Midlothian
TXI Stock Takes a Dive, New North Texas Cement Plant on Way?
Last Wednesday TXI stock didn't do as well as Wall Street thought it should for the quarter and the result was about a 10% drop in value over one day's trading. On a Thursday conference call, CEO Mel Brekhus defended the company's prospects, including the opening of its new Central Texas plant, saying it "was the most successful of any he had been involved with in his career." We imagine that's right since the only other plant the company has built recently was Kiln #5 in Midlothian which faced opposition from Downwinders and others in the early part of the last decade.
But most intriguing from DFW residents' point of view was the hint that Brekhus casually dropped toward the end of the call that the company was thinking about "increasing capacity" in North Texas. You know what that's code for – a new cement kiln.
Midlothian has been home to the nation's largest concentration of cement manufacturing for a long time, but such an addition would solidify its position for decades to come. That's because these days kilns come in one size – very, very large. A new TXI kiln would be massive in all respects. Air pollution would go up considerably, possibly canceling out some gains that have been made by the shutting down of the seven older wet Midlothian kilns that were ground zero for waste-burning from 1986 to 2008. Particulate Matter, smog-forming pollution and more exotic poisons like Dioxins would increase substantially.
Moreover, TXI might be looking for new ways to make money besides making cement – just like they did when they turned their kilns into hazardous waste incinerators for profit. Around the world the cement industry is focusing a lot of effort into becoming waste incinerators for municipal solid wastes, medical wastes and "unrecyclable plastics." Just like they did when they were burning hazardous waste, they charge customers for the right to burn their garbage. TXI recently expanded their list of fuels to include car parts and plastics. Might a new kiln increase the need to develop even larger markets for waste to burn?
It could be PR talk for the investors or reflect real corporate thinking at TXI headquarters. As part of their planning, executives would be advised to also think about the opposition to such a plant now. Midlothian is a different place than it was even 13 years ago, much less 25. People who've moved there recently might not want to see a new source of air pollution, especially one devoted to being a garbage burner. It's not quite the company town it was. And instead of facing a fledgling group, they'd be up against an organization that knows how to win the war. Stay tuned.
“March of the Incinerators” is Killing Recycling in Britain
For 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.
State Ignores Latest Failure and Local Air Committee, Will Host “Public Information Meeting” on DFW Smog
This curt announcement went out last Friday courtesy of the Texas Commission on Environmental Quality:
The Texas Commission on Environmental Quality (TCEQ) will host a public information meeting to provide information on the development of revisions to the SIP for the 2008 ozone National Ambient Air Quality Standard (NAAQS) in the 10-county Dallas-Fort Worth (DFW) nonattainment area. The meeting will take place on Thursday, September 5, 2013 at 10:00 a.m. at the North Central Texas Council of Governments (NCTCOG), Transportation Council Room, 616 Six Flags Drive, Arlington, Texas 76005. NCTCOG and United States Environmental Protection Agency (EPA) representatives will also provide updates on local and federal initiatives.
What this doesn't say is that the last local clean air plan drafted by Rick Perry's TCEQ failed miserably last summer when DFW actually ended up with worse air than when it had begun in 2010. The state can't even bring itself to admit that. It's never had a successful smog plan in DFW, but only Rick Perry's TCEQ plan actually made the air worse. Maybe that's why they're holding this "public information meeting" at a mid-morning time guaranteed to result in a low rate of participation by actual DFW citizens.
You'd also never guess from this release that DFW has a local advisory board for drafting its own clean air plans. The North Texas Clean Air Steering Committee was constituted specifically for the purposes of working with the state on such plans. It hasn't met in two years. Nor is it likely to meet anytime soon if Rick Perry's TCEQ has its way – the state considers it a nuisance to have to come up here and explain itself to local elected officials and environmentalists.
