Dow, Hefty and Keep America Clean’s proposal to burn plastics via bright orange “energy bags” in cement kilns is new but the idea of using kilns as industrial kitchen dispose-alls is not.

DFW has been identified as a national waste disposal destination because of its cement plants since at least the mid 1980’s. And as long as they continue to operate, the area will continue to be seen as a desirable dumping ground.

All these buildings, and roads, and “developments” have to be made out of something. They’re mostly made out of cement. In an area that’s grown by a Tyler or Richardson a year since 1970, cement is as ubiquitous as the air in your lungs. You just take it for granted. But it comes from somewhere and it gets made someplace.

Brought to you by…Cement!

In our case, that place is here – right over there, in Midlothian, just a couple of miles across the Dallas and Tarrant County lines to the south. You know, the direction the wind blows from most of the time.

And its a big place. There’s a Chamber of Commerce sign in downtown Midlothian proclaiming the town the “Cement Capitol of Texas.” There are three large cement plants – TXI, Ash Grove and Holcim – that quarry the limestone rock they need from the escarpment that runs north-south along I-35 for most of the length of the state. But the sign is too modest. Befitting one of the fastest growing areas in the country, it’s the largest concentration of cement manufacturing in the nation.

The Chamber of Commerce sign in downtown Midlothian

These aren’t batch plants. Think coal plants. Smokestacks hundreds of feet high. Furnaces, or kilns, as long as football fields. In 2015, the three plants released 475 tons of Particulate Matter pollution, 2040 tons of Sulfur Dioxide, and 510 tons of Volatile Organic Compounds – more pollution than the totals from entire North Texas counties.

That pollution goes somewhere. Depending on where you live, some of it lands in your lungs.

Holcim – one of three Midlothian cement plants

All three cement plants are in Midlothian to mine the limestone rock just like coal plants would strip-mine coal. Midlothian has a lot of cement kilns because that’s where the raw material for cement is, not because of any other reason.

But unlike coal, the limestone isn’t flammable and for there to be cement, the kilns must reach and maintain a flame of at least 1700 degrees F to bake the limestone with other ingredients. This is the way cement has been made since Rome perfected the process two millennia ago. You bake rock…just so.

And that flame is your number one operating expense as a cement plant owner. It accounts for up to 40% the costs of doing business. Anything you can do to reduce the costs of that flame saves you money. And that equation is the basis of constant mischief in the industry.

When the first Midlothian cement plant opened in 1960, and when the second one opened in 1965, the rock was baked with fire fueled by Texas natural gas. By the time the third cement plant opened in the mid-1980’s , the first couple of “energy crisis” had hit and they all three begun to burn cheaper coal.

The lance of the flame inside a cement kiln, or furnace

But another trend started in the 1980’s. Two of the three cement plants took advantage of a loophole in a new federal law and began burning hazardous wastes to bake their limestone rock.

Unlike gas and coal, the cement plants were paid by hazardous waste generators and middlemen to burn these wastes, so the plants not only saved the cost of buying fuel, they actually profited from becoming incinerators, and labeling waste as “fuel.” Hazardous waste burning at U.S. cement plants peaked in the 1990’s.

Air computer model of where the smog pollution from all three Midlothian cement plants goes during a typical year

Even after many cement plants have stopped burning hazardous wastes, they continue to burn “industrial wastes” like used oil, tires and shredded car interiors. When burned in kilns, these waste often produce exactly the same toxic air pollution as hazardous wastes. That’s what’s happening in Midlothian now. Although decades of citizen action have modernized the equipment and stopped the burning of official hazardous waste, the three cement plants continue to burn a wide variety of materials, and the pollution continues to blow wherever the wind takes it. 

As long as there’s limestone to be mined, the cement plants will remain open in Midlothian. As long as they stay open in Midlothian, they’re going to try to burn all kinds of wastes. When they do, they release a lot of toxic air pollution. And as long as the wind patterns stay the same that means that seven million DFW residents will be exposed to that toxic air pollution.

And that’s the reason why DFW is always just one multinational decision away from being downwind of a huge hazardous waste incinerator again, or a municipal waste incinerator, or a medical waste incinerator: Because we’re already downwind of the three hungry cement plants that need to burn any and everything they can get their hands on, the cheaper the better. And if they can get paid to throw things in the fire, well that’s a business formula they can get behind.  As long as they need to feed their flames, they’re out combing the streets for things to burn – including “hard to burn plastics” for an industry that needs its own greenwashing cover story. 

Until the manufacturing of cement no longer demands a sun-hot flame, or they run out of limestone rock, the Midlothian cement plants pose pose a huge on-going air pollution threat. The Dow project to burn plastics is just the latest, but not last, chapter. That’s why as long as there’s cement being made here, there also needs to be vigilant downwinders.

Anti-Litter Group “Keep America Beautiful” Teams-Up with Dow and Hefty to Burn Plastic Bags Full of Plastic Garbage in Cement Kilns 

And They Want To Do It Here…

 

We’ve been warning you for a while that garbage burning was coming to North Texas one way or another.

What we didn’t anticipate was that “Keep America Beautiful” would bring it.

That’s right. The same group that gave you Oscar “Iron Eyes” Cody crying over litter is now prepared to make your own eyes water and sting from the air pollution it wants to encourage by burning municipal solid waste, especially “hard-to-recycle” plastics.

