No It Isn’t.

Dallas smog aerialIt's unfortunate the Dallas Morning News chose to drink the Kool-Aid and say, that despite DFW once again getting an "F" from the American Lung Association for its smog levels, it "isn't as bad as it looks" because the air is "getting cleaner" than it was in…1999.

And 20 years ago too probably, but what about compared to, say, 2010? In that more relevant comparison, the answer would be no, the air is not cleaner, it's in fact dirtier. The average concentration of smog has inched up over the past two years and the number of monitors in violation of the old 85 parts per billion ozone standard has increased from 2 to 7 in 2011 and 6 last year. That's not progress.

The DMN story also doesn't mention that the state has tried and failed twice with its "clean air plans" to reach the obsolete 1997 standard, and it forget to say we face a 2018 deadline to meet the new 75 ppb standard. But don't worry because the air is cleaner than it was in…1999! Even if it's still not safe or legal.

 

Can Obama’s EPA Save Us From TCEQ’s “Clean Air Plans”?

Dallas smog aerialIt'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.

Study: Car Traffic As Bad As Second Hand Smoke in Causing Asthma

traffic jam_EQA large new European study released this week found that as much as 14% of chronic children's asthma in the Continent's urban areas could be due to traffic pollution. That would put it on par with the effects of second-hand smoke, linked to anywhere from 4 to 18% of all childhood asthma. 

"Air pollution has previously been seen to trigger symptoms but this is the first time we have estimated the percentage of cases that might not have occurred if Europeans had not been exposed to road traffic pollution," lead author Dr. Laura Perez, at the Swiss Tropical and Public Health Institute, said in a press release. "In light of all the existing epidemiological studies showing that road-traffic contributes to the onset of the disease in children, we must consider these results to improve policy making and urban planning."

Although the idea of getting cars off the road as a benefit of mass transit isn't new, this study and others that have been published recently flesh out a new public health concern about the immediate impacts of such reductions in the neighborhoods adjacent to highways. Often these neighborhoods are already low and moderate income, and/or minority-majority with higher-than-average asthma rates already institutionalized because of lack to access to care, poverty or other factors. Highway plannning has yet to take this kind of localized impact into account, especially in Texas and DFW, where regional highway builders are still salivating to build the Trinity Toll Road straight through the middle of Dallas or criss-cross Ft. Worth neighborhoods with the new "Chisholm Freeway."

Asthma affects one in 12 people, or 8 percent of the U.S. population, according to 2009 data from the Centers for Disease Control and Prevention. The number has increased since 2001, when one in 14 people were affected.

State Budget Writers Vote to Keep Raiding Anti-Smog Funds

l__burglar-cartoonToday brings news of the first skirmish in this year's state Legislative session over using anti-smog funds collected in DFW and other EPA "non-attainment" areas to ease budget gaps in general revenue. 

The Dallas Morning News has an account of local Dallas State Representative Helen Giddings teaming up with Houston Rep. Turner Sylvester during a House Appropriations Committeee meeting on Tuesday to make the case that the funds are desperately needed to help reduce air pollution in Texas' largest cities where unhealthy air is still the norm during "ozone season."

Everyone who gets their car inspected in North Texas pays an extra $6 that goes to the "Low-Income Repair and Replacement Assistance Program," (LIRAP). The money is supposed to be used to help low-income car owners upgrade their vehicles so they'll run cleaner. Because they can't afford to buy new vehicles as often, low income owners usually drive older cars. Older cars are dirtier cars. Fix them or upgrade them to newer cars and you reduce air pollution.

According to the folks that wear the green shades, the LIRAP fund will have approximately $77 million in unspent money at the end of August. Another $80 million is expected to be collected in the state's "non-attainment areas" over the next two years. That's a lot of car repair money. But as it turns out, state budget writers are proposing to only spend a little over $11 million in the next two years to be split up between Houston, DFW, Austin and San Antonio.

The size of the diversion has publicly angered elected officials in DFW and the other urban areas who are facing compliance with a new, stricter EPA smog standard by 2018 even as they annually fail to meet the old standard. In DFW and Houston LIRAP funding is traditionally used to build the clean air plans that must get approved by EPA. Without sufficient funds, local officials are telling the state that its next plan, due in 2015, might not get approved by EPA. You can imagine the disappointment in Austin of hearing that news.

Austin and San Antonio officials have actually threatened to pull out of the fee system all together unless they get more back of what their residents are putting in. That huffing and puffing paid off a bit Tuesday, as the Republican-led committee voted to approve an additional, but token, $1.4 million to those cities. Still, perhaps that lesson will not be lost on DFW officials, who have a long history of suffering silently as the state increasingly robs the region of its ability to control it's own air quality fate.