Did we say environmentalists? Since the 2006-2007 smog plan, citizen groups have held three seats on the Committee to balance out the three seats given the local Chambers of Commerce. Right now those seats are held by Downwiders at Risk, the Sierra Club/Public Citizen and the Environmental Defense Fund. The rest of the slots are filled by local city council members, Mayors, County Commissioners and County Judges.
Downwinder's own Jim Schermbeck is a member and has used the meetings of the Committee to cross-examine Rick Perry's TCEQ officials who otherwise receive a mostly unquestioning welcome everywhere else they go. Committee meetings are the one place that representatives fo citizens groups can ask questions like a legislator in an Austin hearing. And the TCEQ reallly doesn't like that. Especially when we've been right about so many things and the TCEQ so wrong.
It's also true that Rick Perry's TCEQ really doesn't even bother to start any kind of consultation or planning process in DFW until a year before the plan is due. Since a new plan to achieve the new ozons/smog standard of 75 parts per billion doesn't kick in until 2015, it's doubtful the Committee will be called to order before next Spring. That way the pollution control measures needed by any plan have no chance of passing a state legislature at the last moment in 2015, ensuing that no real changes take place and DFW remains smoggy.
Perhaps you think that's way too cynical a perspective. But that's exactly what happened this last cycle in 2010-2011. And it was actually worse, because the biggest part of that last plan was to sit back and watch as DFW residents bought new cars. No moving parts.
Meanwhile, can anyone name a current local elected official who's known for their advocacy of clean air? Dallas Mayor Laura Miller fought Perry's coal plants in 2006. in 2013, her successor, Dallas Mayor Mike Rawlings protects secret deals with gas drillers. Dr./Mayor Cluck in Arlington has voted in favor for dozens, if not hundreds, of gas wells near homes, parks, and day care centers even as he recites his familiar litany about running into childhood asthma victims in the hospital emergency room. Fort Worth? Bought and sold to Chesapeake. Dallas County? They're too busy indiscriminately dropping pesticides on us. Mayor Evans of Plano used to be a voice of reason in Collin County. Now you've got Judge Keith Self who never met an air polluter he didn't liked.
Some stalwarts like Parker County Judge Mark Riley and Tarrant County Judge Glenn Whitley still represent moderate Republican views, but many of their peers have been replaced by Tea Party members who think smog is as imaginary a problem as climate change. We're actually going backwards in our local political engagement of the issue.
If TCEQ is emasculating the local advisory group on clean air, it's certainly getting a valuable assist from a feckless DFW indigenous officialdom, who seemed to have all walked away as a group from clean air as a goal they were willing to strive to achieve.
So mark your calendars for another citizen-friendly TCEQ "public information meeting"….at 10 am on a Thursday morning, September 5th, in Arlginton at North Texas Council of Government headquarters, when most people will be working and unable to attend. For for the sensitive among you, we suggest also attending with some handy BS protectors for your ears so as not to irrevokably damage logic receptors in the brain.
Behind Last Week’s Ash Grove Headlines: “The Rest of the (20 year) Story”
There was a great deal of official news fluttering last Thursday when the EPA and Department of Justice announced a national settlement with Kansas-City based Ash Grove Cement that confirmed the company's Midlothian plant, site of The Last Wet Kilns in Texas™, would shut down and covert to one large dry process kiln by September of next year. Both dailies reported like it was 1999, with front page headlines and lots of column inches (ask your parents).
But the newsworthy part of last week's developments was not that Ash Grove was converting its wet kilns to a dry kiln. In February of last year, Downwinders at Risk reported that the company was seeking a permit from the Texas Commission on Environmental Quality to do just that. The Star-Telegram, bless their hearts, even wrote a story about it. Ash Grove's planned conversion was so widely-known that it was the subject of Midlothian Rotary Club meeting speeches this last Spring. So, you know, not news.