Touting bright orange “energy bags” as a quick and easy alternative to throwing those plastics away, a news release issued by the Keep America Beautiful folks, your friends at Dow Chemical, and Reynolds, the makers of “Hefty” trash bags, claims they’re “a convenient way to collect plastic materials that would otherwise end up in the landfill and offers a platform to promote positive behaviors to prevent this material from being wasted.”

What they don’t tout as much is their alternative to throwing these plastics into a landfill – throwing them into a furnace.

As long as cement kilns need a high-temperature flame to make their product, they have large energy costs. Typically, 30% or more of the costs of running a cement plant is in buying the flammable materials necessary to keep that flame lit.


History has taught us that cement kiln operators will burn anything, including the kitchen sink, if they think it will help reduce those high fuel costs.

Kiln flames in Texas used to be powered by natural gas exclusively. Then it was coal. Then it was hazardous waste and coal. Then industrial wastes. And now municipal solid wastes. In bright orange plastic bags.

Cement plants don’t have to pay for the wastes, now termed “fuel,” for regulatory loophole purposes. In fact, because it’s now a “fuel,” they often get the waste for free or even get paid to burn it. It becomes a new center of profit in the company besides making cement.  Maybe even more important. In the 1990’s, there were plenty of rumors about how the TXI cement plant in Midlothian would burn a lot of hazardous waste they got paid a handsome fee to take, but not have much cement product to show for it.

While garbage burning cement kilns have been on the rise in the developing world, the practice hasn’t caught on in the U.S.

Dow’s and Keep America Beautiful’s friendly neighborhood “Energy bags” are a way to jump start it.

This is already happening in Omaha, where 8,500 homes have filled 13,000 “Hefty Energy Bags”  since the program’s launch in October. That’s resulted in more than 13,000 pounds of plastics being burned in a near-by Ash Grove cement kiln. They’re so excited about burning plastics at Keep America Beautiful that they’re not only endorsing the practice, they want to bring it to a cement kiln near you.

At a news conference to announce the offering of cash money grants to local communities who wanted to try the option, they unveiled a contiguous states map of the US where they’d like to see the “energy bag” concept implemented. The approximately 50 locations on the map identified by a red (not orange?) star are almost all sites adjacent to large cement plants – including Midlothian, immediately south of the Dallas and Tarrant Counties line, and home of the largest concentration of cement manufacturing in the nation. 

Local candidates for eager participation in the project include TXI, the cement plant that burned hazardous waste by the thousands of tons from 1987 to 2008, Holcim, which has sought permits to burn carpet scraps and shingles, and Ash Grove, the same operator as the one burning Omaha’s plastic bags now.


 

BURNING PLASTIC IS BAD FOR PUBLIC HEALTH AND PUBLIC POLICY

1. It replaces real recycling with burning.

Once you have a hungry garbage burner, you have to keep feeding it with more and more garbage, decreasing the market for real recycling.

This is already happening with tires. There are good tire recycling programs that can’t stay afloat because local governments have promised the local cement kilns a certain volume every year. 

2. It gives an incentive to the plastics industry keep to just making plastics that you can’t recycle.

Burning plastic garbage is like a relief valve on the growing piles of  “hard to recycle” plastics that industry is producing. Just throw it in a bag and send it to the kiln. Out of sight, out of mind. There’s no question it reduces the percentage of plastics going to landfill…only to increase the percentage of plastic going into your lungs. 

The real answer is to reduce and quit producing those “hard-to-recycle” plastics, not giving them a cheap way to get out of doing so.

3. Burning plastic produces lots of toxic air pollution – and all of DFW is downwind of Midlothian

Burning plastics produces toxic air pollution, a percentage of which escapes the smokestack and ends up in the air you breathe, the soil in your garden, and the food you eat and drink. Specifically, burning plastic creates lots of Dioxins and Furans – the same ingredients that made Agent Orange so toxic. The same poisons that made the State of Missouri evacuate the town of Times Beach in 1983.

Burning plastic also releases metals into the air, like cadmium and lead.

Other chemicals released while burning plastics include benzo(a)pyrene (BAP) and polyaromatic hydrocarbons (PAHs), which have both been shown to cause cancer. If plastic film or containers are contaminated with pesticides or other harmful substances, those will also be released into the air. If plastics are burned with other materials, whole new toxic chemicals may be created from the interaction of the different substances.

But wait! Don’t you want to divert more garbage from going to landfills?    

Yes you do, but by eliminating, reducing and recycling the garbage – not taking a match to it.

Landfills are nasty things. They’re big and smelly and they leak. Sometimes they leak and contaminate ground and surface water.  But these days you usually can trace the plume of those leaks and contain them before they get in drinking water.

On the other hand, once a piece of dioxin-contaminated soot is shot through a smokestack into the atmosphere, you have no idea where it’s going. You’re turning the whole sky into a landfill, full of solid and gaseous residues of refuse. What you didn’t want to drink, you’re now breathing. That’s the opposite of progress.


 

Taking a look at the Board of Directors for Keep America Beautiful, it’s no wonder they have a soft spot in their heart for large plastics manufacturers. They have not one, but two members from DOW, who, we are sure, thought this was a splendid idea. 

