costs associated with ozone pollution, that figure may have been very conservative.
The EPA's next review of the standard is supposed to begin in 2013. The Clean Air Act requires an evaluation every five years; Jackson, however, had planned to act early until Obama asked her to stop.
Meanwhile, DFW still can't meet the old 1997 85 ppb standard after three clean air plans in the last seven years. This year's fate is already sealed thanks to the June smog attack we had early on. Our worst monitors are averaging above 85 ppb and we haven't gotten to August – traditionally our worst month. Smog is taking its toll on our health in DFW, even if it doesn't make the nightly news.
New Study: Reducing Smog Brings More Health Benefits
In the same Washington Post article on the monkey business surrounding the new PM pollution standard comes news of a new study that concludes cutting smog pollution could bring added health care benefits that haven't been accurately estimated in the past.
Researchers at the University of California at Santa Barbara and MIT examined data for five years between 2003 and 2008 from the 20 Eastern states and the District of Columbia where power plants and boilers are required to limit nitrogen oxide pollution between May 1 and Sept. 30 each year – in other words, "oozne season."
During this time, they found prescription drug expenditures dropped by 1.9 percent, or $900 million a year, and the states and DC had 2,200 fewer annual premature deaths among individuals aged 75 or older.
“This is now new evidence of the evidence of the health benefits of ozone reductions, which was not available when the president overturned the previous effort to revise the ozone standard,” said MIT economist Michael Greenstone, who has informed White House officials of his findings.
As Gas Mining Moves East, So Do Smog Violations
Failing the Test on Smog
This is a response to statements in this.
1) "The downward trend" that Mr Clawson of TCEQ says has only been "interrupted," is, in fact continuing, and he knows this because it's TCEQ monitoring that's proving it. This last March saw the highest ozone levels ever recorded for that month since TCEQ air quality monitoring began in 1997. It's only June, and there are already two monitors whose three-year runing average "Design Value" is above the old 85 ppb standard. The "best ever" ozone summer we were supposed to experience this year, according to TCEQ's prediction to EPA submitted in December, is completely off the rails.
2) The "87 ppb" Design Value Mr. Clawson cites is from 2010. Last year it was 92 ppb – at the Keller monitor. This year so far, the Keller monitor is already at a Design Value of 87, a violation of the old standard and something TCEQ said would not happen.
3) The NCTCOG claim that,"the DFW region has a tougher time than other metropolitan areas in the U.S. because of its climate plus its position downwind from outside sources of pollution" is also misleading. Houston is a hotspot for bad air, and yet last year DFW exceeded the number of bad air days and the severity of the violations in that city. Other metropolitan ares downwind of power plants as well as DFW, and yet they've all managed to do better in achieving cleaner air. Atlanta, Phoenix, and other Sunbelt cities that started out at the same smoggy spot a decade ago have all conquered the old 85 ppb std. DFW has not. It's already blown it again this year. Instead of blaming climate or coal plants, it is more realistic to blame DFW's air quality failure on a lack of political will by local and state officials to get serious about decreasing air pollution.
However, there is one large area of policy where the excuses of lack of will and new downwind sources collide – in the official lack of attention paid to the rise of Barnett and Haynesville Shale gas pollution as a source of smog in DFW.
4) The statement that only "5 percent" of the smog-forming emissions in DFW come from oil and gas drilling and production is also highly misleading. First, we know this is one of the fastest-growing categories of air pollution over the last decade. The increase in gas pollution is erasing decreases in emissions from other sources. Second, according to the information submitted by TCEQ to EPA last December, oil and gas emissions are the second largest source (20%) of smog-forming Volatile Organic Compounds, or VOCs in the 9-county DFW non-attainment area. That's more than the total VOCs produced by all on-road vehicles in the same 9 county area. Based on recent field studies by NOAA and others, this is probably an underestimate.
This statement also ignores the impact of gas emissions to the south and east of DFW, like Freestone County's, that are not included in the 9-county area inventory, but are probably influencing air pollution here.
What's always left out of this pie chart is the fact that cars now have a removal efficiency of approximately 90%. No other major sources come close to that kind of effort, despite technology being available to achieve it – at cement kilns, gas operations. and coal plants. That's where "the lowest hanging fruit" remains. But since all those industries are large contributors to the politicians directing the status quo, there's no political will to target them. Exhibit A: the 2011 DFW clean air plan submitted by the state, which relies primarily on marketplace forces to replace old cars with new ones, instead of any new round of pollution controls for any industry sources.
5) The NCTCOG claim that "monitors in the north Dallas and Frisco areas have had the highest readings of the region but the plume seems to be shifting west" is also based on old data. In fact, the opposite is occurring. Violating monitors are moving EAST (just like gas mining). And there are more of them. From 2008 to 2010, Eagle Mountain Lake and Keller were the epicenter of smog in DFW. But in 2011, while Keller tripped the std, EML did not. Moreover, during that same 08-10 period there were only 1-3 monitors in violation of that std. Last year, there were seven. And they included not just Keller and Parker County, but Denton, Grapevine, Pilot Point, Frisco and North Dallas – directly in contradiction to the NCTCOG claim.
This year, the very first monitor to record four "exceedances" of the 85ppb std was located near Mockingbird and I-35 in Central Dallas – the first time that monitor has done so since 2005. Moreover, the fourth exceedance came in June – the earliest that has happened since 2006, when 12 out of 19 monitors were in violation at the end of the summer.
As much as the officials and agencies would like us all to ignore the summer of 2011 and think of it as an aberation, it would be more prudent to see it as another warning sign that DFW needs to do much more to get safe and legal air.
The Petrochemical Circle of Smog
Here's a piece by Texas Tribune off-shoot "State Impact" that more or less revels in the news that the Shale boom in Texas and elsewhere is now finally making its presence felt in the petrochemical capital of the world – the Houston Ship Channels and surrounding communities long the Gulf Coast. Fracking has made natural gas and its condensates so cheap and plentiful that billions are being spent to build new plastics manufacturing and processing plants. It's the "re-birth of the U.S. petro-chemical industry," to quote one producer.
Already the hub of something like 60% of all petrochemical capacity in the US, the Houston/Harris County area has an on-going historical struggle with air pollution. Residents who live near huge facilities like the Exxon-Mobil Baytown Refinery are always on guard against catastrophic accidents, much less the daily or weekly indignities of breathing its perfectly legal voluminous air pollution. Much of the pollution is not only toxic but also adds to Houston's smog problems.
These new Shale-driven facilities, while cleaner than their older counterparts, will nevertheless be adding tens of thousands of tons of new air pollution to the Houston skies. That's going to complicate things for getting cleaner air in Houston. They haven't really mastered how to have clean air after the first birth of the petrochemical industry, much less a rebirth.
DFW is downwind of Houston. When it's harder for Houston to achieve cleaner air, it's also harder for DFW. What else makes it harder for DFW to achieve cleaner air? Large new sources of Un-and-under-regulated emissions from Shale gas mining.
So gas is mined and processed here in North Texas, where it adds to a chronic air quality problem for us. Then it's shipped to Houston, where it's use in making new plastic adds to chronic air quality problems for that city, as well as returning via predominate winds during ozone season to further contribute to deteriorating air quality here in DFW. It's the Petrochemical Circle of Smog.