GAF’s Environmental Record

Beginning in the summer of 2021 Singleton United/Unidos and its allies used Freedom Of Information and Texas Open Records Act requests to obtain all files concerning GAF from the Environmental Protection Agency, Texas Commission on Environmental Quality, and the City of Dallas. Despite reviewing thousands of pages dating back to 1979, it’s clear the files we received are incomplete and contain important gaps of information. This timeline is the best reconstruction of important milestones in GAF’s environmental record that we could assemble using those files. As of May 5th, 2022 it covers the years 1979 to 2009.

For a complete inventory of the environmental and public health hazards GAF currently poses, please see the GAF’sGottaGo Campaign’s “The Case for GAF Amortization.”

1979 Off To a Bad Start

June 20, 1979 

GAF applies for a permit for a new shingle production line

General Aniline & Film (GAF) has been doing business at the same Singleton Boulevard site since 1946, but there’s no record of any government oversight of the factory until 1979 when the company applies for a permit with the Texas Air Control Board (TACB) for a new asphalt shingle production line.

GAF’s new Line No 3 will replace an older line and use glass matt backing instead of felt. GAF will continue to operate another unregulated “grandfathered” shingle production line as well.

GAF’s 1979 Permit Application lists the estimated emissions from the new Line Number 3:

Solid Airborne Wastes:

39 tons of Particulate Matter pollution a year

Gaseous Airborne Wastes: 

“None From process”

Proposed pollution controls will include “Baghouses, Electrostatic Precipitator, and Fume Incinerator”

GAF proposes construction begin in September 1979 and schedules opening by January 1, 1981.

At the time GAF applies for its new permit, West Dallas is already a part of two federal “non-attainment areas” for air pollution. That is, levels of air pollution are routinely exceeding federal standards. One is for ozone, or smog, and it includes the entirety of Dallas County. The second applies only to West Dallas. It’s for Particulate Matter (PM) or soot pollution. The RSR smelter was still pouring hundreds of tons of lead-laden soot into West Dallas air and neighborhoods.  GAF and other industries along Singleton and throughout West Dallas were also contributing to the PM problem.

It’s supposed to be harder to locate new large sources of air pollution in a non-attainment area for that same kind of air pollution.

Less than a month after GAF submits its permit request to the Texas Air Control Board, the first concerns over the factory’s Particulate Matter, Sulfur Dioxide, and Volatile Organic Compounds pollution are raised…by the City of Dallas.

July 30, 1979

The City of Dallas submits a letter recommending changes to GAF’s proposed permit

GAF is presently a major source for particulate matter and Hydrocarbons in Particulate and ozone in particulate and ozone non-attainment area. It is expected that installation…would add 86 to 115 tons of hydrocarbons a year and 2800 to 2900 tons of Total Suspended Particulates per year (uncontrolled)….

” We would request that the Texas Air Control Board model the impact on the ambient (PM) monitoring site…”

“It is seriously recommended that stack sampling for particulate be conducted…”

We would also recommend consideration of stack sampling for sulfur dioxide…”

“…we calculate that hydrocarbon emissions…will exceed the 250 pounds per 24 hour exemption limit”

“…there is some question as to whether the precipitator can handle oily emissions from the coater, etc. without a scrubber.”

Dallas’ own estimates for Sulfur Dioxide emissions from GAF’s new production line is approximately 39 tons a year – or 30 more tons a year than either GAF or the state are estimating at the time.

Dallas also estimates GAF’s new line will release at least 10 tons more Particulate Matter a year than the company is listing in it permit.

Nevertheless, the City of Dallas says it will approve the permit if its recommendations are incorporated into it.

August 1979

State Modeling Shows GAF Permit Will Cause High PM Levels; State Looks the Other Way

Texas Air Control Board memo: “Tech Review”

“This facility is located in a non-attainment area for PM in Dallas. It is 800 meters from a sampler showing particulate matter levels to exceed the primary standard. Emissions of Particulate Matter from the facility allowed by this permit are 33.2 tons per year.

Modeling indicates the maximum annual contribution at the nearest sampler to be 0.7 ug/m3 using the TCM. The Crster model predicts a maximum of 6.7 ug/m3 at the sampler for a 24-hour period.

Significant levels are defined by the General Rule at 1.0 ug/m3 annual and 5.0 ug/m3 for 24 hours. Since this is not a major source our rules do not require it to be below significant levels”

Translation: As part of its review of GAF’s proposed permit, and per the City of Dallas’ request, the Texas Air Control Board performed preliminary computer modeling using the pollution levels GAF submitted with its permit request. That modeling revealed GAF’s proposed Particulate Matter pollution came close to exceeding the level of concern for annual exposure and DID exceed the exposure level for the 24-hour standard – even before the new line produced a single shingle. Normally this would require a deeper analysis and perhaps changes to the permit.

But the TACB engineer uses the excuse that GAF is not officially defined as a “major source” of Particulate Matter pollution  i.e. a factory capable of releasing 100 tons of PM a year, and so these red flags from the modeling can be ignored.

It’s not known if the specific results of this modeling were disclosed to the City of Dallas.

In 1979 not even GAF knows how much PM pollution it’s actually releasing every year. It’s never been subject to any stack testing, air monitoring, or third party oversight of any kind. In ignoring the first official red flags about GAF’s PM pollution, the State is taking the company’s word about its own pollution levels at face value.

October 2, 1979

Texas Air Control Board Awards GAF Construction Permit 7711 for Line #3

On the same day, the Texas Air Control Board sends a letter to Dallas resident Eulaine Hall, who had written in opposition to GAF’s new permit request in August.

“Our technical evaluation confirms that emissions will comply with all rules and regulations of the Board and will not cause or contribute to a violation of any National Ambient Air Quality Standard.”

The letter never mentions the results of the Air Control Board’s own modeling of GAF’s emissions. Looking ahead in the record, It’s very likely GAF was violating one or more federal air quality standards even as this letter was being drafted in Austin.

Only months into the regulatory system for the first time and GAF’s shingle factory is already the source of official concerns about its Particulate Matter, Sulfur Dioxide, and Hydrocarbon (Volatile Organic Compounds) pollution. Those concerns will only grow over the next 40 years.

Permit Revisions 1980-1981

Although only a few months have passed since GAF cleared the last regulatory hurdle to receiving a permit for the new No. 3 Line, the company is already making changes to it, including expanding the numbers of hours the factory will operate to 24 hours a day 7 days a week and changing pollution controls.

September 9, 1980

GAF begins construction of Line #3

Dec 17, 1980

GAF letter to EPA requesting the first change to its Permit: Expanding to 24/7 Operation

“Application for the permit was made …before any substantial progress had been made on detailed engineering for the plant expansion project…the conditions of the Prevention of Significant Deterioration permit are now at variance with plant operations”

The increase in hours will also increase Particulate Matter pollution from GAF by 2 tons a year to a new total of 35.4 tons per year.

On the same day, GAF sends a letter to the Texas Air Control Board that also admits: “At the time of application for the permit…most of the detailed engineering remained to be done.” GAF requests “certain changes” in the permit, including elimination of a dust collection control device.