Howard Ungerleider is Vice Chairman and Chief Financial Officer of Dow, and Greg Jozwiak is the Business President for the Elastomers and Electrical and Telecommunications businesses for the company. Prior to assuming his current role, he served as North America Commercial Vice President for the Packaging & Specialty Plastics business. Hmmmm.

But wait, there’s more! KAB has a board guaranteed to offend just about everyone. Not content with two Dow executives, it also has two Nestle Corporation members, a representative of Waste Management Inc., McDonalds, Keurig, Anheuser-Busch, and Phillip Morrisyes, that Phillip Morris. 

“PEOPLE START POLLUTION. PEOPLE CAN STOP IT.”

Those are the words, spoken in a deep baritone by William “Cannon” Conrad, that ended that famous 1971 Keep America Beautiful commercial in honor of Earth Day. They ring as true now as then.

And so, people, we’re asking you to take action to discourage this kind of BAD IDEA from ever coming-up at a Keep America Beautiful board meeting again – send an email to their new Chair, Helen Lowman.

Ms. Lowman is a former FEMA and Peace Corps executive in the Obama Administration. She’s from Texas, worked at TCEQ, and graduated from Austin College…. So maybe messages from her fellow Texans will have more of an impact. 


TAKE ACTION:

 

TELL KEEP AMERICA BEAUTIFUL’s NEW CHAIR YOU DON’T WANT TO BREATHE TOXIC AIR POLLUTION FORM BURNING PLASTICS

SEND AN EMAIL WITH JUST TWO CLICKS

 

And if you want to leave a public message for the group too, here’s the group’s FaceBook site.

 


 

Other citizens groups, including some national alliances and networks are gearing up to take on this latest proof that all wastes, no matter how toxic, roll downhill to cement kilns eventually.

Meanwhile, Downwinders is taking the lead and beginning the push back we hope buries this project in the bright orange trash heap of history. Join us in not just saying “No,” but “Hell No.” Send that email now and then find two other people that will do the same. Thanks.

Group Picture CSC meeting 2

(Half of these people represent industry. Half are environmentalists. Can't tell which ones? That's a good thing.)

Should a bag of concrete be like an organic banana or a new chair made out of recycled wood and get "certified" as being responsibly-sourced, or "sustainable?" And if so, what's the criteria for making such a judgment, and who's making it?

Those are the complicated questions at the heart of a new worldwide initiative by the concrete/cement industry to come up with a way to sell its products in a more environmentally-friendly way.  

After a couple of years of working on a scoring scheme, the mostly European-based intra-company group (LaFarge/Holcim, Heidelburg, CEMEX) charged with designing the system was ready to unveil it to the international environmental community for the first time in mid-July at a small meeting in Gland, Switzerland, headquarters of the International Union for the Conservation of Nature, whose staff facilitated the review process. IUCN had performed the same function for the aluminum industry when it went through a similar "green" self-examination. 

Nine different environmental groups from at least seven different countries (Britain, Bulgaria, China, India, Lebanon, Switzerland) spent three days assessing and critiquing the industry's proposal – including the lone representative from the U.S., Downwinders at Risk's Jim Schermbeck. Participants not only met during the day, but ate together, and stayed in the same lone hotel in the small, outlying suburb of Geneva.  Inside the meeting room, discussions were often frank, funny, and awkward. Outside, conversations ran the gamut, from architecture, to vacation trips, to Texas BBQ. 

It's not a surprise that the concrete/cement business wants its relatively messy business to be seen through green-tinted glasses. Old timers will recall the burning of hazardous waste in Midlothian cement plants was relabeled "recycling" in the 1980's and 90's.  

But this time around, the pressure is not necessarily to greenwash the transformation of a cement kiln into a waste incinerator, but to give an environmental patina to the final product, concrete, so that it can compete in the marketplace with building materials that already have their own green certification schemes up and running. 

In other words, there appears to be new market pressure on the industry to "go green." Wood and Aluminum all now have their own systems for doing so. Concrete/Cement is lagging behind because it can't point to such a system. They want everyone from a construction site manager to a do-it-yourselfer to ask for "certified concrete" in the same way customers want wood that wasn't cut from a rainforest habitat, and aluminum made with Bauxite that wasn't mined at the expense of indigenous peoples.

Congratulations. Consumer demand for green products is so great that even the conservative cement/concrete industry feels the need to respond. 

But that's also not news to North Texans. Certainly one reason Downwinders had a seat at the table in Switzerland was our pioneering Green Cement campaign of 2006-2011 which used government procurement policies to reward less polluting Midlothian cement kilns and punish the dirtier plants. That was the first time the marketplace for cement had been used toward greener ends in the US.

While that local effort looked exclusively at the differences in air pollution impacts from the Midlothian cement kilns, this new initiative starts at the limestone quarry, includes the aggregate industry (sand and gravel) goes through the cement kiln, and then continues all the way to the concrete batch plant and the bag of Sakrete at the store. It looks at impacts to water supply and quality, air quality, energy use, climate change, and local populations at each of these stops along the product cycle. 

Much of the energy behind the initiative seems to come from a new generation of European industry representatives who've grown up with a different sensibility that takes green values for granted. More than one environmentalist noted a more open and questioning tone to the back and forth conversations. Whether this new attitude can be sustained and allowed to flow into real policy changes, is of course, the acid test of this first round, which must be finished for a pitch to the CEOs of the major industry players in December. Apparently the bosses are not entirely sold on the idea of needing such a certification at all, and, at times the whole idea had the air of being a kind of end-run around the Establishment by some Young Turks, albeit, corporately-backed. 

