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
NOVEMBER 16, 2012 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
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."
"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."
"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)."
Texas Monthly's Paul Burka has written about some e-mails that went flying back and forth among Texas Republican lawmakers as the bitter re-districting battle took place over the last 12-15 months. Some of them have become public. One of these reveals what Texas House of Representatives Speaker Joe Straus thinks about Midlothan-area Congressman "Smokey" Joe Barton and his supporters in their attempts to gerrymander a new, more Republican district for the Congressman (since Arlington is getting a bit too purple for his taste). Welcome to the reality based community Speaker.
A new analysis of the historic 2009 Cook Children's Hospital survey of regional childhood health confirms that higher levels of Tarrant County childhood asthma track closely with the downwind pollution plume coming from the three Midlothian cement plants in adjacent Ellis County.
According to researchers Patricia Newcomb and Alaina Cyr from the UTA College of Nursing "…the bulk of Tarrant County asthma cases lie directly in the path of southeasterly winds that have historically carried high levels of particulate matter from working cement kilns in a neighboring county. Asthma prevalence increases in a linear configuration within the path of the 'cement plume' as residential location comes closer to the cement kiln area."
Exposure to Particulate Matter pollution, or soot, is a well-known known cause for asthma. It can also make a child's asthma worse.
"This latest study is one more piece of empirical evidence that we need to decrease pollution from the Midlothian cement plants to secure the right of our children to breathe without getting sick, " said Jim Schermbeck, Director of Downwinders at Risk, a local group originally founded in 1994 to oppose the burning of hazardous waste in the Midlothian cement plants.
Proximity to the pollution from the three Midlothian cement plants was the only environmental factor geographically associated with higher concentrations of childhood asthma, ruling out poverty and indoor air pollution. There also wasn't a strong correlation to urban gas drilling, although the authors concede that "urban drilling may play a part as well" in the region's higher than normal child asthma rates, and there was no direct comparison between the geography of drilling activity and area asthma levels.
In 2009, Cook Children's Hospital released its Community-wide Children's Health Assessment and Planning Survey (CCHAPS), the largest examination of childhood health in North Texas ever undertaken. It found that Tarrant County and the western side of the North Texas region suffer childhood asthma rates significantly higher than state and national averages.
In "Conditions Associated with Childhood Asthma in North Texas," published in the October edition of ISRN Allergy, Newcomb and Cyr revisit the Cook study and delve more deeply into its data. "The purpose of this study was to identify significant associations between asthma diagnosis, comorbid conditions, and social problems in children." The complete article can be accessed on the Cook Hospital CCHAPS website page devoted to asthma, under "Special Reports."
Midlothian is the home of the largest concentration of cement plant manufacturing capacity in the United States. It hosts three large cement plants – TXI , Holcim and Ash Grove – with a total of six kilns. They are the largest stationary sources of pollution in North Texas. Reports submitted by the plants themselves show they poured over a million pounds of Particulate Matter pollution into the North Texas air in 2009.
EPA recently announced that it was considering once again delaying the implementation of new federal emission rules, including stricter particulate matter pollution standards, from 2013 to 2015 that have been in the works for two decades. The delay would also water down proposed PM pollution standards. Schermbeck said Newcomb and Cyr's analysis shows the real world costs of such a rollback.
"It's a scientific fact, endorsed by EPA, that inhaling tiny bits of particulate matter can make people sick and even kill them. What this study makes clear is that the agency is senselessly condemning more Tarrant County kids to illness and suffering by delaying rules that were supposed to have been in place in the 1990's. It's time to start saving lives by reducing this kind of pollution."
A national research team that includes personnel from The National Cancer Institute, Colorado Sate University, the University of Washington, and the Mayo Clinic has concluded that homes within one to three miles of cement plants contain house dust that contains 2 to 9 times more Dioxins than homes not located near kilns.
Dioxins are among the most toxic substances ever tested by EPA. Dioxin is the poison in Agent Orange. It's what made both Love Canal in New York, and Times Beach Missouri Superfund Sites. It's so toxic it's measured in grams, not pounds. It's a carcinogen and an endocrine disrupter. Like Lead and Particulate Matter, there is no known "safe" exposure level to Dioxin.
