DFW SIP
New UNT Study-In-Progress Links Gas Pollution to Persistent DFW Smog
This is why it's important for citizens to have real scientific horsepower.
DFW has a smog problem. It's not as bad as it used to be, but it's still at unsafe and illegal levels. And for the last four or five years, the air quality progress that should have been made has been stymied. Despite almost all large sources of smog-producing pollution being reduced in volume, our running average for ozone is actually a part per billion higher than it was in 2009.
Many local activists believe this lack of progress is due to the huge volumes of smog-producing air pollution being generated by the thousands of individual natural gas sites throughout the DFW region itself, as well as upwind gas and oil plays. In 2012, a Houston-based think tank released a report showing how a single gas flare or compressor could significantly impact downwind smog levels for up to 5 mile or more. Industry and the Texas Commission on Environmental Quality say no, gas sources are not significant contributors to DFW smog. In fact, during this current round of planning, the state has gone out of its way to downplay the impact of gas pollution, including rolling back previous emission inventories and inventing new ways to estimates emissions from large facilities like compressor stations.
Into this debate steps a UNT graduate student offering a simple and eloquent scientific analysis that uses the state's own data on smog to indict the gas industry for its chronic persistence in DFW – especially in the western part of he Metromess, where Barnett Shale production is concentrated.
On Monday night Denton Record-Chronicle reporter Peggy Heinkel-Wolfe gave a summary of a presentation on local air quality she'd sat through that day at UNT:
"Graduate student Mahdi Ahmadi, working with his advisor, Dr. Kuruvilla John, downloaded the ozone air monitoring data from the Texas Commission on Environmental Quality back to 1997, a total of more than 6.5 million data points, he said, and has been studying it for the past four months.
Ahmadi wanted to explore a basic question underlying a graphic frequently distributed by the TCEQ that shows gas wells going up in DFW as ozone goes down, which suggests in a not-very-scientific-at-all way, that the increasing number of gas wells is having no effect on the ozone.
Ahmadi adjusted for meteorological conditions to determine how much ozone DFW people are making and where. Such adjustments have been explored by others to understand better the parts of ozone-making we can control, because we can’t control the weather. He used an advanced statistical method on the data, called the Kolmogorov-Zurbenko filter, to separate the effects of atmospheric parameters from human activities.
According to the results, the air monitoring sites surrounded by oil and gas production activities, generally on the west side of DFW, show worse long-term trends in ozone reduction than those located farther from wells on the east side of DFW.
His spatial analysis of the data showed that ozone distribution has been disproportionally changed and appears linked to production activities, perhaps an explanation why residents on the western side of DFW are seeing more locally produced ozone, particularly since 2008.
Ahmadi's results are not definitive, and the paper he's writing is still a work-in-progress. But he's asking the right questions, and challenging the right unproven assumptions. He's at least put forth an hypothesis and is trying to prove or disprove it. He's using science. TCEQ's approach is all faith-based.
Anything that takes the focus off vehicle pollution is anathema to Austin and many local officials who want to pretend that industrial sources of air pollution don't impact the DFW region enough to make a difference so they don't have to regulate them. If there's a guiding principle to TCEQ's approach to this new clean air plan, due in July 2015, it's to avoid any excuse for new regulations while Rick Perry is running for President. The agency isn't interested in doing any kind of science that might challenge that perspective – no matter how persuasive. After all, you're talking about a group that doesn't believe smog is bad for you. TCEQ doesn't want to know the truth. It can't handle the truth. It's got an ideology and it's stickin' to it.
So it's up to young lowly graduate students from state universities armed only with a healthy sense of scientific curiosity to step up and start suggesting that the Emperor's computer model has no clothes, and offering up alternative scenarios to explain why DFW air quality is stuck in neutral. It turns out, just doing straight-up classroom science is enough to threaten the fragile House of Computer Cards with which the state's air plan is being built.
Perhaps equally as ominous for the success fo any new clean air plan is Ahmadi's discovery that ozone levels in DFW have been during the winter time, or "off-ozone-season." There could be a new normal, higher background level of smog affecting public health almost year round.
Mahdi Ahmadi's study is just one of the many that need to be done to construct an honest clean air plan for DFW, but it shows you what a curious mind and some computing power can do. Citizens can't trust the state to do the basic science necessary as long as the current cast of characters is running the show in Austin. EPA won't step in and stop the farce as long as TCEQ can make things work out on paper. If the scientific method is going to get used to build a better DFW clean air plan, it's going to have to be citizens who apply it.
What are the Pollution Impacts of the New Liquified Natural Gas Plant Announced for Midlothian?
If you're already hosting the three or four largest single sources of air pollution in the entire region you need new large industrial sources of crap like a hole in the head. Likewise, if you've already violated the Clean Air Act for decades the last thing you need are new large sources of smog-producing pollution. But that's exactly what's happening with the announcement last week that a new Liquified Natural Gas (LNG) plant is being proposed for Midlothian's Railport Industrial Park, located between Midlothian and Venus on Highway 67, directly below, and upwind, of the Dallas-Tarrant County line.
Applied Natural Gas Fuels (ANGF) put out a press release on March 21st that touted the purchase of 31 acres for a facility that would house "five liquefaction units, each able to produce 86,000 gallons of fuel daily, and total onsite storage of 1.5 million LNG gallons."