January 14, 1981

Texas Air Control Board Memo: Tech Review of 7711 Revisions

The annual increase (of PM pollution) is from 33.4 tons a year to 35.4 tons a year. The annual increase is 6% and this is the change expected the annual GLC predicted by previously conducted dispersion modeling” (August 1979).

Note: no mention of the increase in the 24-hour PM emission levels that blew past the Agency’s parameters a year and a half earlier.

The City of Dallas program has requested that stack No 25 be sampled because of the high rate of emissions and because it is located close to a non-attainment area. Sampling of Stack No 25, which is the sand and talc storage control device is included in this permit”

February 2, 1981

City of Dallas Opposes GAF Permit Modification

“We are concerned with the close proximity of a major source to our ambient sampling site in a particulate non-attainment area…..We can not recommend approval of the modification of the permit application without minimal PM stack sampling”

April 28, 1981

Texas Air Control Board grants GAF’s requested permit amendment.

February 2, 1982

Even though the state hasn’t issued an Operating Permit for Line No. 3, GAF begins to run it, two-and-a-half years after requesting a construction permit and a year behind the original schedule.

Volatile Organic Compounds


May 20, 1983

GAF Lobbies to Delay Enforcement of Volatile Organic Chemical (VOCs) Emission Limits

Letter from GAF to the Texas Air Control Board

“Problems exist however in demonstrating compliance with the (VOC) emission limitations in the permit. First, U.S. EPA references and the results of our own recent testing of ESP emissions elsewhere show conclusively that the 0.2 pounds per hour of VOC emissions is an unrealistically low limit. Emission ranges from 4 to 50 pounds per hour of hydrocarbons have been found, and the rate can vary with the source of the crude oil, the method of refining, and the temperature and agitation of the asphalt.

Furthermore, the permit limitations are for new sources only and do not include No 2 machine….”

“We suggest that the application of any VOC limitations to our operation be held in abeyance, and that the need for them be given further consideration after the results of the stack tests are known.”

“The same complications exist for particulate emissions, but there is a way around them in this case… The stack tests, then for both the ESP and the bag collector, can be run to show compliance with those outlet concentrations instead of mass emission rates…. “

“We have given thought to your question about retesting if No. 3 machine production increases 10% and we doubt that it be useful or necessary. VOC emissions can vary, regardless of line speed, and visual operations should be adequate to judge particulate compliance.”

June 3, 1983

GAF letter to Texas Air Control Board

“Another improvement in air pollution control has now been made, that might require an additional amendment. Fumes from the coater of No. 1 roofing machine, hitherto uncontrolled, are now ducted to the electrostatic precipitator.”

November 29 and 30, 1983

GAF performs stack testing on its Electrostatic Precipitator (ESP – a Particulate Matter control device) and the sand/talc storage tank dust collector.

VOC emissions from the ESP range from 2.16 to 5.42 pounds per hour. GAF’s construction permit had authorized only .20 pounds per hour.

June 8, 1984

City of Dallas Environmental Health and Conservation Department

Inspector: Rodger Jayroe

“While in the area of GAF corporation, dust emissions were observed from a vent in the area of the #3 product line. Mr. Moore (GAF plant manager) was contacted and an investigation was started. The dust emissions, which were heavy were coming from the baghouse vent (Emission Point #27) which controls the stabilizer heater. Mr. Moore asked if he could continue to operate until the weekend. He was told that if the emissions continued he would be liable for any subsequent violation. Mr. Moore ordered the #3 line stopped and the baghouse opened.

Several bags in the unit had been previously removed and short socks or boots placed over the air outlets. Some of these had torn and were replaced. The unit was restarted and the dust was as bad as before. The unit was again stopped and opened. Several bags were found to have holes in them and were removed. Some were full of dust. The Company did not have replacements and replacements had to be purchased. This repair and replacement operation resulted in a down time for the #3 line of three and one half to four hours.

Mr. Moore did not know how long the emissions had been in progress but due to the large number of bags that were defective it had probably been some time.”

August 29, 1984

GAF letter to Texas Air Control Board, commenting on the agency’s draft of its operating permit for Line #3 – up and running for over two years now.

Continuing efforts to increase (Line #3) production are proving successful, and a sheet speed of 500 feet per minute is expected to be attained before the end of the year, with a corresponding increase in production tonnage.

…with regard to the revised allowable emissions of volatile organic compounds…The three test results show almost a three to one variation from high to low, evidence of wide fluctuations in VOC emission rates…we believe at least a doubling of the base rate would be more appropriate.

Another variant from conditions that existed at the time of the stack test is the asphalt being used for saturant and coating. We are now using different asphalts from different suppliers, and their sources vary. A number of formulations are being evaluated, with unknown effects to VOC emissions.

…we think it preferable to defer imposing an upper limit on VOC emissions until steady state operation is achieved and actual emission rates have been measured.”

November 20, 1984

Texas Air Control Board memo

TACB requests GAF to perform VOC sampling at the “present (desired) capacity”

July 8, 1985

Texas Air Control Board Memo

“…the sample…revealed that there are VOC emissions not covered in the original permit or subsequent revisions. Company has asked for an amendment to include these VOC emissions.”

“Company accepts the 11.0 tons per year emission limit of VOCs for this asphalt coater.”

(GAF’s original estimate for VOC emissions was .88 tons per year.)

December 4, 1985

Texas Air Control Board awards GAF an operating permit for Line #3

Letter from Texas Air Control Board to GAF

An operating permit for your facility is enclosed. We will appreciate your carefully reviewing the conditions of the permit and assuring that all requirements are met.

We understand that the construction permit did not reflect the emissions of volatile organic compounds emitted from the asphalt coater. Pursuant to Rule 116.5 of Regulation VI of the Texas air Control Board, Permit C-7711 is hereby amended in accordance with your proposal.”

Emissions at the end of 1985 are stated by GAF and the State of Texas to be:

Carbon Monoxide 1.6 tons a year

Nitrogen Oxide 7.1 tons a year

Particulate Matter 35.6 tons a year

Sulfur Dioxide 9.2 tons a year

Volatile Organic Compounds 11.0 tons a year

TOTAL 64.5 tons per year

At this point, Line #3 has been producing shingles for GAF for just short of four years.


Installation of New Tanks and Terminal Makes GAF

An Asphalt Exporter

June 6th, 1997: GAF submits a Texas Natural Resource Conservation Commission Registration Form for Standard Exemption for two new asphalt storage tanks and a railcar/truck unloading terminal.

Proposed construction start is June 30th, 1997. Proposed operation is July 30th 1997

The two tanks are estimated to increase Particulate Matter pollution by 10 tons per year . VOCs are estimated to increase 1.1 tons per year.

Process Description: “Raw asphalt is received by truck or rail car at the unloading system, blended, and transferred to the storage tank. Both tanks are 250,000 gallon fixed roof tanks.”

Total annual throughput of 85,000,000 gallons of raw asphalt a year.

Railcars can hold approximately 7,560 gallons and require approximately 30 minutes to unload.

“Additonal flux may be blended at the Dallas plant and shipped off site for use at other GAF facilities.”

July 25th, 1997: Texas Natural Resource Conservation Commission issues Standard Exemption for construction.

2000-2008 Renewal of Permit 7711. Things get worse.