It wasn't news because those new national EPA air pollution rules for cement plants that we all drove out to DFW Airport in 2009 to testify in favor of and then to Arlington last year to defend, were expected to put the final nail in the coffin of Ash Grove's wet kilns by the time they took effect in September 2013. TCEQ granted the company a lame one-year extension to the 2013 deadline, but by September 2014, it was pretty clear that Ash Grove's Midlothian wet kilns would have to be converted or replaced to meet those new EPA standards coming down the pike. That's why last year's permit application for the conversion wasn't a surprise, but a confirmation.
And then the Obama Administration decided to stop the standards from coming down the pike. Just as those rules and that 2013 deadline was about to be signed into law, the President changed his mind and put them on hold. His EPA weakened the air pollution standards as proposed and delayed the deadline until 2015 or later – against overwhelming public opposition. All of a sudden, that 2014 deadline for an Ash Grove conversion looked to be in trouble. Would The Last Wet kilns in Texas™ just keep chugging along?
But what do you know? As part of that national settlement announced last Thursday, Ash Grove committed to the government to make the conversion and run the new dry kiln starting in….September 2014, or the original date of dry kiln conversion before the Obama u-turn on the new rules. What a coincidence!
So what was REALLY newsworthy about last week's announcement was that the national EPA managed not to screw-up a very good thing that its now-abandoned tougher rules were already putting in motion on the ground in Midlothian. Lucky us, huh?
The luck had some help from Downwinders. We knew the EPA was looking at Ash Grove for the kind of national enforcement settlement it had cut with LaFarge and other cement companies as part of its multi-year spotlight on the industry. We knew that the former Regional Counsel for the EPA office in Dallas, Larry Starfield, who spent decades dealing with all three Midlothian cement plants, was now in DC as EPA Deputy Enforcement Director, and probably in line to sign-off on any agreement. And we knew the original 2014 deadline for Ash Grove's conversion was in trouble with the Administration's reversal on the new air pollution standards.
We made inquiries, We made pitches. If Ash Grove were the subject of such a national enforcement effort, would it be possible for EPA to please consider requiring Ash Grove's Midlothian plant to firmly commit to its 2014 conversion deadline as part of any settlement? Turns out, it was possible.
How likely would it have been without our intervention? Best not to ask. But if you think, as we do, that our showing-up and making the case made a difference in securing progress that was in danger of being further delayed, here's the tip jar.
So yea for our side, although the victory seems a little less satisfying than what it should be when you know it's simply maintaining the status quo. Still, it's better than another couple of years of pollution from the area's dirtiest smokestacks.
$2.5 million in fines plays well in headlines until you realize how small it is compared to company's annual profits (almost $900 million n 2010). Beside the fines, nine Ash Grove plants will have to better control their smog-causing Nitrogen Oxide, Particulate Matter and Sulfur Dioxide pollution better, including the installation of Selective Non-Catalytic Reduction, or SNCR technology. The Midlothian plant was already scheduled to have this included in its conversion in order to meet those now-abandoned new air pollution standards. There's also a strong possibility that Ash Grove's other wet kilns will follow Midlothian's lead and also be converted to dry kiln technology.
Unfortunately, EPA didn't require any new testing of Selective Catalytic Reduction Technology, as it had in previously announced cement company settlements. SCR is twice as effective at cutting cement plant pollution as SNCR and has been used on kilns in Europe for over a decade. It's state of the art. But it's still not required in the US, although the results from two EPA-mandated pilot tests on kilns in the Midwest are due this year. One good thing about Ash Grove's conversion is that the plants can no longer use their continued operation of obsolete wet kilns as an excuse not to install modern equipment like SCR as it has in the past – although we know they'll find a new excuse now.
Here's the consent decree if you want to read all the details of the settlement. And here's the original complaint, which chronicles the alleged misdeeds of the company, plant by plant, including the sins of the Midlothian facility. A lot of the legal case depends on parts of the Clean Air Act that says any "major modification" to a plant must not increase pollution. Ash Grove ignored this law. Repeatedly. Over the last 20 years. According to the complaint, the violations in Midlothian originally occurred in 1995. That's right, it's taken almost 20 years for EPA to enforce a basic Clean Air Act violation.