"In preparation of building the facility, which was announced last September, ANGF has purchase orders for all long-lead time items, such as storage tanks, production skids and electric motors and compressors, the company said.
The plant seeks to supply both road transportation and other off-road high-horsepower applications, such as rail, marine, mining, remote power generation and oilfield exploration/production (E&P) operations."
LNG plants take natural gas and cool it to minus 260 degrees F, at which point it becomes a liquid. This allows the industry to be able to store and move it compactly. It's been described as reducing the air out of a beach ball to shrink it to the size of a ping pong ball. But it also greatly increases the chances of accidents. If there's a leak or spill from a tank or pipeline the LNG would convert back to a gas. As it diluted with air, the natural gas/air mixture could become potentially explosive if the concentration of natural gas in air reached between 4% and 17%. In this range, any source of ignition (cell phone, cigarette lighter, attic fan, light switch, auto or boat engine spark plug, carpet spark, etc.) could ignite a vapor cloud and impact a large area.
ANGF already operates an LNG plant in Topock, Arizona, only three miles on the other side of California's border – and tougher regulations. At the same time it's building its new facility in Texas, the company is also doubling the capacity of the Arizona plant. According to an online document about the company's current operations from the Southern California Air Pollution Control District,
"…the gas must be stripped of impurities until it's over 98% methane. Co2, H2S, other sulfur components, moisture, mercury, and particles are stripped via acid gas removal and disposal, gas dehydration, mercury removal, and particle filtration…. The emissions associated with these processes include CO, VOC, SOx, NOx, H2S, particulates, and many toxic organic compounds."
That's Carbon Monoxide, a poison everyone's familiar with, Volatile Organic Compounds, a smog-producing class of chemicals like Benzene and Toluene, many of which are also carcinogenic, Sulfur Dioxide, a respiratory irritant which also causes acid rain, Nitrogen Oxide, a smog-producing respiratory irritant, PM pollution that's been linked to everything from heart attacks to Parkinson's, Mercury, a notorious neurotoxin, and oh yes, Hydrogen Sulfide, or "sour gas," a highly toxic and flammable poison that causes pulmonary edema at low concentrations and death at high ones.
We don't have specific annual volumes of those pollutants for the Midlothian plant yet, and may never get them if the facility receives a standard permit with only an upper ceiling of emissions, but LNG plants use a lot of energy, and therefore have the potential to emit a lot of air pollution. It appears that the Midlothian plant will be burning natural gas for its power, including huge gas turbine compressors. At much larger LNG export plants proposed for the coasts, these compressors have been the subject of a lot of concern. Last November, a Canadian wildlife conservation group released a report on a string of proposed LNG plants for British Columbia that estimated the facilities would be burning most of the gas used in the Province,
"The report, Air Advisory: The Air Quality Impacts of Liquefied Natural Gas Operations Proposed for Kitimat, B.C., concluded LNG plants permitted to operate primarily with natural gas will collectively burn 60 per cent of all the natural gas burned annually in B.C.
The report concluded nitrogen oxide emissions from the LNG plants would increase 500 per cent above existing levels. Nitrogen oxide emissions create acid rain, which harms waterways and fish and creates smog, which causes respiratory problems for children and the elderly, the report states.
The report also concluded natural gas driven LNG plants will increase emissions in the Kitimat area of volatile organic compounds, carbon monoxide and sulphur dioxide."
As a result of these kinds of concerns, the Canadian government committed to spending over a half million dollars on a study of how the gas industry will affect air quality in this part of British Columbia.
The Midlothian plant will be much smaller, put its impact on local and regional air quality could still be substantial depending on the design and technology. Industrial Hydrogen Sulfide and VOCs are not something you want wafting into your backyard, and anything that makes more smog is bad news for the entire DFW region.
Locating in Railport – itself a piece of heavy-metal contaminated ranch property bought and developed by TXI to prevent further liability issues – the LNG plant adds to the inventory of polluters that call Midlothian home. Three large cement plants, a steel mill, a gas power plant, and other smaller entities have made sure the city is the closest thing to a DFW Ship Channel that we have. Collectively, these facilities emit a kind of super plume of air pollution that spews north into the middle of the Metromess during most of the year. If you live anywhere from SW Dallas to NW Tarrant County, you're already breathing the pollution from Midlothian industry. How much the ANGF facility will add to that plume is not yet known, but any increase is going in the wrong direction. Stay tuned.
Eagle Ford Follow-Up: Your Tax Dollars at Work
There's not much of a local air planning process left in DFW. What remains is an irregularly-scheduled "technical committee meeting" that mostly involves the staff of Rick Perry's Texas Commission on Environmental Quality explaining how their new anti-smog plan will be successful without the addition of any new pollution controls. But after this explanation any members of the audience can ask questions about the presentation. And if they need to, they can ask follow-up questions. It's the only forum where citizens can do this with a real live TCEQ staffer and the staff is expected to respond. You may not like their response, but there is an exchange.
The value of a place where citizens can ask questions of TCEQ and expect to get answers rises when one reads about how difficult it was for the reporters working on the huge Eagle Ford expose published last week to get anyone at the TCEQ to answer their questions at all, much less in person. In a sidebar piece that ran with the original piece, titled "How We Got the Eagle Ford Story," they explain the obstacles the state put in their way,
The agency responsible for regulating air emissions—the TCEQ—refused to make any of its commissioners, officials or investigators available for interviews. Instead, we had to submit questions via emails that were routed through agency spokespeople. It's unclear if the spokespeople passed our questions along to the agency’s experts. We received answers to most of our emails, often in some detail. But some of our questions were ignored or answered with talking points on general topics. The TCEQ employees who dealt with our public records requests were helpful and responsive, however. They discussed the filing process over the phone and answered questions about our requests.