Permit 7711 is GAF’s major operating permit, covering the volumes and varieties of the pollution released from all of the factory’s “emission points.” The State has sent GAF a reminder to submit a renewal 90 days before it expires December 4th, 2000.

GAF is under the impression that the permit renewal will only cover the newer Line No 3.

September 25, 2000

GAF submits Permit Renewal Application, stating “The GAF emission sources have been in compliance with both the general and special provisions of the current Texas Natural Resources Conservation Commission air permit.”

GAF’s application lists raw materials inputs for Line 3 including:

Asphalt feed (including adhesives) averaging 25,000 pounds per hour x 8760 hours = 109,500 tons a year

Crushed limestone feed averaging 49,500 pounds per hour x 8760 hours = 216,810 tons per year

Granules feed averaging 43,750 pounds per hour x 8760 hours = 191,625 tons per year

Sand feed averaging 8,000 pounds per hour x 8760 hours = 35,040 tons per year

Glass Mat feed averaging 2,365 pounds per hour x 8760 hours = 10,358 tons per year

Hourly average raw materials feed: 64.3 tons per hour and 563,333 tons per year

Shingle Production averaging 125,585 pounds per hour x 8760 hours = 550,062 tons of shingles a year

These numbers are only for Line 3.

October 17, 2000

Texas Natural Resources Conservation Commission (or TNRCC, successor to the Texas Air control Board) tells GAF that the application for renewal is “administratively complete.” It will be the last piece of good news for awhile.

October 24, 2000

The Texas Natural Resources Conservation Commission tells GAF that “we have determined that your application is deficient. Additional information is needed to continue with our review:

  • Provide emissions for gas-fired coating heater
  • Provide products of combustion emissions (not currently permitted) for the stabilizer heater
  • Only one 1,200 cfm baghouse is permitted – correct to show the two installed
  • Provide emissions for the sand silo and the granuale silo

November 2000

Notes regarding odor complaint registered with City of Dallas. “Late Nite/Residential”

November 9, 2000

Public Notice published for Permit 7711 Renewal

November 13, 2000

TNRCC receives a request for a public hearing on GAF’s permit renewal from Irvin Uphoff of Dallas

December 18, 2000

For the first time a Texas Natural Resources Conservation Commission internal memo between staffers raises the connection between GAF’s newer Line No 3 and the factory’s older, “grandfathered” production Line No 1.

“You are reviewing this continuance for Permit 7711A for the ‘new line,’ but the asphalt blowing facility is a grandfathered operation. The short stack is the same one I noticed that had apparently ‘dense’ (considerable opacity) blue-black plume and only extends a few feet above the rooftop of a building it is in.”

December 19, 2000

The Texas Natural Resources Conservation Commission tells GAF their permit application is deficient a second time after getting no reply to its October 24h letter.

“We have previously notified you by letter dated October 24th, 2000 that your application for renewal of Permit No 7711A is deficient and additional information was requested (letter enclosed). You have not adequately responded to this request.”

GAF’s Reported Air Pollution Total in 2000

Carbon Monoxide 11.91 tons per year

Nitrogen Oxide 15.5 tons per year

PM 10 43.67 tons per year

PM 2.5 1.07 tons per year

SO2 3.22 tons per year

VOCs 17.58 tons per year

TOTAL 92.95 tons per year

2001: Permit Deficiencies

January 10, 2001

GAF’s First Response to October 24, 2000 State Deficiency Letter.

Included in its response is the admission that despite building it as part of Line No 3 in the early 1980’s, “we have not, to date, been able to locate specific information” on a key piece of pollution control, a dust collector.

Also included is what GAF says is a list of 13 “exempt” emission sources totaling 55 tons of air pollution a year. This “exempt” pollution is part of the 156.7 ton total GAF lists in a new Emission Sources Table for permitted sources it also submits. In other words, GAF is requesting that a third of its air pollution not be regulated by the State in this permit renewal.

GAF is now releasing more than twice the amount of air pollution the company estimated it would release in 1985 when lobbying for the Line No 3 operating permit.

January 25, 2001

City of Dallas Odor Surveillance Form

Description of the Alleged Effects: Difficulty in Breathing”

Description of Odor: “Smelled of asphalt”

Source emissions consistent with the alleged odors? Yes

Specific cause of the odor: “Source in or w/in confines of GAF facility.”

February 14, 2001

Texas Natural Resources Conservation Commission memo summarizing GAF

“This facility has been at this location for some time (prior to 1970) and has both permitted and grandfathered operations...It is (the permit engineer’s) opinion that there are facilities (previously grandfathered) that have been modified and need to be incorporated into the permit.”

“The plant is located in an industrial area. The closest off-site, non-industrial receptor is located approximately 300 feet to the East of the property line. There are several other non-industrial receptors located in the same direction…The remainder of the area (within 3000 feet) are industrial receptors that are located in all four directions.”

The view from a street of “non-industrial receptors” within feet of GAF’s WEST property line.

“Odors are light to moderate…Due to recent public notice, several complaints (odor) have been received by the regional office and/or the local program in Dallas. The Dallas program has made four visits, our monitoring group has made two, and possibly (the Toxics Air Risk Assessment group) has made an individual trip. Based on all the site investigations no nuisance conditions have been verified. As you know the nuisance rule is very difficult to enforce. The odor has to be of “such concentration and duration to be injurous to or adversely impact human health or welfare.” …also recieved a call from (State) Senator West’s office. The Senator’s office had received comment of odors and late night operations.”

February 27, 2001

TNRCC Sends 2nd Deficiency Letter to GAF Regarding Its Permit 7711 Renewal

“We have determined that your application is deficient, and additional information is needed to enable us to continue with our review. Please furnish the information indicated as follows:

“1. Provide an amendment applciation to include your production line 1 in this permit and to reflect the production changes from felt backing to fiberglass backing for the roof shingle production on this Line 1.”

“2. Provide emissions, calculations and emission points of CECO filtered vents for storage tanks and the asphalt fume emissions that are not captured in the line coating and are vented out the steam vents which are not represented on the permit.”

“3. Provide best available control technology for the above emissions.”

“Failure to submit all the requested information within 30 days of the date of this letter may result in the administrative voidance of your application.”

March 22, 2001

GAF responds to TNRCC’s Febraury 27th 2001 2nd Letter of Deficeincy

“The gathering of information on very old equipment required to perform the necessary calculations that you requested has not gone as quickly as expected. Therefore, we are requesting an extension of time beyond the 30-day limit stated in your letter….until Monday April 16th, 2001.”

March 27, 2001

GAF applies for a standard permit registration for its Stabilizer Storage Baghouse, a previously unlisted and unpermitted emission source. The Stablizer Storage tank is part of the truck and rail depot built in 1997 that also added two asphalt tanks for storage and blending. GAF estimates it will add 1.9 tons a year of Particulate Matter pollution.

