West to Dallas: Zoning is Important.

WEST TX MAPFor many of us dealing with the Texas "environmental regulatory system" the shock isn't that something like the West disaster happened, it's the fact that similar accidents don't happen more frequently. Still, it seems like it combined a perfect storm of all-too familiar circumstances

1984 – the company moves two large pressurized tanks of liquid anyhydrous ammonia, a potentially lethal poison, from a site in nearby Hill County to its current location in West without notifying state authorities. It was 1992 before the state caught the mistake and made the company do the paperwork. It moved into an area whre there was already residential development.

1987 – the company was venting ammonia that built up in transfer pipes into the air despite explicit orders in its permit not to do so.

Mid-1990's –  the plant’s neighbors complained often about ammonia odors from the company. A neighbor reported “strong anhydrous ammonia odor at her house on Jane Lane.” Another “alleged that strong ammonia odors had intermittently been coming from the West Chemical and Fertilizer facility. That happened repeatedly, but each time a state inspector arrived, usually days later, he couldn’t smell any ammonia or find any leaks.

2004 – The company’s “grandfathered” status for the two large pressurized tanks of liquid anyhydrous ammonia expires. It was 2006 before an ammonia odor complaint sent an inspector to the company in 2006, a records check revealed the overdue permits.

2006 – a West police officer called a company employee to tell him an ammonia tank valve was leaking. The employee confirmed the leak and “took the NH3 [ammonia] tank out to the country at his farm,” according to a handwritten note. “West Police followed him.”

2006 – EPA fined cited West Fertilizer $2,300 for not implementing a risk-management plan, according to an EPA database.

2011 – In the required risk-management plan, West Fertilizer said the “worst-case scenario” would be an ammonia leak from a storage tank or hose. It didn’t specify the likely consequences. The company said the plant had no alarms, automatic shutoff system, firewall or sprinkler system.

2012 – the Office of the Texas State Chemist, which regulates fertilizer, visited the company 12 times and found "no problems" with the management of its material.

The Occupational Safety and Health Administration had not inspected the plant since 1985, when it gave out a $30 fine. Because of budget cuts, OSHA can inspect plants like the one in West about once every 129 years.

All the elements found in West –  disregard for common sense, "grand-fathering" of incompatible zoning, no enforcement of current regulations – can be found just about anywhere you could throw a dart on a map of Texas. All it takes is a lightning strike, a mistake at a control board, or a wind-whipped ember. For evidence, look only to the stories being told by an ex-Exide employee about working conditions at the recently-closed lead smelter in Frisco.

But much more common still are the daily insults to workers and neighbors inflicted by "upsets," accidental releases, and routine pollution that no one has assessed for its full toxicological impacts. These are the non-spectacular injuries of under and no-regulation, and they overwhelm the headline-making ones. Together with the potential for catastrophe, this is why zoning is important. This is why paying taxes for inspectors is important. This is why industry cannot be trusted with its own regulation. This is why environmental protection is a DIY proposition.

There's been a lot of tsk-tsking over the wayward rural ways of West that allowed the accident to inflict so much damage, but countless North Texas officials have shown they're no more sophisticated. Many Barnett Shale communities allow drilling sites within just 100-500 feet of homes and schools, much less as processing plants and compressor stations. Currently, the majority of the Dallas City Council is in favor of putting drill sites in city parks and a gas refinery dealing with dangerous Hydrogen Sulfide only 600 feet from a giant children's athletic complex. Imagine the indignant questions should they get their wish and something terrible happens. "Who allowed a facility like that so close to those kids?"

We think we live in places where a West could not happen. We're wrong. 

Your’re Downwind of Lots of Burning Trucks

Burning TruckA funny thing happened to Dallas Morning News automobile columnist Terry Box while he was out test driving a new Dodge pick-up truck – it self-immolated and burned to ashes on the side of the road. As he writes about it, his experience is both funny and terrifying. But something he noted in how cars and trucks are made these days caught our eye:

"Open the hood of your late-model car or truck, and you’ll see a half-acre of plastic — actual engine pieces like valve covers, caps and containers for various liquids.

Thirty years ago, most of the pieces under the hood were metal and resistant to fire.

A fire in a modern vehicle burns fast and furiously. What’s intact for the moment can be gone or enveloped in toxic smoke in a matter of seconds."