*When a reporter called TCEQ field inspectors at their homes—a commonly used reporting technique—TCEQ spokeswoman Andrea Morrow left the reporter a message saying, “Under no circumstances are you to call our people and harass them at home.” Morrow also blocked the reporter from approaching the agency’s chairman, Bryan Shaw, at a public meeting in Austin.
The next DFW anti-smog plan "technical meeting" is 10 am on Thursday April 17th at the North Central Texas Council of Government's headquarters at 616 Six Flags Road in Arlington. One of the biggest controversies with the state's approach is determining the amount of gas and oil industry air pollution that's actually out there affecting DFW. The Eagle Ford story shines a bright spotlight on why the TCEQ really doesn't have a clue about the true amount of gas pollution, so why is it so confident about its numbers in the Barnett Shale, or the shale plays to the south and east of us that are upwind during "ozone season?" Good question. Come ask it on the 17th.
Eagle Ford Expose Reveals Weakness in Gas Air Pollution Inventories and That’s Bad News For DFW
By now, many of you have seen the massive eight-month act of journalism that the Center for Public Integrity committed in describing the situation in the Eagle Ford shale play in South Texas. It's probably the most comprehensive look at what it's like to live in Texas fracking hell that's been published, and it rightly got distributed far and wide.
Along with the now-familiar litany of acute human health effects from gas mining – nosebleeds, headaches, skin rashes, respiratory problems – the article also talked about the smog-forming pollution cause by the thousands of small, medium-sized and large gas facilities that invade a shale play. Together they represent a formidable air quality challenge.
Centering on the Buehring family of Karnes City, the piece lists the inventory of gas mining infrastructure surrounding their home. Besides the 50 wells within two and a half miles, they also host,
"….at least nine oil and gas production facilities. Little is known about six of the facilities, because they don't have to file their emissions data with the state. Air permits or the remaining three sites show they house 25 compressor engines, 10 heater treaters, 6 flares, 4 glycol dehydrators and 65 storage tanks for oil, wastewater and condensate. Combined, those sites have the state's permission to release 189 tons of volatile organic compounds, a class of toxic chemicals that includes benzene and formaldehyde, into the air each year. That's about 12 percent more than Valero's Houston Oil Refinery disgorged in 2012.
Those three facilities also are allowed to release 142 tons of nitrogen oxides, 95 tons of carbon monoxide, 19 tons of sulfur dioxide, 8 tons of particulate matter and 0.31 tons of hydrogen sulfide per year. Sometimes the emissions soar high into the sky and are carried by the wind until they drop to the ground miles away. Sometimes they blow straight toward the Buehrings' or their neighbors' homes.
That's 331 tons a year of smog-forming Nitrogen Oxides and Volatile Organic Compounds released from just a small number of square miles in the Eagle Ford. Just two more collections of facilities like that would equal all the smog pollution coming from the TXI cement plan tin Midlothian – North Texas' single largest smog polluter. It's no wonder then that a San Antonio Council of Governments air pollution model found that Eagle Ford smog pollution would make it impossible for the Alamo City to comply with the new 75 parts per million federal ozone standard.
Moreover, that 331 tons a year figure is just what can be discerned by reading Texas' archaic permitting records. The Center's reporters do a real public service in identifying the loopholes and gaps the system encourages that hide the true air pollution numbers,
Texas' regulatory efforts are also hamstrung by a law that allows thousands of oil and gas facilities—including wells, storage tanks and compressor stations—to operate on an honor system, without reporting their emissions to the state.
Operators can take advantage of this privilege—called a permit by rule, or PBR—if their facilities emit no more than 25 tons of VOCs per year and handle natural gas that is low in hydrogen sulfide. Two employees in the TCEQ's air permits office—Anne Inman and John Gott—estimate these PBRs could account for at least half of the hundreds of thousands of air permits the agency has issued for new or modified oil and gas facilities since the 1970s.
Operators with this type of permit aren't required to file paperwork backing up their self-determined status, so the TCEQ has no record of most of the facilities' locations or emissions. A chart generated in 2011 by the office of then-TCEQ executive director Zak Covar says the permits "Cannot be proven to be protective. Unclear requirements for records to demonstrate compliance with rules."
Big operators sometimes get a PBR for each component of a facility. Each might be under the 25-ton-per-year threshold that would require a more rigorous permit, but the facility as a whole could emit more than that.
The TCEQ refers to the practice as the "stacking of multiple authorizations," and the memo from Covar's office said its use "means that protectiveness and compliance with the rules cannot be demonstrated."
But of course that doesn't keep Rick Perry's TCEQ from saying everything is all right. As per usual, officials want to the results of stationary monitors in the region to assure residents that nothing unhealthy is being breathed-in.
"[M]onitoring data provides evidence that overall, shale-play activity does not significantly impact air quality or pose a threat to human health," agency spokeswoman Andrea Morrow wrote in an email."
But in this case, the region, covering a huge area from East Texas to the Rio Grande, has only five such monitors, "all positioned far from the most heavily drilled areas."