April 20, 2001

GAF makes its first detailed response to the TNRCC’s Deficiency Letters for Renewal of 7711

1) In an attempt to keep its Line No 1 “grandfathered” and outside the jurisdiction of Permit 7711, GAF announces its intention to submit a new Voluntary Emission Reduction Permit (VERP) for Line 1

“Your information request was based….on the initial premise that the permit amendment was needed because Production Line No 1 lost its grandfathered status when (a) the shingle manufacturing technique was changed from the old saturated organic shingles to the fiberglass shingles and (b) when the production rate increased resulting from this change in production method. Nevertheless, after careful anlaysis and evaluation of this issue GAF has determined that the change you note…did not result in an increase in emissions (in fact it resulted in a decrease) and the production rate before and after is essentially the same. “

The VERP is only for PM and VOC pollution from Line No 1. No other pollutants – Sulfur Dioxide, Nitrogen Oxide, or Carbon Monoxide – are included.

2) GAF wants pollution from the 1997 Asphalt Storage Tanks to be grandfathered in the renewal…with no public hearing

GAF tells the State that its pollution from the asphalt storage tanks are Permitted by Rule but “is agreeable to folding this pollution into the renewal application” as long as they are “not considered a request for an emissions increase under the permit. As such emissions are already authorized by rule, inclusion in the renewal application is not an emissions increase and the authorization is not subject to an opportunity for a contested case hearing. It is also our understanding that emissions calculations would not be required for these emissions….”

3) GAF tells TNRCC that its “Asphalt Fumes” pollution should also be grandfathered

Fugitive emissions from Asphalt Roofing Line 1 are released into the production building and eventually make their way to the atmosphere via windows, doorways, and vents in the building”

“…the referenced emissions are fugitive asphalt fumes that rise from the hot asphalt that has been applied to the fiberglass carrier mat as it travels from the coater dip pan through the sand application station and on into the cooling section. Reference to steam is the water vapor that is produced as water is sprayed onto the hot asphalt surface to hasten cooling. The air and water vapor are vented from the cooling section via several unfiltered overhead roof exhaust fans.”

“..there has never been any sampling done of the air stream exhausting from the cooling section. With respect to emission from such cooling sections, member of our trade associaiton have indicated that such emissions have not been an issue for them…Notably TNRCC’s draft guidance relating to Asphalt Processing and Asphalt Roofing Manufacturing Facilities specifies no controls required for cooling section emissions. ”

“We have no information on the fugitive asphalt fumes that exhaust with the cooling section air, nor have we been able to locate information relating to such emissions.”

“…it is our understanding that the TNRCC typically does not set enforceable limits for fugitive emissions as part of the permitting process. To the extent these emissions are associated with Production Line No 3, the company believes they are authorized pursuant to the exisitng permit. To the extent they are associaited with Line No 1 they are grandfathered, and pursuant to the submittal today, should be authorized in accordance with the VERP permitting process.”

“Air dispersion modeling or ambient monitoring has not been conducted for this VERP application for the Dallas Plant”

4) GAF tells TNRCC a “Best Available Control Technology” review of its older equipment and Line 1 is not required now:

“There are no New Source Performance Standards that apply to the grandfathered sources at the Dallas Plant. Asphlt roofing Line No 1 was constructed prior to the applicability date of any potentially applicable NSPS.”

“There are no Maximum Available Control Technology standards that apply to the facilities at the Dallas Plant….”

“Due to the ages of these control devices, no vendor guarantees are available for the level of control.”

(In 2001 GAF’s Electrostatic Precipitator, or major dust control device, had not been stack tested since 1983, when Line No 3 became operational.)

“…with submittal of the VERP application for Production Line 1, a Tier 1 Best Available Control Technology (review) is not required. “

“With respect to storage tanks, because they meet the conditions for Permit by Rule, a control technology review is not required.”

“With respect to fugitive asphalt fumes, such de minimus emissions are not subject to control technology, because they are fugitive emissions, and as noted above, have not to our knowledge been subject to controls”

GAF concludes the letter by stating:

“Be assured that the Company is committed to operating in a safe and environmentally sound manner and authorizing emissions from its facility in an efficient and appropriate way.”

Raw Materials Feed for Line No 1

Asphalt (including adhesives) feed is averaging 11,900 pounds per hour

x 8760 hours = 52,122 tons per year

Stabilizer feed averaging 24,700 pounds per hour

x 8760 hours = 108,186 tons a year

Granules feed averaging 19,600 pounds per hour

x 8760 hours = 85,848 tons per year

Sand feed averaging 3,600 pounds per hour

x 8760 hours =15,768 tons per year

Glass Mat feed averaging 1240 pounds per hour

x 8760 hours = 5,431 tons per year

TOTAL Raw Materials Feed: 61,040 pounds per hour, or 267,355 tons a year

GAF is averaging production of 61,000 pounds of shingles per hour or 267,180 tons a year on Line 1.

Combined with Line 3 production averages, GAF is producing over 817,000 tons of shingles a year at its West Dallas factory.

April 30, 2001

TNRCC grants GAF a Standard Permit under Permit 7711 for GAF’s Stabilizer Storage baghouse, even though the company’s renewal for 7711 has produced two deficiency letters from the State that have yet to be resolved.

May 23, 2001

email from TNRCC Permit Engineer

“After July 17th, 1979, GAF replaced grandfathered Line 1 asphalt shingle felt (cellulose) backing with fiber glass mat backing….GAF claims emissions reductions and a permit was not required. When challenged, they provided a Voluntary Emission Reduction Permit application for Line # 1.

This started as a permit renewal for Line #3 and there is a hearing request. Also Senator West, Leigh Ing, Laura Carlisle, and a citizens’ group were next door on the old Dallas lead smelter site and smelled asphalt fumes. Big Stink! Can the company VERP or must they amend the renewal?

May 29, 2001

GAF tells TNRCC it has found new VOC emissions not previously disclosed and guesstimates them

“In your letter of February 27th 2001, you requested emission information on the asphalt fumes that are discharged along with the water vapor vented from the cooling section of the production line.”

“In our response letter we explained that we were not aware of any sampling information or emission factors that existed for this section of the production line. We were therefore unable to provide information on these fume emissions.”

“I contacted my counterparts in the roofing industry to determine if possible unpublished information existed on VOC emissions from the cooling section….the VOC emission factors are a range of 0.01-003 pounds of VOC per ton of product. Assuming the higher emission value, the production rate stated in the permit application, and 8760 hours a year of operation the calculated VOC Potential To Emit (PTE) is 8.85 tons a year.

June 11, 2001

TNRCC email in response to GAFs request for a Voluntary Emissions Reduction Permit

“The Company can VERP an “grandfathered” facility per the statute. In this case, is the line grandfathered? There is an amnesty clause in the rules so they my still apply for a VERP even though they modified their process. We need to talk. “

June 12, 2001

City On-Site Inspection Report: Creating a nuisance condition

“During the inspection a slight asphalt odor was detected.”

January 25th complaint summarized: “Creating a nuisance condition in the residential neighborhood near the facility”

“Facility currently does not have the potential to emit more than 100 tons per year of any critieria pollutant and has no Hazardous Air Pollutants on-site.” (editor’s note: this is inaccurate but no one is aware of it at this point)

…there should be no visible emissions from the facility during normal operating conditions. The plant does generate odors which leave the property line….”