Yep. When we've described the lovely new cement additive called ASR – Auto Shredder Residue – we've often talked about all the vinyl seats, dashboard and switches that get stipped out of a car and shredded, then thrown into a cement kiln. We really haven't talked about all the plastic in the engine compartment that would also be included in this new "fuel" that  TXI has already been permitted to burn at its Midlothian cement plant.

As more and more of every car is made of "soft materials" – that is, not metal – more and more of it becomes fodder for cement kilns. This is material that could be recycled but isn't, and as long as it's cheaper just to burn it, there won't be amrket for recycling it.

Here's the thing, burning plastic creates bad kinds of pollution, including the creation of Dioxin, one of the most potent posions ever discovered by science.  The same "toxic smoke" Terry Box saw pouring off of his burning Ram pick-up is created when you throw the same plastic parts into a cement kiln. The cement industry would like you to think that all of that is taken care of by the polluton control measures installed at the kilns, but it's not. There's no real time Dioxin montoring, much less any kind of monitoring for the host of other exotic fumes coming off burning plastic of various kinds. They barely even know what or how to test for such pollutants, but that doesn't keep the cement industry from marketing its kilns as "Long, Hot, and Good for America"™

If you're an old-timer, you might remember an earlier episode or two that occurred when the cement industry, including TXI, assured everyone that it could burn hazardous waste and make it completely disappear into water vapor. Remind us, how did that turn out?

Dallas Park Driller Was Former Haz-Waste Handler Forced to Shutter California Plant for Violations

hazmat_cdc-300x204The President of the company at the center of the current Dallas drilling controversy was Vice-President and General Counsel of a hazardous waste disposal firm that was forced to close its California plant site after a long history of environmental violations.

Thomas Blanton is President of Keystone, the parent company of Trinity East, which is applying to the City of Dallas for three gas drilling and production permits in the Trinity River flood plain near Irving. But in the 1990’s and early years of this century, he was a leading officer of the Board of Directors of US Liquids, a large broker of hazardous wastes that had its California facility ordered shut by the state’s California Department of Toxic Substances Control.

From 1999 to 2003, US Liquids owned Romic Environmental Technologies Corporation. Romic’s Bay Area operation received hazardous wastes from throughout the country, “blended” them on-site, and then shipped the toxic soup for use as “fuel” for cement plants like the TXI kilns in Midlothian.

Records show that from 1999 to 2004, Romic was slapped with 28 separate environmental violations by the State of California, which resulted in penalties of $849,500. The California Occupational Safety and Health Administration (CalOSHA), discovered 57 violations at the plant from 1988 to 2004, totaling another $163,360 in fines.

Romic closed in 2007 on orders from the state of California as part of a legal settlement stemming from a series of environmental violations. The state and EPA ordered a clean up and closure of the facility after extensive soil and ground water contamination was discovered over most of the site. According to the EPA, the contamination is primarily attributed to the spills, overflows, flooding events, and other accidental releases around the “central process area.” The primary contaminants were volatile organic compounds such as trichloroethene (TCE), a solvent used to clean metal parts. Toxins migrated as much as 80 feet below ground that borders San Francisco Bay tidal marshes.

All three sites that Blanton’s company wants to drill on are located in the Trinity River’s 100-year flood plain; two are also on City of Dallas park land. Opponents have warned about probable contamination from surface spills, which a 2011 UT study concluded were more frequent with fracking than conventional drilling.

It was recently disclosed that a Trinity East sister company experienced a casing failure at an Irving gas well it tried to drill in 2009, although the extent of any environmental damage caused by the incident remains unknown. 

“Does Dallas really want hand over its park land to a businessman who has a history of contaminating and threatening soil and water resources?” asked Gary Stuard, Chair of Downwinders at Risk, a local DFW clean air group that’s been battling the Trinity East permits.

After denying Trinity East’s permits once last December, the City Plan Commission is scheduled to vote a second time on them at its meeting on Thursday afternoon.

Stuard was critical of the lack of due diligence city staff had performed on Trinity East and its owners and said this new information was another example of residents doing the job themselves.  “There’s never been a review of the company’s track record by the City. It had gone completely unexamined until Dallas residents took it upon themselves to do the research. What else don’t we know because the City isn’t doing a routine background check?”

Back in California, the first phase of the EPA-ordered clean-up at the Romic site ended in 2010 with clean-up of surface and above ground messes.  A second phase is addressing the remediation of below surface soil and groundwater contamination. The estimated cost for closure and cleanup of the facility is $2.5 million.