40 homes across four states were chosen from an earlier non-Hodgkin lymphoma study. Samples of dust were collected from vacuum cleaner bags and test for a variety of Dioxins (the testing for Dioxins is VERY expensive and that's one reason you don't see a lot of field tests for it). Four kinds of dioxin-emitting facilities identified by EPA were in close proximity to one or more of the sampled households – cement kilns, coal plants, sewage sludge incinerators, and medical waste incinerators. Proximity to major roadways was also considered a separate source. But "high concentrations" of Dioxins were only associated with homes near cement plants. Major roads also saw "elevated" levels, but not nearly as much as kilns.
The full study was recently published in the September edition of "Science of the Total Environment."
Midlothian currently hosts six active cement kilns. There were as many as ten up until 2008. It is the largest concentration of cement manufacturing in the nation. And all of DFW is downwind of it most of the year.
As we mentioned last week, a 1999 study by Barry Commoner and his group out of Washington University in St. Louis traced Dioxins from the TXI cement plant all the way to the Arctic Circle. So don't feel safe if you think you live far enough downwind not to be affected by the Midlothian plant plumes.
For years, Midlothian residents and others have been asking the federal government for a meaningful health effects and testing protocol for determining the total load of dioxins in and around these kilns. It hasn't come. Their requests were based on published higher incidents of certain kind of birth defects in Ellis County, as well as clusters of animal health effects observed by local ranchers and breeders. And these observations started when hazardous waste burning began in the mid-1980's. EPA has stated that waste-burning kilns release more dioxin than non-waste burning ones.
So it's important to remember that the astounding high concentrations of Dioxins that were located in homes in close proximity to a a cement kiln were linked to a kiln not burning hazardous waste. Granted, we don't know what kind of "non-hazardous wastes" it might have been burning, but the results begs the question about how much higher Dioxin levels might be in a place like Chanute, Kansas where Ash Grove's kiln is still burning hazardous wastes.
And it also once again points out why we can't be complacent about the kilns in Midlothian just because they quit burning the worst of the worst toxic wastes. Even without that practice, they pose an on-going clear and present danger to the region's public health from just their "routine" emissions. Now that all of them have or want permits to burn plastics and garbage, you could reasonably expect to see an increase in Dioxins and other forms of more exotic pollution spewing out of their tall smokestacks. And you know why their so tall don't you? So that the pollution they're releasing travels further downwind.
In Coimbatore, plastic and leather wastes stockpiled waiting to be burned as "fuel" at the Madukkarai cement works spontaneously combusted in a three hour fire that did not result in any known injuries at the plant.
However, thick columns of black smoke poured into the sky and that stuff, as the late Dr. Commoner would note, has to go somewhere. A lot of it will no doubt dind its way into the lungs of downwind residents. More than 200 tons of waste was gutted in the fire out of at total twice as large.
Despite local fire officials urging the cement plant to enclose the waste for some time, it had not done so. That is an apparent violation of state law. And readers, will it surprise you in the least to learn that the plant was already a longtime source of complaints from local residents?
Meanwhile the Fire and Rescue Services Department officials pointed out that storing combustible waste materials outside the plant without adequate protection was in violation of the Tamil Nadu fire service rule of 1990.
"It is a violation of section 250 of Tamil Nadu Fire Service Rules 1990 and we will issue a notice to the factory and will give them 15 days to store the waste materials inside a roofed structure with protective walls," said Subramanian.
Residents have been protesting against the cement factory for a long time and have submitted numerous petitions to the district administration. They claimed that the dust and smoke from the factory was causing major health complications, especially for senior citizens and children.
"We have raised the issue on numerous occasions and also submitted petitions to the district administration but till now no action has been taken," said C Palaniswamy, a resident of Kurumbapalayam.
There is a premeditated and orchestrated campaign by the cement industry to allow kilns to become garbage burners of all kinds of wastes. We've seen it manifest itself locally in Midlothian with the TXI permit that allows that plant to burn car parts and plastic wastes.
The more kilns that become gargabe burners, the more garbage of dubious content will pile up at kilns, the more often that garbage causes a fire. We've reported on three just since the summer alone. Being downind of an uncontrolled garbage fire isn't one of the talking points the industry boasts about when it's trying to sell kilns as the industrial equivalent of Kitchen disposals, but it's looking more like a standard feature rather than an option.