"Kilns 1, 2, and 3 at Ash Grove's facility in Midlothian, Texas: 1) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 1 to the coal mill and performed a project to enable Kiln 1 to burn waste whole tires as a fuel source; 2) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 2 to the coal mill and performed a project to enable Kiln 2 to burn waste whole tires as a fuel source; and 3) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 3 to the coal mill and performed a project to enable Kiln 3 to burn waste whole tires as a fuel source."
Downwinders has always argued that tire-burning increases emissions, not decreases them as the industry maintains. We were saying this in 1995 as these illegal changes were taking place and Ash Grove officials were saying what a great air pollution control strategy it was to burn whole tires.
The implications of these kind of very common violations hang heavy over the current industry transition to new and more exotic industrial wastes being burned in kilns, some of which make tires look like Grade-A fuel oil. Plastics, shingles, car parts. All of the Midlothian cement plant are now burning things that they shouldn't be with no more assurance they aren't breaking the law than there was in 1995 when they were changing fuels then. But don't worry, EPA's on the case and you can expect any such violations to be prosecuted in….2033.
Notice Something Missing So Far This Summer? Smog Alerts.
Along with cooler weather in general and a little more rain this Spring has come some relief from really dirty air in DFW.
Last year at this time, we'd already had 6 "exceedences" of the old 1997 85 parts per billion ozone standard in May, and countless exceedences of the tougher new 75 ppb standard that is supposed to be attained by 2018. As of today, we haven't had one even one monitor reading above 85 ppb and only a handful in the 75 to 85 ppb range.
For the last two years in a row, DFW has seen a decrease in air quality, and an increase in smog. Could 2013 be the year that trend is halted?
Weather takes a lot, or even most of the credit. Cooler temperatures and more moisture are not conducive to ozone creation. But unlike during the recession, new car sales seem to be taking off the way the Rick Perry-approved engineers at the Texas Commission on Environmental Quality wanted them to two to three years ago. It's possible that the replacement of older dirtier vehicles with newer, cleaner ones by the thousands has finally made a difference you can't see. There's also the impact of cleaner operations at the Midlothian cement plants thanks to citizen victories over the last decade, (although the kilns are rapidly turning back into garbage burners), fewer coal burning plants downwind, and other improvements up and down the southeast to northwest axis that carries our predominant winds from Houston to here.
On the other hand, last June was pretty quiet until the 24th, and then all hell broke loose, with ozone levels into the triple digits. 2012 turned out to be a very bad year for safe and legal air.
And there's the unknowns that nobody's really examining closely – at least not in public. How much ozone pollution is being caused by the natural gas infrastructure in the Barnett Shale that's been built over the last decade and gets bigger every week? How much is the gas industry polluting upwind of us in places like Freestone County between here and Houston? Does the continuing boomtown growth in DFW population cancel out the improvement in individual vehicle emissions?
From a regulatory point of view, no matter how good or bad this summer is, we don't get credit for it either way. Another bad year wouldn't be held against us. Likewise, no violations this entire year wouldn't buy us any more goodwill from EPA. We're in a limbo period, where everyone is just waiting around for the average readings from 2015 -2018 to accumulate and tell us what category of compliance with the new 75 ppb standard we're in. While it would certainly help the cause if the region had some forward momentum in lowering the levels of smog going into 2015, officially, it makes no difference at all – unless you're breathing air. Then, according to EPA's own scientists, anything above 65-70 ppb is damaging to human health.
Theoretically, the TCEQ is supposed to be putting together yet another "DFW clean air plan" to reach that 75ppb standard, to be implemented sometime between now and 2015. The last time it tried to reach such a regulatory goal – the 85 ppb standard – it ended up with a plan that worsened air quality here by starting way too late and basically doing nothing but watching as new cars were going to clean up the air in the middle of a recession. (By the way, the "official" regulatory date of that failure is coming up next week even though the failure was certain last summer. Stay tuned to see if TCEQ acknowledges it in any way).