This was only the opening round of votes, and the House is more conservative than the Senate. But it's probably not a good sign that Rep. Giddings was the only one of at least five DFW-based members of the House Appropriations Committee quoted in News as leading the charge. Missing in Action was former Arlington City Council member and previous sometime-clean air supporter Diane Patrick, and oh yeah, the Chair of the Committee that hails from non-attainment Ellis County, Representative Jim Pitts. If the local North Texas clean air establishment can't get more help from its own players in the Lege, they're unlikely to see more money flowing their way.

Another Study Links Autism to Air Pollution

Autism_environment_boyThe more Ozone and Particulate Matter pollution a baby in the womb is exposed to, the more likely he or she will be born with autism according to a new UCLA study published March 1st in Environmental Health Perspectives, a peer-reviewed journal published by the National Institute of Environmental Health Sciences. It's the largest study of its kind to date and is the first to link autism with ozone, or smog, levels.

Researchers compared levels of air pollutants, mostly related to vehicle traffic, during pregnancy gestation periods of 7,603 children with autism and 75,635 children without autism, born from 1995 to 2006 in Los Angeles. Babies at the 75th percentile of exposure to toxins had a 8 percent to 10 percent higher risk of autism than babies at the bottom 25th percentile, the study said. Ozone and fine particulates had the strongest association with autism.

Using government air monitoring stations, researchers estimated average exposures during pregnancy to carbon monoxide, nitrogen dioxide, nitric oxide, ozone and particulate matter. The study adjusted for factors that include maternal age, birthplace, race and education. Using birth certificates, researchers compared control children with non-control children who had matching birth year, sex and gestational age at birth.

"These findings are of concern, since traffic-related air pollution is ubiquitous," said Dr. Beate Ritz, chair of UCLA's Department of Epidemiology and the study's senior author. She said she was reluctant to advise expectant mothers to leave LA or polluted cities, because that's not an option for many. "We can't tell them to not breathe or not go outside or not go to work," she said. She did recommend avoiding sitting in traffic, when pollutant exposure is worst."

Autism is a spectrum of disorders ranging from a profound inability to communicate and mental retardation to milder symptoms seen in Asperger's syndrome. The Centers for Disease Control and Prevention estimates that autism affects one in every 88 children born in the U.S., a 25 percent increase from 2006.

Research on autism and exposure to chemicals has been limited. Studies from 2006 and 2010 found an association between autism and air pollutants from industries and other sources.

A study in 2010 was the first to look at autism and toxins specifically from auto exhaust. The study, based in California, reported that children born to mothers living within 9/10 mile of a freeway during pregnancy were more likely to be diagnosed with autism than children whose mothers lived more than 1/4 mile from a freeway. However, the sample size — 304 autism cases and 259 controls — was much smaller than the just-published UCLA study.

Most policy discussions concerning air pollution in DFW surround the damage done to lungs, or maybe hearts and lungs. Rarely are the other, now well-known associations between air pollution and birth defects, or air pollution and brain function mentioned. And even rarer is the fact mentioned that these harms are often occurring at levels of pollution considered to be officially "safe" or at least legal. We really have no idea what the assault on our bodies by chemicals we involuntarily breathe actually can do to our health over the long term. That's why we should minimize exposure to them as much as possible. And that means limiting the chemicals' movements, not those of expectant moms.

Most Anti-Smog Money in Texas Doesn’t Go to Fight Smog

hoarding moneyOnly 12 cents out of every dollar collected in DFW to pay for anti-smog initiatives actually goes toward cleaning the air, according to representatives of the North Central Texas Council of Governments quoted in a new Texas Observer article.  Most of the money collected goes into the State's general fund to pay for other state programs.

Texas residents pay a small fee whenever they transfer a vehicle title or get their car emissions tested. Those fees are add up into big money every year – an estimated $772 million over the next two years. That funding is supposed to assist low-income families to get their cars repaired, and to help businesses purchase cleaner on and off-road engines. But only about $134 million is actually targeted for those clean air measures in the state's smoggiest areas – DFW, Houston and Austin-San Antonio. Everything else will be diverted according to a proposed state budget.

It's not like we don't need the money. For the last two years, DFW smog has gotten worse, and we're in our second full decade of failing to meet the Clinton-era smog standard even as we're looking at a 2018 compliance date for a much more stringent one implemented by the EPA last year. That means we have to have to go three years without exceeding that standard at any one monitor – beginning in 2015. That's not very long from now and that's why that money is needed now.  Not surprisingly, local government officials are a little upset.