And there are some very large challenges that could sabotage any good intentions, primarily, the continued reliance on burning wastes for the substantial fuel needs of a cement kiln. As much as kilns have modernized, making cement still involves cooking rock at very high temperatures provided by a very hot, continuous flame. Something has to fuel that flame day after day, year after year. Just buying the fuel for that flame represents as much as 60% of the operating costs of a cement plant.

This is why companies are always looking for ways to cut those energy costs: by turning themselves into incinerators and charging generators to burn their toxic wastes, by getting subsidies from government to burn wastes like tires, by getting refuse from other industries which would otherwise have to pay to have them hauled away. In terms of large PR problems, none loom larger than the inherent one that goes with the introduction of burning wastes in the local kiln. That's how Downwinders got our start. 

But because of the volume of fuel needed as well as the required high temperatures, there are only so many kinds of things a kiln can practically burn. Midlothian kilns began by burning natural gas. If you're only looking at the end result of the flame, and not how the gas got here, it's still probably the cleanest source of fuel. Then there's coal, which is a no-go fuel in 2016 for all kinds of reasons. After that you get to wastes. Even if it doesn't have a permit to burn "hazardous" wastes, a kiln still can burn things like carpet pieces, plastics, shingles, and car "fluff." These are all materials that can release toxic air pollution when burned. Finally there's biomass – wood refuse, agricultural waste, or fuel crops themselves like sawgrass. Originally supported universally by environmentalists, these choices now have climate consequences that make them less desirable. 

These are not easy choices for industry….or environmentalists. Schermbeck made the offer to industry to sit down and work on an agreed "hierarchy" of wastes that would establish minimum high BTU value and low toxicity levels, as the group had done over a decade ago with TXI in a private mediation process that never panned out, but showed vast differences in fuel characteristics. At last word, the offer was being mulled over by industry along with all the other suggestions made by environmentalists. By October we should know how first round of assessment has changed the scheme – or not. Then another round of feedback from the environmental community, and a final decision by the end of the year. 

At stake is the potential to connect environmental progress and profit-making within one of the most environmentally-disruptive industries around. To establish performance floors, raise best practices, set new precedents. There are large risks and opportunities for both sides. 

Besides being close to the corporate headquarters of most of the major companies invovled, and home of the IUCN, Switizerland seemed the appropriate place for this first-time gathering for another reason. At the end, everyone arrived at as if on the edge of a metaphorical mountain precipice with a sizable, but not insurmountable gap separating where the industry is now, from where it needed to be. Whether that gap can be bridged any time soon remains to be seen. But the meeting in Gland was a good keystone to put in place for any future span designed for the job.

adhdOver the course of this blog, there have been countless "Air Pollution Linked to….." headlines. Not just diseases or illness you might associate with breathing bad air like COPD, or heart disease, or strokes, but Parkinson's, immune system breakdowns, Autism and so forth – ailments that seem to be skyrocketing even as Americans as a whole receive better medical care and live longer. Almost all the time these ailments are tied to "ambient" levels of air pollution, i.e. levels you might encounter if you lived in a typical city or…downwind of a large polluter.

The latest example of this phenomenon is study from Columbia University's Center for Children's Environmental Health, linking ambient levels of a particular kind of air pollution and the risk of Attention Deficit Hyperactivity Disorder, or ADHD in young children. The air pollution in question is a familiar one to Downwinders – Polycyclic Aromatic Hydrocarbons, or PAHs, that include a variety of nasty substances, including benzo[a]pyrene. PAHs are produced by from "incomplete combustion."

Downwinders first encountered PAHs because of the long list of "Products of Incomplete Combustion" from the burning of hazardous waste in the Midlothian cement plants. But they can be produced from the burning of fossil fuels, tobacco, or the organics that might be in a gas well flare. In addition, they can also show up in the food we eat.

In the Columbia study, 233 non-smoking African-American and Dominican pregnant women and their off spring living in New York City were followed for nine years. Almost half the children started out with detectable levels of PAHs in their cord blood at birth. As the study's authors point out, this is worrisome because "during the fetal period and early childhood years, the brain is rapidly developing and vulnerable to neurotoxic insults that may manifest as adverse outcomes in childhood and adulthood."

And that's exactly what the researchers found. Prenatal exposure to PAHs in umbilical cord blood at delivery was associated with developmental delay at age 3, reduced IQ at age 5, and symptoms of anxiety/depression and attention problems at ages 6–7. By age 9, children whose mothers had higher levels of PAHs in them at birth were five times more likely to be diagnosed with ADHD than those with lesser levels.

It's important to remember that this affect was caused by exposure levels in the ambient NYC air, not particularly "dirty air" by traditional standards. Populations who live downwind of coal plants, cement plants, large gas plays, or any large, continuing source of PAHs might be expected to experience higher rates of impact because their exposure levels are higher. 

And although this study focused on PAHs, the study notes that previous studies have identified "an association between ambient particulate matter (PM10) and childhood ADHD," a combustion pollutant even more common than PAHs.