It's the summer of 2013. Any big changes that need to be in a summer of 2015 clean air plan should be being discussed and set in motion now, especially if they need 2015 state legislative approval, or lead times for industry to adapt. However, state or regional officials have yet to call a meeting of the local advisory group that's supposed to be monitoring the development of that plan. No date is set for such a meeting.
We can hope that a confluence of circumstances is making it possible to have cleaner air in DFW, but as long as Rick Perry is Governor, it's unlikely such an important public health goal will override political agendas.
Why Is a Local Cement Plant Storing 45 Tons of Ammonium Nitrate in its Limestone Quarry?
According to today's Dallas Morning News, the Holcim cement plant in Midlothian is storing 45 tons of ammonium nitrate, the same substance that authorities believe caused the West blast, in its limestone quarry. Apparently no DMN reporter asked what a cement plant was doing with so much "fertilizer" on its premises. Using it as another weird "additive?" Storing it for some farmer friends? Why Holcim and not TXI or Ash Grove? Plus the DMN reporters apparently never even visited the site and described the area as void of houses and schools. In fact, Downwidners' founder Sue Pope and others live just north of the Holcim quarry – close enough for them to be affected by the blasts of rock when the cement plant mines the limestone in that same quarry. And there are at least two schools within a mile of the place.
We've got an inquiry pending with Holcim representatives asking about the presence of the chemical on site. If we get an answer we'll let you know. Meanwhile, we're left to wonder why it took a disaster in West to bring this strange development to light.
Downwinders and Others File Stay Against EPA Over Weakened Cement Plant Rules
Seventeen years and counting – that's how long Downwinders at Risk has been fighting to get the EPA to modernize their rules for waste-burning cement plants. And we're not giving up.
On Wednesday, a national coalition of environmental and community groups that included Downwinders at Risk asked a federal court to stay a decision by the U.S. Environmental Protection Agency to weaken and delay Clean Air Act protection against toxic pollution from cement plants.
By the agency’s own calculations, the delay will cause between 1,920 and 5,000 avoidable deaths and will allow cement plants to release an additional 32,000 pounds of mercury into the environment.
The complete list of groups seeking relief include Cape Fear River Watch, Citizens’ Environmental Coalition, Desert Citizens Against Pollution, Downwinders at Risk, Friends of Hudson, Huron Environmental Activist League, Montanans Against Toxic Burning, PenderWatch & Conservancy, and the Sierra Club, all of which have members who live and work in close proximity to cement plants and have suffered from cement plants’ excessive pollution for many years. Earthjustice filed the stay motion on their behalf in the U.S. Court of Appeals for the D.C. Circuit. A copy of the groups’ motion can be found here: Cement Motion to Stay Rule
Cement plants are among the nation’s worst polluters, emitting vast quantities of particulate matter, mercury, lead, and other hazardous air pollutants.
“As if gutting and delaying the rule were not bad enough, EPA has essentially created a compliance shield for the industry, making it impossible for citizens to hold facilities accountable for their toxic emissions. These changes in the cement rule are irresponsible and reckless,” said Jennifer Swearingen, of Montanans Against Toxic Burning.
“Los Angeles is ringed by cement plants, and three of them operate near my home in Rosamond,” said Jane Williams, of Sierra Club and Desert Citizens Against Pollution. “The pollution from these plants hurts the people in this community and robs us of the outdoor lifestyle we came here to enjoy. We can’t wait two more years to get relief from these plants’ pollution. I don’t want anyone in these communities to be among the people this pollution is going to sicken and kill.”
Our own Midlothian is the cement capital of the United States and so Downwinders at Risk' Director Jim Schermbeck had something to say about the move. “The EPA seems to have learned nothing from having cement plants exploited as inadequate hazardous waste incinerators. As cement plants are once again becoming the nation’s Dispos-All, and new wastes are generating new emissions, the Agency is weakening air pollution controls and making it easier for cement kilns to poison their neighbors. It was wrong to turn kiln into incinerators in the 1980s and it’s wrong to try and do so again in the 21st century – especially accompanied by a roll back in regulations."