“The asphalt is received in bulk by truck or train. The material is initially received stored in two upright tanks, transferred into a holding tank, then conveyed into smaller tanks. All tanks or stills are jacketed and heated with steam coils to keep the asphalt hot. A total of nine tanks are used for storage:

  • T-120 250,000 gallons
  • T-110 250,000 gallons
  • T-8 215,000 gallons
  • T-15 120,000 gallons
  • T-14 50,000 gallons
  • T-10 27,000 gallons
  • T-9 20,000 gallons
  • 2 Tanks 18,000 gallons

TOTAL 968,000 gallons of onsite storage

July 9, 2001

TNCC Permit Engineer to GAF: Newly Identified VOC Pollution Must Be Permitted

“The increase in emission of 8.85 tons a year VOC requires a permit amendment for authorization. The amendment must be complete before the permit can be renewed. I was expecting a permit amendment application from your consultants but have not recieved it to date. Also need to visit this facility again and observe the emissions from the blown asphalt storage tank. As I remember there were visible emissions from this tank for which you are claiming authorization under Permit by Rule 106.472 which states “liquid loading or unloading equipment for railcars, tank trucks , or drums, storage container, reservoirs, tanks, and change of service of material loaded, unloaded, or stored is permitted by rule provided that no visible emissions result...” We cannot allow authorization..if there are visible emissions.

“TNRCC Management has accepted the VERP application for Line 1 and I shall be sending you a publication under authorization for this permit”

July 12, 2001

GAF submits permit amendment for the 8.85 tons per year of new VOC pollution

Minor quantities of asphalt fumes continue to rise from the asphalt coated fiberglass mat in the short distance that it travels from the coating operation to the cooling operation. The asphalt fumes are emitted as fugitive VOC emissions that are eventually exhausted from the production building.”

July 18, 2001

GAF submits a TNRCC General Application Air Quality Permit Form Pl-1 for a Permit Amendment to cover the new VOC pollution

GAF classifies this as a “Change with insignificant Emission Increases.

July 31, 2001

GAF Finds More Undisclosed Pollution

TNRCC internal memo: Permit #7711 RENEW

“7711A…was reviewed and there were emissions that were not represented. These emissions required an amendment before 7711A could be renewed….during this renewal review process GAF applied for a VERP…Since there was difficulty in separating the Renewal, the Amendment and the VERP process, the company withdrew the VERP and included those facilties by Amendment.

GAF did not think they had Public Notice significant emissions in the Amendment and elected to test. We asked that they test for both PM and VOC.

The resulting additional allowable emissions are

VOC = 24.53 tons per year

PM = 43.82 tons per year.”

Translation: After using nothing but a guesstimate to quantify the “new-found” VOC emissions from their West Dallas factory cooling section, GAF actually samples the air pollution being released without the TNRCC present.

Although GAF believed their own stack testing would confirm their low numbers, it did just the opposite, showing the factory releasing over three times the amount of VOCs the company had claimed and exceeding the entire permitted total for PM pollution – all from this one “new source” that had never been on the books.

November 6, 2001

TNRCC email

SUBJECT: GAF 10/17/01 Site Visit

GAF is “operating outside the boundaries of their permit”

On October 17th 2001, the TNRCC permit engineer assigned to GAF’s Permit Renewal is accompanied by three other TNRCC staff members, a City of Dallas air pollution investigator, GAF’s Director of Environmental Engineering and GAF’s Dallas-based lead-counsel on a factory site visit in West Dallas. This is a TNRCC staffer’s description of the visit:

“We arrived at the GAF facility with winds out of the south and observed strong tar-like odors near property line of the facility. Two of us experienced mild nasal irritation when the strong odors were present.”

“(GAF’s Env Engineering Director) stated that no progress had been made in implementing TNRCC control recommendations from the December 2000 site visit.”

During the visit GAF was advised that they were operating outside the boundaries of their permit by rule having visible emissions and modifying the formerly grand-fathered production line...GAF must go through to amend their permit and the procedure for a request for hearing.”

“(TNRCC permit engineer) stated he had received two citizen’s odor complaints about GAF and one of which from Senator West’s office.”

“Like our first trip, only one of the two lines was operating. However, the one operating was the one with the larger production capacity (20-30% more). The other line was down for routine maintenance. During the tour (the Dallas investigator) noticed that the lime dust heater stack was puffing particulate matter and that no control device was connected. She suggested that it be addressed by adding a baghouse and/or checking the operation of the present set-up. (The TNRCC permit engineer) identified fugitive sources from 4 vertical storage tanks and 2 horizontal storage tanks that could be captured and routed to the incinerator. (The TNRCC permit engineer) also suggested GAF could extend duct work at the cooling section on the production lines to decrease visible emissions and possibly cut down odors.”

December 12, 2001

GAF representatives and TNRCC officials meet meet at Agency headquarters in Austin to address unpermitted pollution from the West Dallas factory.

“TNRCC will review if Amendment is required for the additional 8.85 tons per year. GAF will proceed to stack test under TNRCC protocol”

By the end of 2001, GAF’s “grandfathered” Line 1 is averaging 104,180 pounds of shingles per hour, or 456,308 tons a year, almost twice as much as the year before, and only 100,000 tons less than the newer and larger Line 3. Its pollution remains un-inventoried and un-permitted while Line 3’s permit 7711 expired over a year ago.

2002: The Cooling Section Gets Hot

January 17, 2002

email from GAF to TNRCC

GAF’s Own Consultants Tell Them They Have A Problem

GAF announces its intent to raise the height of the 8-foot Cooling Section Vents to 22 feet.

This is being done in reaction to recent news from their own analysis that the factory is violating state and/or federal PM and/or VOC air pollution standards with the vents at their current height.

Instead of reducing the amount of PM or VOC air pollution GAF proposes to raise the stack height of where that pollution is being released into the atmosphere. Raising the stack height will disperse the air pollution over a wider area. GAF is implementing a strategy often summarized as “The Solution to Pollution is Dilution.”

That kind of disbursement might work for gaseous fumes like VOCs, but PM is potentially harmful even at very low levels so in this case GAF could actually be exposing even more West Dallas residents to harmful air pollution instead of fewer.

“This is just a short note to ask about authorization requirements for the planned stack extensions on the cooling section vents. And to update you on the current level of activity. Progress has been a little slower than I would have expected since our meeting on December 12th. During December the plant was heavily involved in planning and preparation for their year-end shutdown in order to implement activities that can only take place during the extended shutdown.”

“We have obtained preliminary stack sizing information and have obtained bids for budgeting and planning purposes. The stacks will be extended from the current 8 ft height to a height of approximately 22 ft. Is an authorization or permit of any type required for this modification?”

We have authorized our consultant to complete the dispersion and GEP evaluation of the planned stack extensions…We anticipate that all work will certainly be complete by the end of February.

April 22, 2002

Two Months Later: No New Stacks

Things are taking longer than expected. Instead of February, GAF says it will now be May when the new stacks are up. GAF is commissioning computer air dispersion modeling to make sure the stacks are high enough to dillute its air pollution and avoid triggering violations of state or federal air quality standards.”

TNRCC email to GAF:

“No permit required. The stack is ductwork. It is not a source of emissions.. Does this mean you have finished the test???”

GAF email to TNRCC:

“No the plant has the cooling section stack engineering completed. They had a consultant do a full Good Engineering Practice analysis and a basic dispersion model to determine proper height, and discharge velocity.”