“Our local and elected officials see it as county money that’s not coming back to the county,” said Shannon Stevenson, program manager at the North Central Texas Council of Governments.

The Capital Area Council of Governments, an association of ten Austin-area counties, has considered a plan to opt out of the program altogether, said Adele Noel, air quality project manager for Travis County.

“Honestly, we cannot operate if they do not give us more money,” Noel said.

So the North Central Texas COG is teaming up with other local governments in the state's largest urban areas and trying to redirect the anti-pollution funds back to their original purpose. With so many members of the legislature from districts affected by the funding shortfall, you might think they stand a good chance. But those other programs that get the money now also have their advocates, and not every member of the Lege from an urban county is necessarily sympathetic to clean air concerns. Stay tuned.

 

Study: Gas Drilling Cause of Wintertime Smog in Utah Basin

Wyoming Gas Field98 to 99 percent of the Volatile Organic Compounds (VOCs) and 57 to 61 percent of the Nitrogen Oxide (NOx) found in Utah's Uninta's Basin are emitted by gas drilling or production sources, and are responsible for worsening smog there, according to a new Utah Department of Environmental Quality study of air quality there.

The Basin is one of several large rural Western areas of the country that also includes stretches of Colorado and Wyoming where gas drilling has caused the phenomena of "wintertime ozone," creating smog as bad or worse than Los Anageles or Houston. 

Despite low snowfall this year, the Basin has still seen more than a dozen episodes of high ozone so far. The ozone readings can reach nearly twice the limit considered safe by the EPA and last for weeks at a time. In 2011, levels reached 139 parts per billion, nearly double the federal health standard. About 1,100 wells were drilled that year.

Leaks from pipes and tanks and fumes from pumps, dryers and compressors were major sources of volatile organics. Drill rigs and fracking were sources of nitrogen oxides and methane, according to the study.

While making no recommendations,the report did say that reductions in certain kinds of volatile organic compounds, including benzene and toluene, “could be particularly effective since they are not only a direct health concern but are more active in ozone production than many other” VOCs.

Time to Push Back and Make Some History

pushingbackDallas Plan Commission Public Hearings on Trinity East Gas Permits, including the "Rawlings Refinery"

Thursday, 1:00 pm

6th Floor Dallas City Hall, City Council Chambers

When the Dallas Plan Commission held its January 10th vote to "reconsider" the denial of gas permits to Trinity East, it didn't allow any public testimony at all about the dangers posed by these proposed drilling and production sites.

Tomorrow it will. And we need you to come and add your body and your voice to this fight.

When the Mayor and City Manager first cooked up this scheme to ram through the last three gas permits in Dallas, they didn't expect to have any roadblocks. They scheduled a meeting five days before Christmas and thought they had it locked up.

They were wrong. You showed up anyway and the Plan Commission voted to deny the permits based on your impassioned pleas for public health and safety.

When City Hall didn't like the results of that vote, and pulled the "reconsideration" stunt in January, 100 of you showed up on a work day to shame the CPC publicly in a meeting that received a huge amount of media coverage.

Now they're holding the second public hearing on these gas permits. We need a larger show of strength to demonstrate we're gaining momentum

We need you to personally come and tell the Plan Commission why it's a bad idea to allow drilling in floodplains and parks and build a refinery next to the city's largest soccer complex where thousands of kids will be playing every weekend.

We know it's getting tiresome, but when you show up at these meetings and hearings, you're helping us win this fight.

Slowly, but surely, your concerns and questions about these Trinity East permits are weighing them down and making it harder for them to get rammed through.

For example, because of your work, we're about to see a bi-partisan call for the Mayor to reject the refinery permit near the Elm Fork Soccer complex. That news will be announced at tomorrow's press conference starting at 1:00 pm.

There's also more in the works challenging the process the City is using to keep these "zombie" permits alive.

The tide is turning. But you have to keep showing up.

Nothing can take the place of a room full of angry citizens. Tomorrow, don't just watch history on TV or read about it the next day. Make history.  Thanks.

Red Alert for Dec 20th: Dallas Wants to Drill Like It’s 2009

This is a heads-up to all Dallas residents: Dallas City Hall – the building, the people, everything – has climbed into a time machine and traveled all the way back to 2010.

This has allowed the City council and staff to ignore citizen demands for a more protective gas drilling ordinance, the defeat of a council member who advocated drilling, the creation and conclusion of a task force for helping write a new ordinance, and a bunch of public hearings over the last two years – all so that Dallas City Hall can now just go ahead and do what the gas operators originally asked it to do at the beginning.