Moreover, that's just the holes in the permitting process itself. What about when a facility is a bad actor and has an "emission event' or "upset" where more than the permitted amount of pollution is released for hours or even days at a time?
"The number of emission events associated with oil and gas development doubled between fiscal years 2009 and 2013, from 1,012 to 2,023. The amount of air pollutants released into the Texas air during these events increased 39 percent."
A gas processing plant in McMullen County, in the southwestern portion of the Eagle Ford, reported 166 emission events last year, almost one every other day. From 2007 through 2011, the Tilden plant, owned by Regency Energy Partners of Dallas, discharged 1,348 tons of sulfur dioxide during such episodes. That's more than 30 times the amount it was legally allowed to release during "normal" operations.
Marathon waited three months to report a 2012 incident at its Sugarhorn plant near the Cernys and Buehrings. It released 26,000 pounds of VOCs in 12 hours, 1,000 times more than allowed under its air permit.
But what has this got to do with DFW smog? Everything. Besides the Barnett Shale play entering and enveloping the Metromess from the West, we also have the Eagle Ford and Haynesville shale plays to our South and East – upwind of DFW during our eight-month "ozone season." There are now as many wells in close proximity to DFW up wind as downwind.
Right now, as part of the new anti-smog plan for DFW being drafted by the TCEQ, the state is "re-calculating" oil and gas air pollution emissions and you'll never guess how that's working out – TCEQ is using industry advice to lower their estimates from last time around. At a January 31st meeting of what's left of the local air planning process, the state presented its new study that it's using to revise the considerable amount of air pollution coming from leaks and releases from condensate storage tanks in the Barnett and elsewhere. As of 2012, these releases are estimated by TCEQ to be only 25% of what they were in 2006. See how well that works out? And this number will be plugged into the computer model that then estimates how much of that air pollution turns into smog.
Instead of getting real world numbers for compressor stations, the TCEQ is now using a fomula based on local production and horsepower to estimate emissions, and guess which way this new technique is sending the numbers?
TCEQ is doing everything it can to make sure that the oil and gas air pollution numbers are as low for this new anti-smog plan as they can make them without breaking out laughing. Why? To prevent the call for new controls on these sources, even though everyone knows they're adding to the problem. Oil and gas emissions are the one air pollution category in DFW that's grown in volume since 2006, while others, like the Midlothian cement plants and East Texas coal plants, and even cars, have all gone down. Meanwhile, DFW ozone averages are higher then they were in 2009. Many of us don't think that's a coincidence. But the ideologically-driven TCEQ can't afford to admit the obvious – not while Rick Perry is running for President.
Compare the TCEQ strategy in DFW with the reality described in the Center for Public Integrity's reports from the Eagle Ford Shale and you have two completely different pictures of the amount of air pollution coming from the oil and gas industry. Which do your trust more – the official calculations coming out of Austin, or the secret memos and field reports uncovered by the reporters?
If what's happening in South Texas is also what's happening in the shale plays in and around DFW – and there's no reason to think it isn't – then the volumes the TCEQ is plugging into its anti-smog plan for the Metromess are off by large factors. That in turn could spell doom for the plan, due to be submitted to the EPA by July of 2015 – a little over a year from now.
This is why it's important for citizens to have their own computing power with their own modeling capabilities. It's the only way to call TCEQ's bluff that it's using all the right information to draft its new clean air plan to EPA. Without the technical know how to be able to look over TCEQ's shoulders and reveal its "GIGO"strategy, our lungs are hostages of Rick Perry's political ambitions.
The next North Texas appearance by TCEQ staff to explain how its estimating – or not – the air pollution from oil and gas industry sources as well as every other source – is scheduled for 10 am on Thursday, April 17th at the HQ of the North Central Texas Council of Governments located at 616 Six Flags Drive – right across the street from the Amusement Park. We need citizens to come out and ask pointed questions about the TCEQ effort to keep us from being taken on another ride to nowhere. Anyone can come and ask questions of the presenters – it's an open forum – and indeed it's the ONLY opportunity citizens have to actually quiz the TCEQ about the process. Please mark the date and try to be there. Meetings usually last until 12 noon or so. They think you're not paying attention. These numbers and quotes from the Public Integrity Center piece gives you lots of ammunition to prove otherwise.
Between Now and Friday: Tell Them What They Can Do With Their Smog
Frustrated that Rick Perry's Texas Commission on Environmental Quality isn't doing enough to end DFW's chronic smog problem, the local "Council Of Governments" has issued a "Request for Information" asking for the public's help in suggesting ways to reduce ozone pollution in North Texas.
Please use our Click N' Send E-mail form to make sure they get the message that the public wants:
1) State-of-the-Art pollution controls on huge "point sources" of pollution like the Midlothian cement kilns and East Texas power plants.
2) New pollution control equipment and strategies to reduce the air pollution from the thousands of natural gas facilities mining the Barnett Shale.
3) Inclusion of all trucks and off-road vehicles in the state's vehicle maintenance and inspection program.
You can also add strategies or ideas of your own as well. Just click here, fill out the e-mail and send it in to be counted.
It takes as little as 30 seconds.
BUT YOU ONLY HAVE UNTIL 5 pm FRIDAY, VALENTINE'S DAY.
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Rick Perry's TCEQ is so discredited on the matter of DFW smog, local officials usually working in concert with the state agency are now looking elsewhere for help.