Scientists: Classify Plastic As Hazardous Waste

Plastics wasteWe missed this the first time around, so we're glad that "Living on Earth" caught it again. A group of scientists, including marine biologist Chelsea Rochman, recently signed an article in the magazine Nature that called for classifying plastic as a hazardous waste.

What's the rationale? It turns out to be pretty solid and based on current regulations. As Rochman described it, 

Waste is basically separated into two categories, those that are non-hazardous like grass clippings, and those that are considered a hazard, which are often based upon this long list of priority pollutants, or substances that the government deems are hazardous to organisms. And we found that plastics are associated with 78 percent of these priority pollutants listed by the US EPA and 61 percent listed by the European Union, either as a chemical ingredient of the plastic itself or when the plastic ends up in the aquatic environment; they absorb these contaminants from the water. And so from that perspective we thought maybe plastic as a waste product should also be considered as a hazardous substance.

Rochman cites styrene in Styrofoam as an example of a well-known pollutant that's incorproated into plastic. Another is vinyl chloride that's used to make PVC.

Plastics' threat to marine life has been well-documented, but it's also a threat to those living downwind of places that burn plastic wastes – like an increasing number of cement plants, including TXI's huge Midlothian Kiln #5. Besides being assaulted by the leftovers of the ingredients in the original plastic, downwind neighbors are also subjected to entirely new pollutants that are made ONLY when plastics are burned. The most notorious of these is Dioxin, one of the most potent poisons ever tested.  Dioxin is what made Agent Orange so toxic to Vietnamese and veterans alike. It's why Times Beach Missouri is a Superfund Site. And it's what's released every time plastics are burned.

Incineration of plastics is dramatically increasing despite producing this kind of pollution. Classifying this waste as "hazardous" might be the only way to limit their use as "fuel" in cement kilns that weren't built to be garbage incinerators.

EPA Challenges State Clean-Up of Frisco Smelter Waste

boxing gloves picDespite denying that it was submitting comments on the state's plan for cleaning up the recently closed Exide lead smelter, the Environmental Protection Agency turned in a sometimes scathing assessment of Austin's proposal to allow the company to treat prohibited hazardous waste that still lies buried in its landfills in Frisco.

"The landfill is not permitted or constructed as a hazardous waste unit. Please clarify the regulatory/statutory provisions TCEQ is following that would allow for treatment of hazardous waste in the landfill," wrote EPA Associate Director Susan Spalding in a five-page letter sent to the Texas Com mission on Environmental Quality (TCEQ) on January 25th.

News of the Agency's comments comes on the eve of a public meeting scheduled by Exide for Wednesday night at the historic Frisco Depot to explain its clean-up operation.

Besides criticizing the on-site treatment of the hazardous waste, EPA also had a harsh review of the way Exide and TCEQ had identified areas of the current landfill with concentrated lead wastes that needed treatment, suggesting four times as much sampling as the company had proposed, and TCEQ had approved.

EPA also noted that a closed landfill in Frisco was already leaking hazardous levels of lead and selenium and suggested that the treatment method Exide is using in its current landfill was not going to be effective.

But in what may be a crushing blow to the company's plans to keep the wastes it generated for almost five decades buried in Frisco permanently, EPA stated that if the current landfill had been used for disposal after 2011 sampling to determine clean-up, which it almost certainly has,"This may require removal of all material" in the landfill.

Many of the problems cited by the Agency are the same ones citizens have been complaining about since Exide announced its unusual scheme to try to treat its illegal hazardous waste in place in its Frisco landfill, instead of digging it up and re-burying it in an official, licensed hazardous waste disposal site.

Exide does not have a permit to handle or dispose of hazardous waste. It's landfill is classified as a "non-hazardous waste" disposal site. The hazardous waste inside of it was discovered by inspectors several years ago.

Citizen groups have said Exide must apply for a full Resource Conservation and Recovery Act permit in order to deal with its prohibited wastes. EPA's letter seems to suggest that the Agency agrees.

Besides commenting on the landfill plans, EPA's letter also seeks changes in the dust controls guiding the smelter clean-up, and the public release of information about the clean-up.

Copies of the EPA letter can be downloaded from the Frisco Unleaded website here.

"We're very appreciative that EPA changed its mind and decided to comment on the ridiculous plans by Exide and TCEQ to use the same treatment method on this hazardous waste that failed to work the first time," said Colette McCadden, Chair of Frisco Unleaded, the citizens group who successfully campaigned to close the old smelter last year.