The first Special Use Permit request from a gas well operator to allow drilling in Dallas since 2010 will be on the agenda at the December 20th Dallas Plan Commission meeting at City Hall. It concerns a new request to drill by XTO (Exxon-Mobil) at the old Navel Air Station in southwest Dallas, near the Grand Prairie line, that was submitted on November 16th.

Time it's taken the City of Dallas to write a new drilling ordinance in Dallas: 24 months and counting

Time it took XTO to get its new drilling request heard despite not having that new ordinance yet: 20 days

You can read about the sudden jump into municipal action here behind the DMN paywall.

"XTO’s latest requests are apparently on a fast track, headed to the City Plan Commission….

A new, tougher Dallas drilling ordinance is in the works but has not been approved or even published for review, so the existing ordinance would govern the XTO applications, based on the city’s legal view that one set of rules should apply throughout the process."

Every Dallas City Council member appoints a representative to the City Plan Commission. Dallas residents should call their own City Council member (info here), or their Plan Commission appointee (download a list and contact info here) and tell them to reject this XTO request and any others that try to get processed before a new drilling ordinance is in place.

Here's the media release that Dallas Residents at Risk put out this morning about the sudden turn around:

Dallas Officials Consider Throwing Away Years of Work on New Gas Drilling Ordinance and Simply Let Fracking Begin

Have Mayor Rawlings and the Dallas City Council made a decision to move ahead with existing, pending and even new gas drilling applications without taking any action on the new “fracking” ordinance that has been in the works since 2010?

Two weeks ago, Exxon-owned gas company XTO filed a new gas drilling application—because their previous bid to drill at Hensley Field was denied by the Dallas City Plan Commission two years ago. Then the City Council appointed a special Gas Drilling Task Force, whose members met every week for eight months to consider proposals for a new ordinance. They finished their work in February of this year and issued their official recommendations, yet the City Council has not even begun drafting a new ordinance. The only rumored exception: City officials may consider simply changing the existing ordinance to allow fracking in floodplains, which would be necessary for gas company Trinity East to move ahead with its plans to drill in floodplain areas along the Trinity River. Neighborhood groups and environmental advocates say that’s unacceptable.

"This is the largest retreat of leadership that I can ever remember on such an important public health and environmental issue,” said Jim Schermbeck, Downwinders at Risk. “After three years of citizen complaints, a task force created, convened and concluded, expert and public testimony, and all Dallas residents get is a pair of shrugged shoulders from Mayor Rawlings and the Council? It's a bad joke."

There have been several major scientific studies surrounding the risks of fracking since Dallas officials began debating the new ordinance. Community leaders worry that new evidence pointing to health and safety risks for residents living near drilling sites will simply be ignored.

“So what if there's a 66% higher cancer risk within a half mile of a gas well; so what if already bad Dallas smog is made worse; so what if we still have no idea what chemicals will be used for fracking in Dallas,” said Claudia Meyer of the Mountain Creek Neighborhood Alliance. “It's as if the Mayor and Council are closing their eyes, plugging their ears, and desperately hoping to make all these new facts go away by just pretending they never happened.”

The new drilling applications leave Dallas officials exactly where they started, with the City Plan Commission being asked to shoulder the responsibility of deciding on whether to allow fracking to go forward. Advocates say the Commission should decline this offer and let the City Council do what it said it was going to do: Draft and pass a new gas drilling ordinance first.

“If we were only going to end up where we started, what was the point of a task force, or public hearings or anything that's happened since permitting stopped because the City wanted a new drilling ordinance,” said Zac Trahan with Texas Campaign for the Environment. “This is complete and utter dereliction of duty and public trust by the elected officials of this city on one of the most important public health and environmental questions to face Dallas in decades."

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

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

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

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

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

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

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

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

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

Health Consultation/Assessing the Public Health Implications of the Criteria (NAAQS) Air Pollutants and Hydrogen Sulfide MIDLOTHIAN AREA AIR QUALITY MIDLOTHIAN, ELLIS COUNTY, TEXAS
NOVEMBER 16, 2012 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Community Health Investigations

Recommendations:

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

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

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

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

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

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

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

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

From Sulfur Dioxide:

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

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

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

From Particulate Matter, or Soot:

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

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

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

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

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

From Lead:

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

From Smog:

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

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

From Breathing Multiple Pollutants:

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

From New Production:

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

 

Regulatory "Safe Levels" Very Often Aren't

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

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