“The plant will soon be issuing a PO for fabrication and installation of the stacks….I would expect the work (and perhaps the stack sampling) to be done by the end of May”

June 10, 2002

TNRCC sends GAF a Notice of Violation for Failure to Submit Completed 2001 Emissions Inventory Questionnaire

For whatever reason, GAF’s West Dallas factory doesn’t submit its 2001 self-reporting estimates of releases of EPA’s six “Priority Pollutants” identified in the Clean Air Act. Because of the lack of monitoring and testing It’s likely no one at GAF or TNRCC can say for certain how much air pollution GAF is releasing.

June 13, 2002

GAF email to TNRCC

GAF: Let us use Grandfathered Line #1 to set pollution limits for both production lines

“We are proceeding with the installation of stack extensions over the cooling section of shingle Line #1 while issues with Line #3 are resolved. We anticipate the installation of the stacks may be completed before the end of the month.”

We would like to proceed with a stack test on Line 1 to produce a VOC emission factor (We realize that Line #3 is the production line for which the VOC emission value is needed).”

“The Line #1 shingle production rate will be documented during the stack test sampling. The VOC emission value resulting from the stack sampling would then be converted to a pds of VOC per ton of product produced. This would be comparable to the emission factor originally use to calculate the VOC emissions from Line # 3 cooling section.”

“We propose to use the VOC sampling results from Line #1 to produce an emission factor representative of the Dallas Plant machine layouts. This emission factor would then be used to calculate the VOC emissions expected from either shingle machine at their maximum anticipated production rate.

We will continue with the installation of the stack extensions as we agreed to do. However, before we perform the stack sampling on Line #1, we would like your input as to whether or not emissions factors derived from Line #1 stack sampling will be accepted as representative and suitable to use to calculate cooling section VOC emissions for Line #3 (It should be noted that sampling for Line #3 will also require an emission factor to be derived. The line will not be operating at the expected maximum rate. There are some minor modifications needed for the packaging section before rates can be attained.)”

December 9, 2002

GAF: Can we submit a new permit without public notice or hearing?

GAF email to TNRCC

“Would it be possible to combine the two permits into a single permit? I realize that Line #1 and the other so-called “grandfathered” equipment was submitted for permitting under a VERP application, but can a request be submitted to combine the two permits? (Without triggering public notice or public hearing)

“I’m about 98% complete with the Emission Source tables. Every time I review what I think is the finished product, I find another error or question I worked on yesterday…the plant also finished the stack test on the cooling section last week. I will await the results before inputting those numbers.”

It’s been two years since the expiration of

Permit 7711.

2003: GAF becomes a “Major Source”

January 16, 2003

State to GAF: No Public Notice Required. Write Your Own Permit Language

Email From Texas Commission on Environmental Quality (successor to the TNRCC) to GAF 7:53 AM

RE: “Dallas Air Permit Draft Review Questions revisited finally

“I had discussed combining the two permits into a single permit with my management. The answer was that we should be able to combine the two permits without additional public notice and of course without public notice there is no opportunity for a hearing request. You need to withdraw the VERP application for Line 1 and add Line 1 to the permit amendment application for 7711A for the addition of the cooling emissions….I think this is the best because the 2 lines are not easily separated for permit purposes. I would add the Torpedo style heaters to be on the safe side and this is the time to clean up everything.”

“Because of the lack of maintenance observed at the Dallas facility I feel compelled to provide you with some incentive to maintain all pollution control devices. Perhaps you can provide us with some wording that will do the same thing and is enforceable.”

“I hope you have been able to complete the testing of the cooling emissions…I have management asking me what is taking so long on these GAF permits. The answer is long and I am sure confusing to those not involved. The result is that we need to try to complete this permitting in the near future.”

GAF to TCEQ 9:31 AM

GAF to TCEQ: Whew!

“Obviously your management is concerned about the time taken for the permit process at Dallas – as is mine.”

“I’ve discussed combining the the two permits here and everyone agrees that it is the way to go, with qualifiers (of course):”

“1) this will not trigger a need for public hearing (which you indicate it won’t)”

“2) the VERP permit process allows older BACT requirements for older Line 1 than would apply to a Line 3 permit renewal. There were concerns that Line 1 would not meet BACT requirements. I explained that in my opinion the control methods used for Line 1 are identical to the control methods for Line 3 and therefore, if Line 3 meets BACT, than Line 1 should also (subject to TNRCC review and agreement).”

“I assume you are aware that the stack test was performed on the cooling section stacks at the Dallas Plant just before the year-end shutdown. I’ve been bugging the plant to get me some results, but they are slow to respond.”

February 20, 2003

GAF to TCEQ: Stack Testing Shows GAF is a “Major Source” for Particulate Matter Pollution, i.e., it releases 100 tons or more of PM annually

“I apologize for the delay in getting back to you with the final information needed to complete the Dallas plant permit: the emissions from the cooling section.

“We’ve encountered a problem with preparation of these final values which I’ll attempt to explain.”

1) We’ve received the stack test report that provided emissions for both VOC and Particulate being emitted from the cooling section stacks for Line #3.

2) Although the VOC values are higher than expected, they have not resulted in the same level of concern as the Particulate values.

3) The Particulate stack test results indicate 13.52 pounds an hour of PM (8760 hr/yr divided by 2000 pounds/ton = 59.2 tons yr PM as PTE

“4) Prorating these results for smaller Line #1 yields approximately 49 tons /yr PTE”

5) Total Combined PM PTE for the cooling section ONLY from Line #1 and #3 equals 108 tons /year

6) The facility becomes Major Source for PM emissions.

“7) the Particulate values are of concern and we believe them to be inaccurate.”

This PM emission value of 13.52/pounds per hour is 5 to 6 times the UNCONTROLLED PM emission rate coming from the roofing shingle coater, as determined by stack testing performed by the roofing industry in conjunction with with the EPA while evaluating plant emissions for the asphalt roofing MACT standards.

Based on residents’ complaints and official investigations it’s likely GAF was a “Major Source” of PM pollution since shortly after Line 3 began producing shingles in the 1980’s. But because no actual monitoring or testing was done to confirm what GAF was estimating in its paperwork to regulators, the discovery was delayed by two decades.

The State used GAF’s lack of Major Source status to ignore red flags about its PM pollution from the beginning in 1979.

March 25, 2003

GAF: Our Stack Test Must Be Wrong

GAF email to TCEQ

“As you may recall, I previously explained that the Dallas Plant was the first GAF plant at which stack sampling of the cooling section stacks has been performed and we had no idea what results to expect. Based on discussions with a contact from another roofing company in the industry (who has done some cooling section sampling) I had some idea of what emission rates we should see.”

After performing the stack test the emissions were far higher than expected and did not seem reasonable based on known emission rats from other emission sources in the plant. Therefore we requested a third party to review the stack test report..

….Based on his review of the cooling section stack test, we believe there exists significant potential for excessive error in the results. We believe that the stack testing should be redone an have initiated effort toward this objective… is believed that the sampling should be performed with all three stacks being sampled simultaneously, rather than sequentially.”