"We hope the EPA continues to provide needed oversight to what Exide and the state are doing – or not doing."

Other groups were more cautious.

"It's a pleasant surprise to see EPA comment so bluntly about the more absurd parts of the proposed Exide clean-up," said Jim Schermbeck of Downwinders at Risk. "My hope is that this is only the beginning of a new level of review for Exide by the Agency in light of the USA Today's "Ghost Factory" series chronicling what happens when it's not paying such attention. Only time will tell."

Guess What? That “Drilling” Permit is Really for a Refinery

Under the guise of "gas drilling," Dallas City Hall and industry are pressing for approval of a permit that would locate a gas refinery only 600 feet from the new Elm Fork soccer complex, and immediately give birth to one of the ten largest air polluters in the City of Dallas, as well as one of its most toxic.

"There's a huge toxic Trojan Horse hiding in what the City and Trinity East describe as just a gas drilling permit," charged clean air activist Jim Schermbeck of Downwinders at Risk. "In fact, the Elm Fork permit allows for the building of a gas refinery that houses at least three giant compressors as well as an entire acid gas removal unit that strips off hydrogen sulfide, one of the most dangerous substances in the gas patch."

A motion to "reconsider" the Dallas City Plan Commission's 7-5 December 20th rejection of the Elm Fork permit and two other Trinity East gas sites is being advocated by CPC Chair and Mayoral appointee Joe Alcantar at this Thursday's meeting. If successful, the "reconsideration" would require the CPC to hold a second hearing and re-vote on the permits less than a month after denying them.

Opponents say the move is an act of desperation on the part of the Mayor and City Manager to protect a secret deal that was made between the City and Trinity East when the company first paid for mineral rights leases on city owned land. In interviews, the Mayor himself has said that a "deal was cut." Residents say the public was left out of that deal. 

But after making calls to City Hall, Schermbeck is convinced that no one in Dallas city government is aware that the "gas drilling permit" being proposed by Trinity East is actually a permit to build a large gas refinery in the Trinity River floodplains.

"They're in way over their heads. City attorneys are still describing this as a drilling permit, but that's not what takes up most of the acreage on this site – it's all about the refinery."

During the December 20th City Plan Commission hearing on the permit, Trinity East representatives stated that the three proposed compressors alone – huge locomotive sized diesel-powered engines that produce thousands of horsepower in order to move gas through pipelines – would release 25 tons of air pollution each every year for an annual total of 75 tons.

That number would immediately place the facility among the city's ten largest air polluters according to the latest state emission totals from 2010. It would join power plants, asphalt and roofing materials manufacturers, and chemical plants as one of the city's biggest "stationary sources" of pollution.

However, Schermbeck thinks Trinity is low-balling their total air pollution impacts by not including other on-site refinery sources like its battery of storage tanks and "acid gas removal" operation that's designed to strip dangerous hydrogen sulfide off of natural gas streams through a series of acid baths and heat.

Hydrogen Sulfide is a harmful and toxic compound. It is a colorless, flammable gas that can be identified by its "rotten egg" odor. This invisible gas is heavier than air, travels easily along the ground, and builds up in low-lying, confined, and poorly ventilated areas. It acts as a chemical asphyxiant through inhalation exposure and its effects are similar to cyanide and carbon monoxide, which prevent the use of oxygen. 

The equipment to strip off Hydrogen Sulfide from raw gas is large, complicated and dangerous. Site plans show a 200 foot long "pipe rack" with at least 20 "point sources" or stacks, apart from the compressors, where pollution could be released into the atmosphere. 

"This isn’t a facility you want near parks or kids," said Schermbeck. "Yet, the City of Dallas seeks to put it just 600 feet away from its new huge soccer complex that’s meant to attract thousands of kids for hours every week."    

Such a gas facility also challenges regional smog goals. A 2012 study from the Houston Advanced Research Center found that "routine emissions from a single gas compressor station can raise ozone levels by 3 parts per billion (ppb) as far as five miles downwind, and sometimes by 10 ppb or more as far as 10 miles downwind." 

The Trinity East numbers don't reflect the release of greenhouse gas pollution either, which could be enormous from a facility the size of the refinery being proposed. Gas processing plants can release 20 to 80,000 tons of greenhouse gases a year. By comparison, the entire inventory of greenhouse pollution from all Dallas industrial sources in 2005 was 25,000 tons a year.