In North Carolina groups are fighting a massive proposed cement plant. “A gigantic foreign cement company wants to build one of the world’s biggest plants here,” said Allie Sheffield, of PenderWatch and Conservancy, a group that works to protect the coastal ecosystem in Pender County, North Carolina. “If this plant is built, EPA’s new rule will let it emit twice as much lead, arsenic, and particulate matter into our air and waters. At this point, I have to ask – why do they call it the Environmental Protection Agency?”
William Freese, of Huron Environmental Activist League, lives near what the EPA’s Toxic Release Inventory lists as the dirtiest cement plant in North America for point source pollution. “This makes one wonder how the EPA, in violation of U.S. Court of Appeals’ order, can allow this company to do keep polluting for two more years. By the time they get around to finally doing what’s right, they won’t have any environment to protect,” Freese said.
“Federal law required EPA to put limits on this pollution more than a decade ago,” Earthjustice attorney James Pew said. “But under one administration after another, the agency has refused to put limits in place. Real people suffer as a result of EPA’s scofflaw behavior, and now they are going to court to say ‘enough is enough.’”
The 1990 amendments to the Clean Air Act required EPA to limit cement plant’s emissions of hazardous air pollutants such as mercury. In 2000, a federal court had to order EPA to set these standards after the agency refused to do so.
In 2010, in response to a lawsuit filed by Earthjustice on behalf of community groups living in the shadow of cement plants, EPA finally set the standards that the Clean Air Act had required it to set more than a decade before. These standards would have significantly reduced cement plants’ emissions of soot, mercury, lead, benzene and other toxic pollutants by September of this year.
Rather than acting to clean up their pollution, cement companies attacked EPA’s new rule in court and in Congress. The attacks failed. The court denied their request to vacate or delay the standards, and legislative efforts to do the same failed to gain support on the Hill.
In 2013, however, the EPA voluntarily gave the cement industry the very relief it had failed to get in court or in Congress. It delayed emission reductions that were already more than a decade overdue for another two years, until 2015. Additionally, EPA weakened particulate matter standards and eliminated requirements that would have required cement plants to monitor and report their emissions to the public.
Citizens are down but not out. And we will never rest until we see cement plants regulated the way they should be when they burn so many different types of waste. We can fight this fight because of your support over the years. Please help us keep fighting by putting a bill in the tip jar. We need your help to raise our 2013 budget to keep our staff in the field working for your lungs. Thanks.
Can Obama’s EPA Save Us From TCEQ’s “Clean Air Plans”?
It's only a proposal, but the Obama Administration's plan to cut sulfur in gasoline is aimed primarily at drastically reducing smog-forming Nitrogen Oxide, Volatile Organic compounds and Particulate Matter, the major pollutants that causes DFW to have such bad "ozone seasons." Would it reduce it enough to finally put the region in compliance with the Clean Air Act? Good question.
Sulfur content in gasoline would drop from the current standard of 30 ppm to 10 ppm by 2017 – one year before the compliance deadline for the tougher 75 parts per billion national ambient air ozone standard. That's not a coincidence. The EPA hopes that this initiative is going to drive urban ozone clean-up throughout the country, even in stubborn dirty air hot spots like DFW, which hasn't been in compliance with a smog standard since it was created over 20 years ago.
Along with new stricter emission standards for cars that have already been implemented, the pollution from cars will be coming down over the next decade to historic-per-vehicle lows. Since forever, the state of Texas and local officials have put almost all the blame for DFW's poor air quality on cars. So does this mean that we might actually have a chance to breathe safe and cleaner air, by say, 2020?
Maybe.