March 26, 2003

TCEQ: GAF Stack Test Perfectly Normal

TCEQ internal memo

“Yes, (TCEQ staff) attended this stack test. No unusual situations or deviations from the methods were encountered. I would be curious to see the review conducted by (the GAF consultant) and what specific issues/biases were with the sampling/analytical data. Have you received a copy of the test report? The region has not received a copy of this test report.”

June 10, 2003

Further TCEQ Review of Stack Tests Still Shows it Was Normal

TCEQ internal memo

(TCEQ staff) have read the response from (GAF’s consultant)…and we have determined that this argument, although understood, is not appropriate.….FYI, I have not seen the GAF sampling report….”

June 13, 2003

GAF letter to TCEQ

GAF: We’ll combine permit requests – as long as there’s no public notice

“This letter is submitted to confirm our discussions in which GAF agreed that the current air permit renewal application and the VERP permit application can be combined into a single permit for the permitted facility.”

“Based on our discussions, it is our understanding that combining these permit applications into a single permit will not subject the permit or applications to further public notices or public hearings before the final permit can be issued.”

September 3, 2003

TCEQ to GAF: Still waiting for those almost year-old stack test results…and your total air pollution inventory

TCEQ email to GAF

Question number one: Have you completed the test for the cooling emissions?

Question number two: Have you completed a table 1(a) with emissions for the entire plant? This is needed to combine your permits into one permit without going to public notice.

Look forward to these answers soon.

September 4, 2003

GAF: Our Lousy Pollution Control Equipment is Responsible for the High PM Numbers

GAF email to TCEQ

“Regarding your questions:

1). Have we completed the test for the cooling emissions? (In a word, “No”) a) As you know we completed the initial cooling section stack test back in December. I had it reviewed by (the GAF consultant). He had some concerns with the test results which I forwarded on June 6, 2003. b) you sent these comments to (TNRCC engineering staff member ) and he responded on June 10th basically commenting that, although he had never received a copy of the stack test report, he concluded the sampling was acceptable. c) I emailed a copy of the report to (the TNRCC staffer) on June 24, 2003 and asked that he contact me after he reviewed the report. I haven’t heard from (the TNRCC staffer). d) in continued preparation for another stack test, (GAF consultants) visited the Dallas plant on June 12th for a pre-test review an submitted comments on June 30, 2003. “

“e) their comments raised one big issue that impacts the stack testing: they noted the air draw from the roof exhaust fans is apparently greater than the dust collector draw at the sheet back-surface sand applicator (which is just before the sheet enters the cooling section). Therefore, very light fine sand appears to be pulled by the roof fans and exhausted via the cooling section – contributing to high PM results in the stack test. f) we are currently working to find a “material handling” consultant to design and upgrade to the existing sand applicator dust collection system….g) we expect the modified sand application dust collection to significantly reduce the PM emissions from the cooling section. h) Permitting will need to be done once the modifications are defined….Design and installation is probably 4-6 months away. How should this be handled with the current permit renewal?”

2) Has Table 1(a) been completed for the entire plant? a) I sent the attached version of Table 1 (a) for Line 1 and 3 back in January before we agreed the two lines could be combined into a single permit. b) should the permit values be combined for a revised Table 1(a) set of values? c) I note that these versions of Table 1 (a) do not have values for the cooling section. I was awaiting the stack test results. I presume I should now incorporate the December stack test values?”

October 28, 2003

TCEQ Declares GAF permit Amendment for Cooling Section Pollution “Technically Complete”

Letter from TCEQ to GAF

This is in response to your FormPl-1 entitled “General Application for Air Preconstruction Permits and Amendments” and Form Pl-1R, entitled “General Application for Air Permit Renewals” concerning your proposed amendment and renewal of Permit Number 7711A. We understand that you propose to renew the referenced permit and amend it to include additional emissions from the Line 3 cooling exhaust and include all of Line 1 (formally grandfathered). This will acknowledge that your application for the above referenced amendment and renewal is technically complete as of October 28th 2003.

November 5, 2003

GAF Comments on its own permit 7711 renewal language being proposed by TCEQ

Comments: Dallas DRAFT Air Permit 7711A of 10-27-03

We would like to have the 90 days after issuance date of this permit extended to 180 days. As you are aware we are currently planning modifications to the sand applicator dust control system in order to reduce the fines (PM) that are exhausted via the cooling section exhaust.”

“Please revise the PM 10 values for this Source (EPN 8). Based on recent stack testing and other facilities, we have determined that PM 10 emissions from blowstill thermal oxidizers are much higher than PM values. Evaluations are still in progress to determine the cause of the situation.”

“Maximum Allowable Asphalt Throughput Rate” – Please revise values for Line 1 and Line 3 to the following:”

Line 1 at 24,886 per hour

Line 3 t 41,472 per hour

171 tons per hour of finished shingles

1,498,000 tons per year of finished shingles

NOTE: these values are higher than in the draft permit. The emission rates for EPN 34 were calculated on pounds per hour of operation (at 8760 hours a year) and should satisfy these higher rates. Also, they are based on production rates not yet achieved by the plant, but efforts are currently in progress to make them reality. They may not be achieved by the time stack testing is performed but Item 13 of the Special Citations addresses this situation.

GAF Draft Permit 7711 (Predicted) Emission Estimate 2003

Particulate Matter 98.21. tons per year

Volatile Organic Compounds 43.77 tpy

Sulfur Dioxide 3.39 tpy

Nitrogen Oxide 33.01 tpy

Carbon Monoxide 26.83 tpy

TOTAL 205.21 tpy

It’s been three years since the expiration of GAF’s Permit 7711. There’s still no full accounting of all of GAF’s air pollution and no new pollution control devices installed.

2004: “All NAAQS and state regulations were exceeded”

February 10, 2004

TCEQ: GAF’s PM Pollution is Violating Federal Air Quality Standards

TCEQ Internal Memo

Subject: Modeling Report – GAF Materials Corporation

“Modeling Summary: As requested the (TCEQ) Air Dispersion Modeling Team conducted preliminary State Property Line and National Ambient Air Quality Standard particulate modeling from certain existing emission sources at the GAF Materials plant. The results are summarized on Tables 1 through 3 below. The test show exceedences over the 1-hour/3-hour PM and 24-hour/annual PM 10 standards occur.”

February 10, 2004

Email exchange

TCEQ to GAF: You have to show you’re not going to break the law

“I had our modeling group perform a screen model of the proposed PM and PM 10 for your proposed permit 7711A. All NAAQS and state regulations were exceeded. We request that you perform an impact analysis for this proposed permit to show that it meets all federal and state regulations for criteria pollutants.”

GAF to TCEQ: Just PM, Right?

We have contracted with Trinity Consultants to do this work….In my discussion with them I stated that PM/PM 10 is the only pollutant needing evaluation (please confirm).

TCEQ to GAF: All pollutants should be included

“In my letter which you should get soon, I have requested modeling of all criteria pollutants, PM, PM 10, NOx, Co, SO2, VOC. I do not think there is any lead.”

July 15, 2004

GAF Confirms Its a Major Source for PM Pollution…and learns that burning Sulfur produces Sulfur Dioxide

GAF email to TCEQ”… the plant is now a major source for PM/PM10 emissions and therefore will require a Title V permit.….We had been closely watching this issue as the permitting progressed.”