None of this information was brought up at the December 20th CPC hearing on the Elm Fork permit because the permit request in its current form was only a couple of weeks old when it went to the CPC and the compressors were a last-minute addition to an older, pending request.

Citizens were lucky to get a crowd to even show up five days prior to Christmas, and Schermbeck believes no one at Dallas City Hall bothered to notice that one of the so-called drilling permits was a refinery permit.

"Because it had no expertise of its own, and it was ignoring citizens, City Hall was completely reliant on the company's version of what the permit was for, and Trinity East probably didn't want to admit they were stuffing one kind of permit inside of another. The City didn't perform its due diligence. The result is that it's been completely played by the company."

Schermbeck recounted that he could find no one at City Hall who had any idea of how Trinity East arrived at their "25 tons a year" air pollution figure, knew what kind of specific pollutants that tonnage included, or, most importantly, thought it would be good to know this information before the city handed the company a permit to operate an inner-city gas refinery. 

"Mayor Rawlings and the City Manager seem content to give Trinity East a blank check to pollute Dallas air," he said.

A closer look at the refinery site plans also reveals equipment that is fundamentally at odds with the way Trinity East and the gas industry has been portraying what kind of gas Dallas has underneath it. 

Up to now, gas operators have been saying Dallas gas is "dry" and without a lot of extra hydrocarbons found in "wet gas" further west. But the acid gas removal units and Glycol conductors proposed for the Elm Fork refinery are built for wet gas. 

Schermbeck suggests that perhaps either the City has been mislead about the nature of the gas it owns or the nature of the Trinity East site. He theorized that instead of the Dallas refinery being built for dry Dallas gas, it might be aimed at wet gas coming from the west. 

"Dallas would get none of the royalties, but all of the pollution."  


Mad? Go to this link now and send an e-mail to the Dallas City Council and City Plan Commission that says you oppose these gas permits and the "reconsideration" of their denial by the Commission:


Do it Now.

“Statistically Significant Increase” in Risk of Dying from Cancer in Towns Near Incinerators

You know that argument you sometimes hear about how those ecologically-minded Europeans are burning everything in incinerators and cement plants, so it must be OK to do it here? Maybe not so much.

In one of the most ambitious and far-ranging efforts of its kind ever attempted, the newly-published results of a 10-year study from Spain's national Center for Epidemiology looked for 33 different kinds of cancer in dozens of Spanish communities that hosted "waste incinerators and installations for the recovery or disposal of hazardous waste." They found "a significant higher risk from all cancers in towns near these industries."

Cancer impacts were greater around waste incinerators and scrap metal operations – you know like the three giant Midlothian cement plants upwind of DFW that are burning larger and larger amounts of industrial wastes and the steel mill across the street from them melting scrap cars.

Researchers used standard computer modeling to estimate what cancer rates should be in the host communities and then compared them to what they actually were.

"Excess cancer mortality was detected in the total population residing in the vicinity of these installations as a whole and, principally, in the vicinity of incinerators and scrap metal/end-of-life vehicle handling facilities, in particular. Special mention should be made of the results for tumors of the pleura, stomach, liver, kidney, ovary, lung, leukemia, colon–rectum, and bladder in the vicinity of all such installations. Our results support the hypothesis of a statistically significant increase in the risk of dying from cancer in towns near incinerators and installations for the recovery or disposal of hazardous waste."

There has never been any kind of systematic study of cancer rates around and downwind of the Midlothian cement plants. From the Texas birth defect registry we know that certain reproductive organ birth defects that are associated with pollutants known to have been released from the plants are higher than the state average in Ellis County.

This study, as well as the recent warnings of the federal Agency for Toxic Substances and Disease Registry about the public health dangers of the pollution coming from the Midlothian cement plants arrives at a time when the plants are gearing up to add plastics, car interiors, and other kinds of garbage to their lists of "fuels" that will be burned. After losing the fight to be able to burn hazardous wastes willy-nilly in cement plants, the industry is turning to industrial and municipal garbage that can produce many of the same worrisome kinds of pollution. This is what makes the EPA rules governing the emissions of the nation's cement plants – rules that are still in play – so very important.

Hell Freezes Over: Why the New Federal Report on Midlothian Matters

Everything in italics and "quotation marks" below is a direct quote from the latest chapter of the ATSDR's (Agency for Disease Registry and Toxic Substances) "health consultation" on the impact of certain kinds of industrial air pollution on the local population.