Ever since DFW was required to write and submit new clean air plans, The North Central Texas Council of Governments has been the local vehicle used by the state to funnel information, concern, and ideas back and forth.
It was never easy to get Austin's attention or convince the Powers That Be of the need to take bigger clean air measures. It took a decade for Downwinders to get the State to admit that the Midlothian cement plants had a huge impact on local air quality before they were the targets of new controls.
But ever since Rick Perry began running for President in 2010, it's been impossible for Austin toget serious about any DFW clean air plan. For the past four years, TCEQ has claimed that it can reduce air pollution enough by doing nothing.
That strategy has been a dismal failure. New car buying in the middle of the worst economic downturn since the 1930's was the TCEQ clean air plan in 2011. Austin promised that if we just sat back, we'd have the lowest smog levels ever recorded. Instead we had worse air pollution levels than we did five years ago.
This time round, TCEQ is saying a new EPA-mandated low-sulfur gasoline mix in 2017 will be the region's savior for the new clean air plan that's supposed to be successful in reaching the new federal ozone standard of 75 parts per billion in 2018. We're at 87 ppm now – still in violation of the old 1997 standard.
Just watch this new fuel being added to cars and see the ozone numbers drop, TCEQ is saying. No need to put controls on gas facilities, or cement kilns, or power plants. Nothing that would give Rick Perry's opponents on the Right any opportunity to claim he was "anti-bidness."
Even the Council of Governments isn't buying it.
That's why, in their own bureaucratic fashion, this Request for Information that the COG has issued is it's own middle-of-the-road middle finger to TCEQ.
Usually, it would be the state facilitating a discussion of new air pollution control strategies, but since it's obviously not interested, the COG has decided to go its own way. That's how bad things have gotten in Austin – even their most reliable allies in DFW can no longer take them seriously.
It's not clear what will happen to the list of control measures that the Council of Governments is assembling. Some might receive some more official attention, but locals have no authority to write or override Austin's decisions. TCEQ is the only entity that's authorized to submit a new clean air plan to EPA by the June 2015 deadline.
But there are ways to use the useless clean air plans that Austin is submitting. Downwinders' own green cement campaign is a great example.
In 2007, we successfully inserted a voluntary air pollution control strategy into the TCEQ plan revolving around the purchasing of cement from newer cleaner "dry" kilns by local North Texas governments. We then took that "green cement" procurement option and went to Dallas to pass the nation's first green cement ordinance. Then Fort Worth passed it. Then Plano. Then Arlington. Then Denton. Then Dallas County. Then Tarrant County.
Within two years, we had established a de facto moratorium on dirtier "wet kiln" cement within at least a dozen municipal and counties. Combined with federal rule changes, we were able to get all Midlothian wet kilns closed. The last one is being be converted to a dry kiln this year. All while Rick Perry was governor.
The same thing could happen with a good "off-sets" policy for gas facilities if a local city of county could pass a template ordinance showing the way. Currently, most of the gas industry is exempt from being required to "off-set" their air pollution in smoggy "non-attainment" areas like other large industries in DFW. Take away this exemption and you'll see a swift decrease in gas industry air pollution.
It's these kinds of strategies that don't depend on action from Austin that offer the greatest potential for progress this time around.
TCEQ has never written a successful clean air plan for North Texas, and it's not going to start now. But citizens themselves can take their lungs' fate into their own hands and begin to build a system of local measures that can make breathing easier.
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CALENDAR AND STATUS REPORT OF DFW'S NEWEST CLEAN AIR PLAN
Reach a 3-year rolling average of no more than 75 ppm of ozone at all 18 DFW area air monitors.
End of an Era: TXI Cement Sold To Martin-Marietta
In a $2 billion deal, Raleigh, North Carolina-based aggregate and crushed stone manufacturer Martin Marietta Materials (a separate spin-off on the more well-know aerospace conglomerate) bought Dallas' own TXI Cement, which opened its first cement kiln in Midlothian in 1960.
This year, that kiln, along with the three other obsolete wet kilns at TXI's Midltohian plant that burned hazardous waste for two decades, is due to be demolished, following the company's corporate demise at the hands of the grandson of its founder. And then, the last remnants of the old TXI will be gone for good.
What does the change in ownership mean for breathers in North Texas?
Martin Marietta has owned and operated cement plants around the US in the past, but they'd divested themselves of these prior to 2014. As of now, the TXI cement plants in Texas and California are apparently the only ones the company owns. There's some speculation that Martin-Marietta bought TXI for its aggregate, stone, and concrete facilities in Texas and California, and will soon seek a buyer for the cement plants it inherited, but doesn't really want.
If that's true, the new owners will act as placeholders of the status quo, not investing in big new capital projects, but also trying not to lose any of the value of the assets they now have by running them into the ground. Martin probably won't look favorably upon attempts to bring smog-reducing modern Selective Catalytic Reduction (SCR) technology to TXI via the next clean air plant for DFW, now due in June of 2015. Not only would the plant be among the first to adopt the technology in the US, (even though SCR has been successfully used in European cement kilns for over a decade now), but it would mean new capital investment and a new learning curve.