Studies like these raise the same question time and again: how much of our current epidemic of childhood behavioral and developmental problems are caused by environmental factors within our control? With each successive year of research, we find links between "ambient levels" of environmental contaminants and a long list of health problems never before associated with pollution.

They also highlight the complete inadequacy of our current way of regulating pollution. As long as we're only regulating it from each source, instead of from a cumulative perspective, we're always be overdosing people with contaminants. By themselves, many different sources of air pollution can be churning out "safe" levels of things that can kill you. Combined downwind, not so much.

Haz mat suit - picnic tableEven though this EcoNews article is about air poisons that result from fossil fuel production, it applies to just about any combustion source, including cement plants, manufacturing plants, vehicles, and so on. It's a pretty good top ten list, although you wonder why Dioxins and Furans got left off, since they're toxic by the gram instead of pound. Also missing is Particulate Matter as a stand alone threat, although it gets a shout out as a by-product. Nevertheless, these are the among the most dangerous pollutants that have caused and are still causing a lot of problems in North Texas and elsewhere:

1. Benzene

Benzene is a well-established carcinogen with specific links to leukemia as well as breast and urinary tract cancers. Exposure to benzene reduces red and white blood cell production in bone marrow; decreases auto-immune cell function (T-cell and B-cells); and has been linked to sperm-head abnormalities and generalized chromosome aberrations.

Benzene is one of the largest-volume petrochemical solvents used in the fossil fuel industry. It is a major component in all major fossil fuel production: oil, coal and gas. People are exposed to it from inhaling automobile exhaust and gasoline fumes, industrial burning such as oil and coal combustion, and exposure to fracking fluids.

There's a recent Emory University study concluding that risk for leukemia fell with every mile between a person's home and facilities that release benzene.

2. & 3. Sulfur Dioxide (SO2) and Nitrogen Oxides (NOx)

Sulfur dioxide (SO2) and nitrogen oxides (NOx) are two primary examples of particle-forming air pollutants (particulate matter). Particulate matter is known to contribute to serious health problems, including lung cancer and other cardiopulmonary mortality. SO2 and NOx are both highly toxic to human health, and contribute directly to thousands of hospitalizations, heart attacks and deaths annually.

SO2 is particularly dangerous for children. Studies correlate SO2 emissions from petroleum refineries—even in lower exposure levels over time —to higher rates of childhood asthma in children who live or attend school in proximity to those refineries. Similarly, small particles of NOx can penetrate deeply into sensitive lung tissue and damage it, causing premature death in extreme cases. Inhalation of such particles is associated with emphysema and bronchitis.

4. Petroleum Coke (Pet Coke)

Pet coke is a by-product of oil processing that's also used as a fuel. It's a heavy dust which resembles coal. It's burned in power plants and cement plants. It contains dozens of dangerous chemicals and heavy metals, including chromium, vanadium, sulfur and selenium. It's a huge contributor to particulate mater and NOx and SOx formation 

5. Formaldehyde

Formaldehyde is a carcinogen with known links to leukemia and rare nasopharyngeall cancers, according to the International Agency for Research on Cancer. Formaldehyde is highly toxic regardless of method of intake. It is a potent allergen and genotoxin. Studies have linked spontaneous abortions, congenital malformations, low birth weights, infertility and endometriosis to formaldehyde exposure. Epidemiological studies link exposure to formaldehyde to DNA alteration. It is also contributes to ground-level ozone.

Independent studies,  have detected dangerous levels of formaldehyde in both wastewater and ambient air emissions from fracking operations. One researcher, with the Houston Advanced Research Center, said reading from one test site in North Texas, “astoundingly high,” and, “I’ve never heard of ambient (formaldehyde) concentrations that high… except in Brazil.”

6. Polycyclic Aromatic Hydrocarbons (PAHs)

In actuality, this is not a single listing—polycyclic aromatic hydrocarbons (PAH) is an entire class of toxic chemicals, linked together by their unique chemical structure and reactive properties.

Many PAHs are known human carcinogens and genetic mutagens. In addition, there are particular prenatal health risks: prenatal exposure to PAHs is linked to childhood asthma, low birth weight, adverse birth outcomes including heart malformations and DNA damage.

Additionally, recent studies link exposure to childhood behavior disorders; researchers from Columbia University, in a 2012 Columbia University study, found a strong link between prenatal PAH exposure and early childhood depression. Infants found to have elevated PAH levels in their umbilical cord blood were 46% more likely to eventually score highly on the anxiety/depression scale than those with low PAH levels in cord blood. The study was published in the journal Environmental Health Perspectives.

7.  Mercury

Mercury is a dangerous neurotoxin emitted from coal-fired power plants and any other combustion source using coal for fuel – like the Midlothian cement plants. It damages the brain and the nervous system either through inhalation, ingestion or contact with the skin. It is particularly dangerous to pregnant women and children. It is known to disrupt the development of the in-vitro brain. In low doses, mercury may affect a child’s development, delaying walking and talking, shortening attention span, and causing learning disabilities. High dose prenatal and infant exposures to mercury can cause mental retardation, cerebral palsy, deafness and blindness. In adults, mercury poisoning can adversely affect fertility and blood pressure regulation and can cause memory loss, tremors, vision loss and numbness of the fingers and toes.