You should take five minutes to glance over the sentences. They've taken a better part of a decade and a great deal of citizen persistence to make it to print. You can read them now only because of a petition to ATSDR by local Midlothian residents, spearheaded by Sal and Grace Mier in 2005, prompted the Agency to get involved.

They're also rarer than hen's teeth. Because the words actually come together in sentences to conclude human health was likely harmed by the pollution from Midlothian's three cement plants and steel mill, as well as recommend decreasing that pollution.

Among grassroots activists, ATSDR has a notorious reputation for issuing reports that are "inconclusive by design." The joke is that the agency never met a facility it couldn't learn to live with. And sure enough, previous chapters in this saga have disappointed. Just two years ago, ASTDR's shoddy work in investigating health impacts in Midlothian and elsewhere across the country was the subject of a Congressional hearing.

These ATSDR reports generate no new data. Instead, they are retrospective looks back at the available sampling/monitoring information and a piecing together of possible exposure paths and levels. As such, they're only as good as the data they can digest. In Midlothian's case, that means they're completely dependent on state monitoring – criticized by citizens for years as being inadequate. Nevertheless, with this latest report, citizens have been somewhat vindicated because of what even that inferior sampling revealed.

The health impacts described in this latest report are also limited to what are called "Criteria Pollutants" – old school substances like lead, soot, sulfur dioxide, and ozone that have been regulated by the Clean Air Act for decades. They do not apply to more exotic kinds of air pollution like endocrine disruptors, which there's little or no monitoring for at all.

So there are a lot of missing pieces, but the ATSDR's conclusions and recommendations have an impact on your lungs and maybe your own local fight, even if you don't have a Midlothian zip code. For the first time a federal agency known to avoid coming to any conclusion about anything was forced to say that human health was adversely affected by the operations of industry in Midlothian.

There's a public meeting on this report on December 6th from 7 to 8:30 pm at the Midlothian Conference Center.

Health Consultation/Assessing the Public Health Implications of the Criteria (NAAQS) Air Pollutants and Hydrogen Sulfide MIDLOTHIAN AREA AIR QUALITY MIDLOTHIAN, ELLIS COUNTY, TEXAS
Agency for Toxic Substances and Disease Registry
Division of Community Health Investigations


"Texas Commission on Environmental Quality (TCEQ) should take actions to reduce future SO2 emissions from TXI to prevent harmful exposures."

"TCEQ should take actions to reduce future PM2.5 emissions from TXI and Gerdau to prevent harmful exposures."

"TCEQ should continue efforts to reduce regional ozone exposures."

"TCEQ should insure that levels of these air pollutants do not increase to levels of concern in the future."

"TCEQ should conduct ambient air monitoring to characterize exposures to persons located downwind of the Ash Grove and Holcim facilities and take actions to reduce SO2 emissions from these facilities if harmful exposures are indicated."

"TCEQ should conduct appropriate ambient air monitoring to characterize exposures to persons located downwind of the Ash Grove and Holcim facilities and take actions to reduce PM2.5 emissions from these facilities if harmful exposures are indicated. In addition, particulate matter monitoring is needed in residential areas that are in immediate proximity to the facilities’ limestone quarries."

"In ATSDR’s judgment, one notable gap in monitor placement is the lack of monitoring data for residential neighborhoods in immediate proximity to the four industrial facilities, where fugitive emissions (those not accounted for in stack emissions) likely have the greatest air quality impacts."

Human health was likely harmed, and is still threatened by industrial pollution from Midlothian

From Sulfur Dioxide:

"Breathing air contaminated with sulfur dioxide (downwind of TXI's cement plant and the Ameristeel steel mill) for short periods could have harmed the health of sensitive individuals.ATSDR cannot determine if harmful exposures to SO2 have been occurring downwind of the Holcim and Ash Grove facilities."

"All 24-hour values in Midlothian were lower than EPA’s former standard. However, the World Health Organization’s health comparable guideline is 8 ppb (WHO, 2006). This value was exceeded at both the Midlothian Tower and Old Fort Worth Road stations in most years of monitoring through 2008…"

"Overall, in the years 1999 to 2001, Old Fort Worth Road (monitoring site north of TXI) ranked among the stations with the highest 24-hour average sulfur dioxide concentrations in the state. As sulfur dioxide emissions from TXI Operations decreased in following years, so did the measured concentrations at this station."