Swiss-based Holcim Cement, with a huge plant already in Midlothian and a large manufacturing footprint in the US, was rumored to be one of TXI's suitors before the sale was announced. It could be that Holcim, or another well-established player in the cement industry winds up with the actual kilns in the next year. That could complicate the plant's participation in the new clean air in other ways even if new owners are not as intimidated by the demand for new technology
Politically, it'll be interesting to see which Austin lawyers and lobbyists get the business of the new company. Martin-Marietta owns over 40 facilities in Texas already and is represented by it's own crew. Will TXI's law firm and lobbyists survive the buy-out? There are industry lobbyists that will keep the ball rolling no matter what – the Chemical Council, the Aggregate Association, etc. But in Austin, it's all about relationships, and it's hard to say yet how this Martin's buying of TXI changes any of them.
Maybe the place TXI's absence will be felt the most in in the corridors of power in DFW. TXI was proudly headquartered in Dallas. Ralph Rogers, TXI's founder and patriarch was a driving force in local philanthropy, giving millions to public broadcasting (KERA is housed is housed in the "Ralph Rogers Communications Center") and other non-profits. Besides feeing like he was entitled to use PBS's iconic Big Bird to sell the benefits of burning hazardous waste in 50-year-old cement kilns, the non-profit giving Rogers was responsible for made him a known figure on the Dallas Charitable circuit. In turn, this made it hard for the Powers That Be to criticize Roger's company when it became a waste incinerator.
Locally, the establishment played golf with the Rogers' or attended black tie dinners with them, or helped them lift the oversized scissors at ribbon-cutting ceremonies. But that was old Dallas. Hardly of those relationships survived past Ralph Rogers' death in 1997. His son, Robert, failed to maintain that same high-profile locally, and his grandson Jamie seems totally disinterested in the family business or its legacy of charitable giving.
Now, the move of company headquarters from Dallas to Raleigh will complete the disappearance of the once-mighty TXI on the local scene. They'll still be company representatives at functions, but it won't be the guy who can write the big checks, or who the Mayor had a splendid time with last Saturday at the Club.
The company's local political influence has forever been diminished, and that's a good thing for citizens who are fighting the company to get modern controls like SCR. Now, it's just one more corporate entity with a presence in North Texas. A presence that makes it the single largest air polluter in the region. That's the way Dallas and other downwind cities should have viewed the company all along.
The New Gas Pollution Problem for DFW in Two Pictures
So far the debate over how much impact the gas industry has had on DFW air quality has centered on the Barnett Shale. That's logical because that's the gas play right in front of us, in the middle of the North Texas "non-attainment area" for smog. One of the main arguments Rick Perry's Texas Commission on Environmental Quality has made against any significant impact is that most of the drilling is happening west of the DFW urban centers.
Ignoring how geographically-incorrect this argument is – there's drilling and compressors in Dallas County right now, much less Ellis, Johnson. Denton and Tarrant – let's just cede the argument to the state that it would take gas fields to the Southeast of us, that is, upwind of us during ozone season, to really impact our air quality.
Guess what? There's gas fields Southeast of DFW that are producing lots of air pollution.
In previous posts over at least the last two years, we've shown that if you add up the standard permits of all the gas compressors in Freestone County alone, they represent more smog pollution than the Big Brown Coal Plant doing business down the road. Now there's new evidence of the size of these gas fields and their relationship to the DFW airshed, thanks to Google.
Here's a picture of the area we're talking about – just about an hour and a half drive southeast of DFW, east of Waco. That makes it directly upwind during ozone seasons.
When you zoom into where the green arrow is, you see the familiar sight of hundreds of square drilling pads laid out over the landscape – just like the Barnett Shale – only DFW is directly downwind of it during the summer.
Pollution from these sources has most likely been grossly underestimated by the state. Moreover, when gas field pollution comes into an urban area with dirty air, it increases the likelihood of that pollution turning into smog. Rick Perry's employees are loath to admit the gas industry plays any part in the stagnation of DFW air quality progress since 2007, but as these images make clear, facts on the ground trump their ideology.
State Predicts DFW Will Fail New Smog Standard, But Air Quality Is Getting Better!
By 2018 the Texas Commission on Environmental Quality predicts DFW will finally be in compliance with the federal ozone standard. The 1987 federal ozone standard. The 2012 ozone standard? Not so much.
That was the bottom line of last Tuesday's very defensive TCEQ staff presentation on the new effort to rein-in North Texas smog at the Council of Government's headquarters in Arlington, in what could be considered the kick-off meeting of yet another "State Implementation Plan," or SIP, for DFW. A plan drawn up by the state has to be submitted in place by June of 2015, with a goal of meeting the new 75 parts per billion ozone standard by the summer of 2018.
But even giving generous credit for the effect of new, lower sulfur gasoline standards, the TCEQ's computer model predicts the area will fall short of the 75 ppb goal at four very familiar monitor sites, with final estimates just a fraction above 75 ppb at Keller, readings of 76 ppb at Grapevine and Eagle Mountain Lake and as high as 77 ppb in Denton. To understand how optimistic even this result is however, you have to know that the Denton monitor is sitting at an average of 87 ppb as of this last summer. It took 10 years for that monitor to come down from an average of 97 ppb of ozone in 2003 to 87 ppb in 2013. With its new model, TCEQ is asking everyone to believe that ozone levels will come down another 10 ppb in less than five years.
As this excellent Denton Record Chronicle piece about the TCEQ effort points out, there's plenty of reasons to be skeptical. The agency has been wildly inaccurate in its past predictions. According to the last computer model the TCEQ ran, DFW was supposed to be enjoying record low ozone levels by now. It never happened, and in fact we're still in violation of the old 1987 standard of 85 ppb.