First, there's the question of continued growth. If per-car emissions go down, but you're importing 120,000 more cars every year into North Texas, the decreases in emissions are being canceled out to some degree. In this respect, DFW has been its own worst clean air enemy. By attracting new residents year after year and, for the most part, not creating successful transportation options other than private vehicles, the Metromess dooms itself to more total car pollution.
Then there's the climate. Everyone knows how unbearably hot it can get in DFW during July, August and September. That heat and sunlight is one reason we have a smog problem – it chemically transforms the Nitrogen Oxides (NOx) and Volatile Organic Compounds (VOCs) into ozone. What if it gets hotter, and drier? When the ground can't cool off at night and you start out with high morning temperatures that will only get worse by 5 pm, you know it's going to be a bad air day. The more days like that, the harder it's going to be to have safe and legal air despite the changes in engine design and fuel specs. So climate change could rob us of some of those automobile reductions.
If the last couple of years are any indication, you also have to wonder how much of those vehicle changes will be lost on DFW because we live in the Barnett Shale. 16,000 gas wells that are relatively short-term air polluters are being supplemented with more processing infrastructure like compressors, refineries, and pipelines that are year round polluters. Last year's Houston Advanced Research Consortium study estimated the impact of even a single compressor or flare to be as much as 3-10 ppm within five to ten miles, something it would take thousands of cars to accomplish. Even if those cars aren't there anymore, or their emissions make them less of a clean air threat, you have these decentralized major sources taking up the slack. This is one reason why the state itself told EPA that last year there was more VOC air pollution coming from oil an gas sources in North Texas than all the area's on-road cars and trucks, and a large contributing cause to why air quality has been getting worse in DFW over the last two years.
It's not just the number of these facilities but their physical location as well. The more the gas industry moves eastward, the more of the DFW core urban area is "downwind" of these sources, the more the pollution from these facilities combines with car emissions and other urban sources, and the longer they take to leave the now 10-county "non-attainment area," meaning they linger, exposed to sunlight and heat, and have more opportunity to create high levels of ozone. If you have more flares and compressors within 1 to 3 miles of one of 18 or so state air monitors – you will probably begin to see higher ozone readings as a result of their operation – as you have the last couple of years. Most of these pipelines and processing facilities have come online only since 2006.
And that's just in the North Texas area. There's evidence to suggest that the gas industry's building-out to the southeast – or upwind – of DFW is also affecting our air quality. In the same way that Houston's air pollution is said to make our initial "background" ozone levels higher, so too the 60-100 compressors in Freestone County, about 90 miles southeast of Dallas also feed their under-regulated "Standard Permit" pollution into the DFW urban mix. As does the Haynesville Shale gas play itself, as do the remaining east and central Texas coal plants and so forth. If sources to the south and east continue to increase their emissions, it means DFW starts from further and further behind, so that even if cars get cleaner, they might not get so clean so fast as to compensate for this imbalance.
Then there's the "fire hose" effect of the three Midlothian cement plants sitting so close to one another as to create one large super plume that's usually pointed toward the DFW urban core most of "ozone season." Because of citizen efforts, those cement kilns are substantially cleaner in 2013 than they were as recently as 2008. All but one wet kiln is closed, and that one is due to shut down next year. None are burning hazardous waste. But they're still the largest stationary sources of pollution in North Texas – including emitting copious amounts of NOx and VOCs – and they can still impact monitor readings miles and miles away. It's unclear what impact the burning of newly-permitted "non-hazardous" industrial wastes like car parts and plastics in the Midlothian kilns will have on the formation of smog-forming pollution.
EPA estimates an 80% drop in VOC and NOX pollution from cars as a result of its new low-sulfur fuel rule. That's steep. Remove that amount of pollution from all DFW's cars and trucks, and you'd expect to see a substantial improvement in air quality. That's what you'd expect. But, depending on a lot of other variables the state and federal government may or may not be interested in fixing, it could take more than this proposal to bring DFW into compliance with the new 75 ppb ozone standard that is now the federal definition of safe and legal air.