One out of every six women of childbearing age in the U.S. have blood mercury levels that could be harmful to a fetus, according to EPA reports. The EPA estimates that  300,000 children are born each year at risk for significant development disorders due to mercury exposure.

8. Silica (Silicon Dust/Sand)

Crystalline silica (“frac sand”) is a known human carcinogen; breathing silica dust can lead to silicosis, a form of lung disease with no cure. This is a hazard in the cement industry and threat to those living downwind of cement plants, and now it appears to be one for natural gas roughnecks and adjacent homeowners as well.

Silica is commonly used, in huge amounts, during fracking operations. Each stage of the process requires hundreds of thousands of pounds of silica quartz–containing sand. Millions of pounds may be used for a single well.

The presence of silica in fracking operations, simply put, is a major safety risk with a high likelihood of dangerous exposure. Case in point: researchers from the National Institutes of Occupational Safety and Health (NIOSH) recently collected air samples at 11 fracking sites in five different “fracking states” (CO, ND, PA, TX and AR) to evaluate worker exposure to silica. Every single site had measures higher than the NIOSH threshold for safe exposureso high, in fact, that about one-third of the samples collected were even above the safe threshold for wearing a safety respirator mask. This was reported in May 2013 in the Journal of Occupational and Environmental Hygiene.

9. Radon

Radon is a colorless, odorless, tasteless radioactive gas which causes lung cancer. It is the second largest cause of lung cancer in the U.S. after cigarette smoking. About 20,000 people per year die from lung cancer attributed to radon exposure according to the National Cancer Institute. Further, there is no known threshold below which radon exposures carries no risk.

Radon exposure can come from a variety of natural sources. However, fracking (natural gas) represents a significant new and increased source of radon exposure to millions of citizens. Radon is released into local groundwater and air during fracking operations. It also travels through pipelines to the point of use—be it a power plant or a home kitchen.

The science behind radon release and exposure is complex but explained well here by Christopher Busby, the Scientific Secretary of the European Committee on Radiation Risk, who warns that radon dangers from fracking “have not been addressed properly (or at all) by the environmental impact statements published by the operators, or by the Environmental Protection Agency in the USA.”

10. Hydrofluoric Acid (HF) / Hydrogen Fluoride

Hydrofluoric acid (HF) is “one of the most dangerous acids known.” HF can immediately damage lungs, leading to chronic lung disease; contact on skin penetrates to deep tissue, including bone, where it alters cellular structure. HF can be fatal if inhaled, swallowed, or absorbed through skin.

The senior laboratory safety coordinator at the University of Tennessee said, “Hydrofluoric Acid is an acid like no other. It is so potent that contact with it may not even be noticed until long after serious damage has been done.”

Hydrofluoric Acid is a common ingredient used in oil and gas extraction.

Numerous studies, including recent ones conducted by both The Center for Public Integrity (CPI) and the United Steelworkers Union (USU) cite the oil industry’s abysmal safety record as a high risk factor for a major HF accident; over the past decade, more than 7,600 accidental chemical releases from refineries have been reported by the industry. In the past three years alone, a total of 131 “minor” accidents involved HF.

cement1Downwinders has been trying to get new emission limits for cement plants since the mid-1990's. We're still trying.

The first real reform in those rules during the Clinton Administration were pathetically inadequate. Downwinders and other groups assisted by DC-based Earth Justice sued to get them strengthened. We won. When new rules finally emerged from EPA in 2009, they were much better. Many of you came out to the historic national hearing at the DFW Airport hotel to testify in favor of them.

These rules were on their way to being signed by President Obama when they got hijacked by industry at their stop at the Office of Management and Budget, which must review all new regulations. When they emerged, they were unrecognizable in many ways, with deadlines pushed back by years and the important Particulate Matter standard being significantly weakened.

Once again, we're back in court trying to get these watered down rules thrown out. Last week, the DC appeals court that usually takes up federal regulatory fights heard oral arguments from both sides, and even the Republican judges on the panel were skeptical of the Administration's rewrite job.

Reprinted in full below is an inside-the-Beltway account of the proceedings that gives you some idea of what's at stake and what a good day citizens and their representatives enjoyed in court. No date on when to expect a ruling. Even then, if we win, the rules go back to EPA to be rewritten again, albeit with more judicial constraint…theoretically at least.

Judges seem skeptical of EPA claims in cement emissions case

Jeremy P. Jacobs, E&E reporter

Published: Thursday, October 24, 2013

Public health advocates argued in court today that U.S. EPA unlawfully weakened and delayed air standards for cement manufacturers, appearing to gain some traction with a panel of federal appellate judges.

The Natural Resources Defense Council contends EPA caved to industry pressure when it revised its National Emission Standards for Hazardous Air Pollutants, or NESHAP, for portland cement kilns and pushed back its compliance date by two years.

EPA's standards apply to several pollutants, including particulate matter, mercury and other acid gases. The agency revised the particulate matter standard after a court ruling in 2011, but advocates claim the agency did more than the ruling required.

James Pew of Earthjustice, representing the NRDC, told the U.S. Court of Appeals for the District of Columbia Circuit that EPA "gratuitously weakened the particulate matter standard" and violated the "plain and literal meaning" of the Clean Air Act.

Further, he said, many of the issues EPA addressed with its changes "didn't come up" in the previous case.