From Particulate Matter, or Soot:

"Public health concern is warranted for adverse health effects from long-term exposure to PM 2.5 in Cement Valley"

"In the past (1996–2008), annual average PM 2.5 levels measured were just below the range of concentration proposed by EPA for lowering the annual average standard…Moreover, many of the annual average PM 2.5 concentrations were above the more conservative WHO health guideline (10 μg/m3)."

"No PM 2.5 monitoring data are available to evaluate exposures downwind of the Ash Grove facility. Furthermore, although annual average PM2.5 levels detected at the Holcim monitor indicate possible harmful levels…."

"We estimated that annual average PM2.5 levels in the vicinity of the Gerdau Ameristeel monitor, from 1996 to 1998, could have ranged from about 22.6 to 26.4 μg/m3, which is above both the current and proposed EPA standard. Using EPA’s approach, the 3-year average level might have been above the NAAQS standard of 15 μg/m3 for these years in the vicinity of the Gerdau Ameristeel monitor. Applying this same approach to annual average PM10 data from other monitors suggests that PM 2.5 levels could have been close to the current and proposed PM2.5 standard, especially for the Wyatt Road, Old Fort Worth Road, Gorman Road, and Midlothian Tower monitors."

"Consistent with the other pollutants discussed earlier, the estimated annual PM 2.5 emissions listed for these facilities are among the highest for Ellis County and also rank high among industrial sources statewide."

From Lead:

"Past lead air exposures during the period 1993 to 1998, in a localized area just north of the Gerdau Ameristeel fence line, could have harmed the health of children who resided or frequently played in this area….In the mid-1990s, the lead levels measured in this area ranked among the highest lead concentrations measured statewide."

From Smog:

"Scientific studies indicate that breathing air containing ozone at concentrations similar to those detected in Midlothian can reduce lung function and increase respiratory symptoms, thereby aggravating asthma or other respiratory conditions. Ozone exposure also has been associated with increased susceptibility to respiratory infections, medication use by persons with asthma, doctor’s visits, and emergency department and hospital admissions for individuals with respiratory disease. Ozone exposure also might contribute to premature death, especially in people with heart and lung disease. School absenteeism and cardiac-related effects may occur, and persons with asthma might experience greater and more serious responses to ozone that last longer than responses among people without asthma."

"The Midlothian Tower site recorded ozone concentrations above the level of the NAAQS for several years (TCEQ, 2011b), and the Old Fort Worth Road site has been measuring ozone concentrations close to the level of the NAAQS. Based on the data from both monitors, from August 1997 to September 2011, the 8-hour EPA ozone standard has been exceeded 236 times."

From Breathing Multiple Pollutants:

"ATSDR believes that sufficient information exists to warrant concern for multiple air pollutant exposures to sensitive individuals, especially in the past….The ability of the scientific community to fully and quantitatively evaluate the health effects from the mixture of air pollutants people are exposed to is at least ten years away (Mauderly et al., 2010)……The current state of the science limits our ability to make definitive conclusions on the significance of simultaneous exposures to multiple criteria air pollutants. ATSDR’s conclusions are based on our best professional judgment related to our understanding of the possible harmful effects of air pollutant exposures in Midlothian and our interpretation of the current scientific literature; therefore, these conclusions are presented with some uncertainty."

From New Production:

"Reductions in SO2 levels in Cement Valley have occurred since late 2008 resulting in exposures to both sensitive individuals and the general public that are not expected to be harmful. These reductions may be caused, in part, by declining production levels at local industrial facilities. Future harmful exposures in Cement Valley could occur if production rises to at least previous levels and actions are not taken to reduce SO2 emissions."


Regulatory "Safe Levels" Very Often Aren't

"Past SO2 exposures were not above the Environmental Protection Agency (EPA) standard in place at that time but were above the current standard."

"Past lead air exposures were not above the EPA standard at that time but were above the current standard.…The scientific community now believes that the current standard (15 μg/m3) for fine PM (measured by PM2.5) is a better indicator of possible long-term health effects from PM exposures than was the former EPA annual average standard for PM10 (EPA, 2006b)."