Your’re Downwind of Lots of Burning Trucks
A funny thing happened to Dallas Morning News automobile columnist Terry Box while he was out test driving a new Dodge pick-up truck – it self-immolated and burned to ashes on the side of the road. As he writes about it, his experience is both funny and terrifying. But something he noted in how cars and trucks are made these days caught our eye:
"Open the hood of your late-model car or truck, and you’ll see a half-acre of plastic — actual engine pieces like valve covers, caps and containers for various liquids.
Thirty years ago, most of the pieces under the hood were metal and resistant to fire.
A fire in a modern vehicle burns fast and furiously. What’s intact for the moment can be gone or enveloped in toxic smoke in a matter of seconds."
Yep. When we've described the lovely new cement additive called ASR – Auto Shredder Residue – we've often talked about all the vinyl seats, dashboard and switches that get stipped out of a car and shredded, then thrown into a cement kiln. We really haven't talked about all the plastic in the engine compartment that would also be included in this new "fuel" that TXI has already been permitted to burn at its Midlothian cement plant.
As more and more of every car is made of "soft materials" – that is, not metal – more and more of it becomes fodder for cement kilns. This is material that could be recycled but isn't, and as long as it's cheaper just to burn it, there won't be amrket for recycling it.
Here's the thing, burning plastic creates bad kinds of pollution, including the creation of Dioxin, one of the most potent posions ever discovered by science. The same "toxic smoke" Terry Box saw pouring off of his burning Ram pick-up is created when you throw the same plastic parts into a cement kiln. The cement industry would like you to think that all of that is taken care of by the polluton control measures installed at the kilns, but it's not. There's no real time Dioxin montoring, much less any kind of monitoring for the host of other exotic fumes coming off burning plastic of various kinds. They barely even know what or how to test for such pollutants, but that doesn't keep the cement industry from marketing its kilns as "Long, Hot, and Good for America"™
If you're an old-timer, you might remember an earlier episode or two that occurred when the cement industry, including TXI, assured everyone that it could burn hazardous waste and make it completely disappear into water vapor. Remind us, how did that turn out?
Scientists: Classify Plastic As Hazardous Waste
We missed this the first time around, so we're glad that "Living on Earth" caught it again. A group of scientists, including marine biologist Chelsea Rochman, recently signed an article in the magazine Nature that called for classifying plastic as a hazardous waste.
What's the rationale? It turns out to be pretty solid and based on current regulations. As Rochman described it,
Waste is basically separated into two categories, those that are non-hazardous like grass clippings, and those that are considered a hazard, which are often based upon this long list of priority pollutants, or substances that the government deems are hazardous to organisms. And we found that plastics are associated with 78 percent of these priority pollutants listed by the US EPA and 61 percent listed by the European Union, either as a chemical ingredient of the plastic itself or when the plastic ends up in the aquatic environment; they absorb these contaminants from the water. And so from that perspective we thought maybe plastic as a waste product should also be considered as a hazardous substance.
Rochman cites styrene in Styrofoam as an example of a well-known pollutant that's incorproated into plastic. Another is vinyl chloride that's used to make PVC.
Plastics' threat to marine life has been well-documented, but it's also a threat to those living downwind of places that burn plastic wastes – like an increasing number of cement plants, including TXI's huge Midlothian Kiln #5. Besides being assaulted by the leftovers of the ingredients in the original plastic, downwind neighbors are also subjected to entirely new pollutants that are made ONLY when plastics are burned. The most notorious of these is Dioxin, one of the most potent poisons ever tested. Dioxin is what made Agent Orange so toxic to Vietnamese and veterans alike. It's why Times Beach Missouri is a Superfund Site. And it's what's released every time plastics are burned.
Incineration of plastics is dramatically increasing despite producing this kind of pollution. Classifying this waste as "hazardous" might be the only way to limit their use as "fuel" in cement kilns that weren't built to be garbage incinerators.