The cement NESHAP has long been the subject of controversy and litigation.

The kilns are one of the top sources of man-made mercury emissions in the United States. Public health advocates forced EPA to set the standards in a 2010 lawsuit, and when the agency issued the standards later that year it said they would prevent 960 to 2,500 deaths per year.

Industry, however, quickly challenged the standards at the D.C. Circuit. In December 2011, the court ordered EPA to reconsider the standards by taking commercial incinerators that burn solid waste out of its calculations. However, the court largely left the standards in place, including their 2013 compliance deadline (E&ENews PM, Dec. 9, 2011).

When EPA recalculated the standard for particulate matter, the advocates claim the agency made it less stringent. Additionally, EPA reached a settlement with the portland cement industry to delay compliance to September 2015 for all pollutants — not just particulate matter (Greenwire, Dec. 7, 2012).

Public health advocates challenged both actions, as well as a shift from continuous monitoring to one-time annual stack testing for compliance — which also changed the particulate matter standard. The environmentalists also question the standard's inclusion of an "affirmative defense" that protects kilns from citizen lawsuits if they violate the standards during an unavoidable malfunction.

Each issue came up today before a three-judge panel, which included two judges who are considered potential future Supreme Court nominees. The panel appeared receptive to some of the advocates' arguments but not to others.

For example, Judge Brett Kavanaugh, one of the country's leading conservative jurists, appeared skeptical of EPA's decision to delay standards for mercury and other gases to 2015, even though the Clean Air Act says standards must take effect within three years. The 2010 standards for those pollutants, which weren't affected by the D.C. Circuit ruling in 2011, should be in effect now.

"I don't understand," said Kavanaugh, a Republican appointee. "I need help. I don't understand the interrelatedness."

Further, Senior Judge Harry Edwards, a Democratic appointee, said EPA could have easily linked the standards by saying it wasn't "practicable" to meet some without meeting the others. But EPA, Edwards said, never made that argument in the rulemaking.

"I'm really not following this," Edwards said. "Where does the agency make the finding … that compliance couldn't be done practicably?"

Matthew Oakes of the Department of Justice, representing EPA, countered that all the standards are related because the pollution control technology required to limit particulate matter also controls emissions of mercury and other gases. Therefore, it didn't make sense to require kilns to install technology for mercury, for example, before it knew the final particulate matter standard, he said.

That argument was echoed by Carter Phillips of Sidley Austin LLP, representing the cement industry, which intervened in the case.

"You cannot implement any of them in a one-off system," he said.

It was unclear which way the judges were leaning with regard to the advocates' arguments surrounding the particulate matter standard itself. But they appeared receptive to their challenge to EPA's affirmative defense.

Oakes argued that the advocates lacked standing to challenge the affirmative defense, meaning they had failed to prove how they would be injured by it. That notion was flatly rejected by the panel, which said the defense would allow kilns to, at times, exceed the standards, which would harm human health. Therefore, the advocates have grounds to bring the lawsuit, the judges said.

The panel was also skeptical of EPA's arguments on the substantive issue of whether EPA could create the affirmative defense in the first place. Judge Srikanth Srinivasan, President Obama's first appointee to the D.C. Circuit and a leading liberal judge, contended that the Clean Air Act didn't grant EPA that ability.

"This authority wasn't delegated to the EPA to begin with," he said.

preemie4A new study being published in the November issue of Epidemiology concludes that even low levels of pollution from solid waste incinerators causes an increase in premature births downwind.

Italian researchers examined over 21,000 births to women living within four kilometers of one of eight solid waste incinerators operating in the Emilia-Romagna region.

"Each newborn was georeferenced and characterized by a specific level of exposure to incinerator emissions, categorized in quintiles of PM10, and other sources of pollution (NOx quartiles), evaluated by means of ADMS-Urban system dispersion models. We ran logistic regression models for each outcome, adjusting for exposure to other pollution sources and maternal covariates.

 Preterm delivery increased with increasing exposure….A similar trend was observed for very preterm babies. Several sensitivity analyses did not alter these results. Maternal exposure to incinerator emissions, even at very low levels, was associated with preterm delivery"

Now, you can reassure yourself that we have no single-purpose solid waste incinerators around these parts the way they do on he East Coast or Midwest, so we don't have to worry about this kind of threat. But that's not entirely accurate.

We do have solid waste incinerators in North Texas, they're just called cement kilns. And we have more incinerator capacity than anyone else in the country when it comes to cement kilns.

And, as it turns out, these cement kilns are expanding their lists of available "fuel" to include solid wastes, as well as coal – medical, municipal, and "hard to burn" plastics, as well as car parts, shingles and carpet remains. It's all part of the new wonderful world of commercial garbage burning. If the kilns happen to make some money in the process of turning themselves into under-regulated incinerators, well, all the better for their operators. 

For example, and try not to throw up, in the Philippines, the local cement plant is marketing the burning of "Holcimables." What are "Holcimables" you ask? They're "plastics – styrofoam, sando bags, cellophanes and foil packs – textile and rubber." Yes, the same company that operates a cement kiln in North Texas is burning styrofoam in the name of environmental-friendliness in the Philippines. You can bet the Italian incinerators included in this new study were burning some of the same kinds of wastes with the same ingredients.

Burning stuff is bad, whether it's in an incinerator or a cement kiln. And industry is making it very hard  to tell the difference.