It's this lack of progress, particularly in the last thee years, that Downwinders and others cite when we're making the argument that more aggressive control measures are needed. In countering us, the state keeps insisting that – compared to 2003 – we're doing much better. And that's true -if you stretch things out over a decade we have gotten better. But compared to 2009 and 2010, we're doing the same or even worse. Look at the last three years of results and there's no way to conclude that DFW air quality is "getting better." It's just not true.
And all of this is really just a proxy for the fight over how much natural gas pollution is to blame for that stagnation. If there's no stagnation, there can be no cause of that stagnation. If there's a rollback in air quality, there must be a cause for the rollback. And many of us think that it just might be the pervasiveness of gas productions facilities within and surrounding DFW that are contributing factors.
Chris Kite, the TCEQ computer modeler that produced the new plan, used his presentation to mostly try to rebut specific quotes and arguments cited by Downwinders Director Jim Schermbeck about the lack of local air quality progress. It was a rare and raw indication of just how much TCEQ's Austin Headquarters considers Downwinders a threat. Too bad that even his own charts betrayed Mr. Kite's counter-thesis.
For instance, look at the numbers from 2008 to 2012 for average smog levels in DFW and see if you can cite the progress in this slide from the TCEQ PowerPoint:
For the past two years, our average has been higher than the two years before that. That ain't progress. Especially if you look at the previous four years, 2006 to 2009:
We're trying to think of what might have happened since 2008 to make it more difficult for the DFW region to attain a 1987 ozone standard at a time when emissions from just about every traditional source of smog pollution have been going down. Oh yeah, there was a huge natural gas field that opened up in the heart of the western part of the Metromess. But don't try telling the TCEQ that. They're convinced, absolutely convinced, that gas industry pollution couldn't possibly be responsible for any lack of progress in DFW air quality. Because hey, there hasn't been any lack of progress, and even if there wasn't, it wouldn't be due to the thousands of new gas sources. They're as sure of this as they are about their new computer model. Which is why the rest of us should keep an open mind.
TCEQ is hoping that coming close is good enough for EPA, that they can take advantage of something called "weight of evidence" that says that a clean air plan's parts are larger than its actual numerical sum and EPA reasonably expects the thing to succeed despite not all monitors hitting 74 ppb or below by 2018. In this way, Austin once again hopes to avoid any discussion about new control measures. But that's hanging your hat on a very precarious hook, given the agency's poor prognostication, and the EPA may demand a larger margin of safety.
In fact, an honest review of TCEQ's track record for past DFW clean air plans would necessarily place the "weight of evidence" in this new one on the agency itself to show that they'll get at least 10 ppb or more below the 75 standard just to make sure they come close to achieving compliance.
Something Wicked This Way Blows…..
Events like the gas pipeline explosion in Milford are graphic reminders of just how vulnerable our North Texas air shed is to pollution sources from Ellis County. Proximity, predominant wind patterns, and potential for disaster combine to make our Southern neighbor a constant threat.
On Thursday, one could see the plume of smoke stretch out south to north across the entire Metromess. It's a safe bet that not too many of the 6 million plus residents of greater DFW knew there was a town called Milford near them at the beginning of the day, but a lot of them had inhaled Milford soot by evening.
That would be the same soot that reporters keep reminding us "the EPA" says is "non-toxic," based on measurements. Except there is no such thing as non-toxic smoke from a combustion source, which the Milford explosion and fire most certainly was. All combustion produces soot, or Particulate Matter. According to the latest evidence from research scientists, there is no safe level of exposure to PM Pollution. That is, any amount of PM pollution can do human health damage. Even short-term exposure can lead to asthma attacks, heart attacks and strokes. How do we know this – the EPA tell us so on their own website.
Only a couple of years ago, the Magnablend fire in Waxahachie poured its own plume of "non-toxic" smoke into DFW skies, despite the incineration of a large variety of chemicals used in the oil and gas industry. You might remember the water run-off from fighting that fire went into a creek and killed a lot of fish. But don't worry, that same stuff in your lungs is nothing to worry about. Perfectly natural to be able to see what your breathing.
Perhaps the most spectacular modern reminder of how close Ellis County is to us in air miles came back in 1995 when a Midlothian-based tire dump, called…wait for it…."Safe Tire Disposal Company" that was actually a collection site for the nearby cement plant tire-burning operation caught fire its own self.
There are fires, and then there are tire fires. They burn extremely hot, produce a lot of that "non-toxic" smoke, and can keep going for days. And that's exactly what happened in Midlothian. The predominant southerly winds carried all that dark dense smoke right into Downtown Dallas, where it surrounded and engulfed whole office buildings.
Timing is everything and so it was with the Safe Tire Fire. It happened at the exact moment when local citizens were engaged in very public debate with state and local officials over whether air pollution from the three large cement plants in Midlothian (two of which were burning tires) could impact air quality in DFW. You read that correctly. In 1995, citizens were still trying to make the case that millions of pounds of air pollution released just across the Dallas and Tarrant County lines could possibly have a negative impact on metropolitan smog levels. And it was an uphill fight. Officially, there was no confirmation of the impact of these facilities. The DFW air plan stopped at the County Line. Unofficially, you could see the cement plant smokestacks as you drove I-20 across Grand Prairie and Arlington.