30 Years After They’re Banned, PCB’s Still Making It Hard to Have Kids – In Texas

Another argument for the implementation of the Precautionary Principle.
PCBs (polychlorinated biphenyls) are chemicals that were used as coolants and lubricants in electrical equipment for 50 years. They were banned in the US in 1979 because of their severe toxicity. Although they're no longer manufactured, PCBs are still present in older products, such as caulking, oil-based paint, floor finish, older automobile electrical systems, and insulation.
PCBs persist for years in the environment — in soil, water and the food chain — as well as in body fat and breast milk. PCBs are endocrine disruptors, that is, they can alter a person's hormone system at even small levels of exposures.
And now we know that over 30 years after they stopped being manufactured, PCB's are making it harder for couples to have children, including in 12 counties in Texas.
That's the conclusion of a new extensive $10 million National Institue of Health study that's the largest of its kind ever done.
Researchers enrolled 501 couples from four counties in Michigan, and 12 counties in Texas, from 2005 to 2009. The couples were part of the Longitudinal Investigation of Fertility and the Environment (LIFE) study, established to examine the relationship between fertility and exposure to environmental chemicals and lifestyle. An earlier analysis from the LIFE study found that high blood levels of lead and cadmium also were linked to pregnancy delay.
Those couples that had the highest PCB levels in their bloodstream had the most difficult time conceiving, 20% harder on average.
Exposure to these pollutants is known to have a number of effects on human health, but their effects on human fertility — and the likelihood of couples achieving pregnancy– have not been extensively studied.
"Our findings suggest that persistent organochlorine pollutants may play a role in pregnancy delay," said the study's first author, Germaine Buck Louis, Ph.D., director of the Division of Epidemiology, Statistics, and Prevention Research at the Eunice Kennedy Shriver National Institute of Child Health and Human Development (NICHD) at NIH.
Dr. Buck Louis added that individuals may limit their exposure by removing and avoiding the fat of meat and fish, and by limiting the consumption of animal products.

The study was published online in Environmental Health Perspectives and is available online at http://ehp.niehs.nih.gov/2012/11/1204996/.
Think the problem is only with leftover PCBs? Think again. PCBs are part of a category of chemicals known as persistent organochlorine pollutants (POPs) and include industrial chemicals and chemical byproducts as well as pesticides. In many cases, the compounds are present in soil, water, and in the food chain. The compounds are resistant to decay, and may persist in the environment for decades. Some, known as persistent lipophilic organochlorine pollutants, accumulate in fatty tissues. Another type, called perfluorochemicals, are used in clothing, furniture, adhesives, food packaging, heat-resistant non-stick cooking surfaces, and the insulation of electrical wire. This stuff is all around us. As are other endocrine disruptors.
And is this a good time to remind you that the Midlothian cement plants have all put in permits to burn more industrial wastes, including the shredded remains of older cars?

Even Low-Level Cadmium Exposure in Womb Can Lead to Lower IQ

By way of the Environmental Health News comes word of a new study looking at the effects on low-level, "ambient" levels of the toxic metal Cadmium on 5 year-olds in Bangladesh. 

Although the exposure pathway in the study assumes the Cadmium is coming primarily from a diet of food grown in contaminated soil, the results speak to the possible effects of any kind of risk – inhalation or ingestion.

"Prenatal exposures to the metal cadmium — even at low levels common in most countries — can have long-lasting effects on children's IQ. A study from Bangladesh found that 5-year-olds who were exposed through their mothers to higher levels had IQs that were 2 to 3 points lower than less-exposed children. The new evidence suggests that even low-level exposures before birth may have continued effects on children's brain function.On average, scores dropped by 2 to 3 points in children with the highest exposures when compared to those with the lowest exposures. Even small drops in IQ may affect a child’s ability to succeed at school and work later in life. Lower IQ's across the population also have large impacts on society."

Cadmium is a naturally-occurring metal contaminant found at low levels in the environment. Industry uses it to make batteries, coat and plate plastics and other metals, and make paint (remember Cadmium Red?). It's also emitted by car exhaust, the burning of industrial wastes, coal, and oil. When spread on fields, fertilizers and sewage sludge contaminated with cadmium can increase levels in cropland soils.

What are some possible local sources of cadmium in the air? The Midlothian cement plants that are now increasingly burning industrial wastes. Steel mills  – like the Ameristeel one in Midlothian. Lead smelters like the one Exide is closing up at the end of the month in Frisco, along with the slag and battery chips the smelter "landfarmed" in Frisco for decades. These are all in addition to the Cadmium you may be ingesting through your diet or by sucking on that cute charm bracelet you bought that was made in China.