The Devil BurnsFor the first time in 30 years recycling rates in the UK are going down and a influx of incineration capacity is being blamed.

New European Union directives favoring waste burning over recycling are now spreading throughout Great Britain and having a big impact. Landfill disposal has gone down by almost 50% in just over a decade. Meanwhile there are now 39 incineration plants in the UK that have either been built are under construction or are at the planning stage – so many that there are now concerns about overcapacity. Moreover, every time an incinerator is chosen over other options, it institutionalizes the economics of incineration.

Experts said the use of incinerators had consequences for recycling as local authorities were forced to divert waste to feed the plants. "The choice to invest in thermal treatment can hold back recycling efforts," Adam Baddeley, principal consultant at Eunomia, said. "At one level, the money invested in such plant simply isn't available to put into building recycling plants or collection infrastructure. And once you've built an incinerator or gasifier, there's a strong incentive to keep it fed with waste, even if that means keeping on collecting as 'black bag' rubbish, material that would be economically practicable to collect separately for recycling."

Because Texas is still home to relatively cheap and abundant land, it hasn't seen the wave of incinerators that swallowed up the budgets of East Coast and Midwestern towns throughout the 1980's and 90's. But that may be about to change with increased urbanization, the desire of cities to profit from their garbage somehow, and new regs that are written to encourage incineration of "biofuels" that can include waste. Some local observers think it's only a mater of time before a large garbage incinerator is proposed for the Dallas area.

But why wait when you've got three large cement plants down the road?

Hazardous waste was burned in two out of the three Midlothian cement plants for decades and now all three are burning different kinds of solid wastes, including tires, car parts, and "non-recyclable" plastics. They're the front line in the March of Incineration in North Texas.

carbon black

Carbon soot found in Particulate Matter air pollution is responsible for increasing death risks in US cities according to a new nationwide study conducted by John Hopkins, Yale and Harvard. 

“Our work indicates that some constituents of PM2.5 may be more toxic than others and therefore regulating PM total mass alone may not be sufficient to protect human health,” the authors wrote in Environmental Health Perspectives.

Figuring out which ingredients are the most dangerous could help local air pollution agencies hone in on certain sources, making regulations more targeted.

“By identifying PM2.5 constituents that are more toxic, we can move towards developing source-specific air pollution regulation that may be more effective at protecting public health,” the authors wrote.

The study included data from 72 American cities, but that data was limited in a way familiar to downwinders – PM monitors often only took measurements every 6th day.

Particulate Matter, or PM, are microscopic leftovers of combustion that you can not only breathe, but also absorb into your blood stream. PM pollution has been linked to an increasing number of health effects, including asthma, heart attacks, strokes, and immune and brain disorders. Many scientists identifying these effects have concluded there probably isn't a "safe" level of exposure to PM – that any amount is capable of doing some kind of short or long-term harm.

PM pollution comes out of everything that burns something – fires, boilers, furnaces, and internal combustion engines. Locally, cars and trucks, the Midlothian cement plants, and the natural gas industry are the largest sources of industrial PM.

ruptured appendixAccording to CBS News

"A new study published July 10 in The Lancet showed that even breathing low levels of air pollution for a prolonged period of time could raise risk for the often-deadly lung disease. Another study released on the same date showed that short-term exposure to most major air pollutants could increase the risks of hospitalization and death from heart failure."

Lung cancer risks went up 18% with each increase of 5 migrograms of PM 2.5. Researchers noted that they did not find a level of pollution for where there was no risk, and the results indicated "the more the worse, the less the better" when it came to pollution.

"At this stage, we might have to add air pollution, even at current concentrations, to the list of causes of lung cancer and recognize that air pollution has large effects on public health," Takashi Yorifuji from the Okayama University Graduate School of Environmental and Life Science and Saori Kashima from Hiroshima University in Japan…."

A second study shows the risk of dying or going to the hospital because of heart failure increased by 3.52 percent for every 1 part per million increase of carbon monoxide levels; 2.36 percent for every increase of 10 parts per billion of sulfur dioxide; 1.7 percent for ever 10 parts per billion increase in nitrogen dioxide; and about 2 percent for every 10 micrograms per cubic meter increase of particulate matter. Surprisingly, increases in ozone were not linked to heart failure. Unsurprisingly, you're breahting in all of these kinds of air pollution if you live in DFW.

All of that is kind of old news – put stuff in air, see stuff harm your lungs and heart. But here's a new "adverse health effect" being linked to air pollution – appendicitis. While not as lethal as lung cancers and heart attacks, anyone who's had their appendix rupture can tell you it's not a pleasant experience.

And while ozone may not have been linked to heart problems in that previous study, the New York Times reports a Canadian one links it to a slight increase in your chances of having appendicitis.

High ozone levels were associated with an increased number of hospitalizations for appendicitis and were even more strongly associated with cases of burst appendix. For each 16 parts per billion increase in ozone concentration the scientists found an 11 to 22 percent increase in ruptured appendix cases. The study was published in Environmental Health Perspectives. The associations persisted after controlling for age, sex, season of the year and the presence of other air pollutants, like nitrogen dioxide and particulate matter. The reason for the association is unclear, but studies in mice have shown that air pollution can alter the animals’ abdominal bacteria.

Who knew?