When those tires went up in smoke, so did the arguments being used to downplay the impact of Ellis County pollution. It was like adding a dark black dye to the North Texas air flow, beginning in Midlothian, and watching it be carried downstream/downwind right into the heart of downtown Dallas. It was the most defiant demonstration of the citizen's arguments one could imagine. After that, it was a lot easier for everyone to understand Midlothian was only a breeze away from their lungs.
With yet another fire in Ellis County setting off yet another dark, thick plume of smoke that wafts into DFW, we get a reminder of how much closer together the air brings us. Only about half an hour or so away from Milford, a little bit further south, is a new belt of natural gas compressors churning out voluminous amounts of air pollution that's being blown in the same direction as the smoke from that gas pipeline explosion. Unlike that smoke, pollution from these facilities will keep being released 24/7 for the foreseeable future. Add up all this new compressor pollution and it could rival the impact of a new coal plant – just upwind of us. Just because you can't see it doesn't mean it's not having an impact.
Once again, the state's position is that this pollution is no big deal. Once again, citizens are disagreeing. Who would you put your money on?
Can You Hear Me Now? EPA’s National “Listening Session” on New Coal Carbon Pollution Rules This Thursday
Many of you have already seen the increasingly urgent pleas from the usual suspects for people to show up at this Thursday's national EPA "Listening Session" on new emission standards for Greenhouse Gas pollution. Try to ignore the New Age-by-way-of-George-Orwell alternative name for a public hearing, and the industry-friendly "listening" schedule of 10 am to 3 pm, and concentrate on the fact this is one of only a handful of such sessions taking place nationwide, and it's in Texas, our Texas.
Like it or not, public health-minded residents of DFW have the burden of showing up to national hearings like this just to prove we exist. Nobody expects there to be an viable environmental movement in the Belly of the Beast, especially outside Austin. However hard we work to change that image, it's still a popular one and in this case, it hits entirely too close to home. Because Texas is the world capitol for carbon pollution. We're Numero Uno, A Number 1. We're living in the barrel of the gun that's pointed right at the planet's head.
EPA recently reported that Texas released more GHG pollution in 2012 than the next two states – Indiana and Pennsylvania – combined. We're responsible for a full 12.5 % of the entire US annual total, almost 400 million metric tons of the stuff, ever year. Just take a look at the difference between us and the other 49.
Then use this handy-dandy EPA map of incredibly large sources of GHG pollution in the US. It allows you to zoom down to what's in each county of each state. Look at all the sources around DFW. Most are also large sources of other kinds of pollution. We're living in a sea of pollution created by these facilities.
So when EPA decides to schedule its one and only listening session in Texas on new rules to reduce this kind of pollution from some of the biggest sources in our own backyard, we need to show up because we're a disproportionate part of the problem.
We also need to be there because industry will be there, in force. The old TXU really wants to keep its obsolete, lignite-burning East and Central Texas coal plants running without any of these modern pollution control contraptions. Doesn't matter if they're aimed at Particulate Matter, or smog-forming pollution or GHGs, they just don't want them. You can bet they'll be bringing in folks from those coal plants to say what a terrible economic cost it would impose on the host communities and the company, and how it'll put the entire statewide grid in peril.
Someone has to be there to balance that testimony by pointing out that the economic, public health, and environmental impacts of this pollution reach far beyond Limestone County, Texas or even the US, and need to be considered on the agency's balance sheet as well.
Every yahoo with Americans for Prosperity, or other industry astroturf groups will be there because these kinds of national forums to bash Obama's energy policies are what they live for – and it's the only thin they do halfway competently. Likewise for the industry-aligned Freedom Works branch of the Tea Party.
And does someone want to start an office pool on how many Republican primary candidates will be appearing, trying to outflank each other on their Right? Expect to see and hear a lot about "Obama's War Against Coal" on Thursday. It's Texas.
Which is why even if you're not a fan of this Administration, you have to recognize that the first attempt to regulate greenhouse gases from coal plants should be encouraged, in Texas. It's a foot in the door to do more effective things, to start talking about GHG regulations in a serious way. It establishes a precedent. And that is what industry fears the most. You don't have to like the EPA to understand that the enemy of your enemy is your friend in this fight. And did we mention it's in Texas?
Finally, we just emerged from an ozone season that was mild by recent standards – but still harsh enough to keep us in violation of the old 1997 smog standard. We know the East and Central Texas power plants contribute to DFW's air quality problems. These new carbon regulations EPA is considering for existing power plants have the potential to reduce a variety of air pollution, not just GHGs. We know Austin and TCEQ are going to be of no help in addressing these sources in the next DFW clean air plan. If reductions are going to happen, they're going to have to be driven by the EPA, local governments, or the marketplace. We can't let this opportunity for meaningful reductions and better air pass us by. If for no other reason, you need to show up on Thursday and say you support the EPA's regulation of these facilities because you've given up on Texas doing so.
For lots of reason, it's in your own self interest to attend this thing, even if you real passion is gas field pollution, or smog, or cement plants or whatever. A victory in this category of regulation is a victory for all of us involved in clean air issues. And it's Texas.
National EPA "listening session" on carbon limits for existing coal plants
THIS Thursday, November 7, 10:00 a.m. to 3:00 p.m.
1st Floor Auditorium, J. Erik Jonsson Dallas Central Library, 1515 Young Street, Dallas, TX (map)