“The change in PM 10 emissions for the thermal oxidizer was a significant increase. We historically have not performed stack testing for PM 10 and limited data is available on PM 10 emissions from thermal oxidizers or afterburners that are used to burn asphalt fumes. We recently did stack testing at two of our facilities that have had PM10 limits stated in the most recent versions of the air permit. We discovered that PM10 emissions were higher than PM emissions and we believe this is due to the fact that condensible particulate is included in the count for PM10 but is not included in the PM count.”

Based on the results of Internet searches on PM10 emissions, we believe the high PM10 values may result from sulfur in the asphalt fumes that are being burned. The sulfur produces SO2 when burned and then apparently condense in the condensible particulate cooling step of the PM 10 sampling apparatus. We have found one specific research report that tested PM 10 emissions levels as a function of sulfur in the burning of fuel oil. The report indicated that the PM10 emissions levels increased in direct proportion to the sulfur content.

“As with the stack tested plants, the Dallas Plant boiler is also a thermal oxidizer that burns asphalt fumes. We therefore felt that the PM 10 emission value needed to be increased to incorporate the new information we have learned about asphalt fume burning and PM 10 emissions….I failed to update the spreadsheet after giving this revision to Trinity Consultants and I didn’t realize that PM/PM 10 emissions now exceeded the 100 tons a year threshold.”

March – June 2004?

GAF submits new computer air modeling for five pollutants showing no violations of federal air standards.

Despite requesting all GAF files from EPA and TCEQ for this archive, this second, much more favorable 2004 air modeling report could not be located. The only references to it are passing mentions in TCEQ internal memos from October and December 2004, and the July 30, 2004 comments from the TCEQ’s Executive Director dismissing requests for a public hearing on Permit 7711. He uses this second set of numbers that GAF generates at the last minute (and that apparently the TCEQ accepts) to argue predicted levels of air pollution numbers from GAF will be below federal air standards. No mention is made of the initial results that prompted this second set of numbers.

It’s unknown how long after the state made the request for new modeling in February 2004 that this second run was performed, or by whom. The memos and comments only reflect the convenient drop in PM levels that now allow GAF to be in compliance with federal air standards …by a theoretical .54 ug/m3

July 30, 2004

TCEQ’s Executive Director Dismisses Residents’ Concerns About GAF, Recommends Renewal

Letter to all residents objecting to GAF permit renewal

As part of the renewal process for Permit 7711, now it in its fourth year, the TCEQ’s Executive Director must respond to all public comments objecting to it as it proceeds to a final vote of the TCEQ’s three Commissioners.

In this process, the Executive Director is assigned to advocate for the TCEQ’s position. In this case, he’s reassuring residents about the Commission’s decision to go forward with GAF’s renewal.

In response to concerns raised by residents that GAF will cause air pollution, exceed air quality standards, and produce nuisance odors, the Executive Director notes that:

A renewal application does not address a facility’s impacts on the surrounding area or the changes in the surrounding area” …the review of a renewal application is limited by law, and to renew their permit the Applicant must demonstrate that the facility will continue to operate in accordance with all the requirements and conditions of the existing permit. As long as there are no changes to the facility and as long as the compliance history reveals general compliance with environmental laws, the Applicant is eligible to renew their permit. The Commission may only impose more stringent conditions at renewal if it is necessary to avoid a condition of air pollution or to ensure compliance with otherwise applicable federal or state air quality control requirements.”

….the (TCEQ) permit reviewer identifies all sources of air contaminants at the facility that is proposed to be modified and assures that the facility will be using the best available control technology (BACT) applicable for the sources and types of contaminants emitted…applying BACT results in requiring technology that best controls air emissions with considerations given to the technical practicability and economic reasonableness of reducing or eliminating emissions.”

“…appropriate air dispersion modeling was performed; and the likelihood of whether this facility’s emissions would cause adverse health effects in members of the general public, including sensitive subgroups such as children, the elderly, or people with existing respiratory conditions, was determined by comparing the facility’s predicted air dispersion modeling concentrations to the relevant state and federal standards. The permit reviewer used tis facility’s modeling data to verify that ground level concentrations of emissions are not likely to adversely impact off-property receptors. The TCEQ Air Permits Division reviewed the modeling predictions, and the analysis was acceptable.”

“According to the facility maximum allowable emission rate table in the draft permit, it will emit approximately 98.21 tons of per year of particulate matter, 33.01 tons pr year of nitrogen oxides, 3.39 tons per year of sulfur dioxide, 26.83 tons per year of carbon monoxide, and 44.77 tons per year of volatile organic compounds. These emissions are not expected to create nuisance conditions.”

Some facts going unmentioned in the Executive Director’s response:

Line #1 has never had a permit and the original Line #3 permit that began this renewal process is now unrecognizable.
Total air pollution levels are twice what they were only four years earlier when the renewal process began.
Over the last four years GAF, required monitoring and testing has “found” huge amounts of “new” pollution previously unreported in ANY permit.
GAF’s own air dispersion modeling, as well as TCEQ’s, has shown the factory’s air pollution violating federal air quality standards.
GAF is having to raise the height of its smokestacks to prevent computer-modeled violations of federal air quality standards.
There are no modern “Best Available Control Technology” standards for much of the equipment and processes GAF is operating in West Dallas.
GAF was likely operating “outside the boundaries of its permit” for most of the last two decades, with all of its air pollution unmonitored and untested by regulators.

October 21, 2004

TCEQ Letter to GAF

GAF withdraws its VERP permit application for Line #1

…we are withdrawing the Voluntary Emission Reduction Permit Application…We understand that GAF Materials has agreed to autorize th Asphalt Roofing Line #1 by amedning Permit Number 7711A.”

October 21, 2004

TCEQ Executive Director approves GAF’s application for Renewal of Permit 7711

2005: Stack Testing of the Electrostatic Precipitator

An Electrostatic Precipitator (ESPs) is a pollution control device for particulate matter. ESPs remove particles from emissions by using electrically-charged particles. The charged particles attach to rows of metal collector plates carrying the opposite charge. The collected pdust articles may be removed from the collector plates as dry material (dry ESPs), or they may be washed from the plates with water (wet ESPs). Effective ESPs can remove 90% or more of a smokestack’s Partculate Matter.

But ESPs are NOT designed as pollution control devices for Volatile Organic Compounds. They’ve been show to remove less than 50% of the VOCs routed through them.

And yet in 2005 GAF is using its ESP as a pollution device for the VOCS being released from its Asphalt Coaters. As their name indicates the Asphalt Coaters release a lot of asphalt fumes. But fumes are gaseous. The’re composed of hydrocarbons like gasoline and diesel. These asphalt fumes are Volatile Organic Compounds. They are not particles. They can’t be controlled effectively by an ESP .

Most polluters burn off their VOC pollution in a giant incinerator called a “thermal oxidizer.” GAF has one but it’s not routing its VOC pollution from the Asphalt Coaters to it. Instead that pollution is being sent to GAF’s ESP.

GAF’s decision to use an ESP as a VOC pollution control device is one reason why the company had what it termed unexpectedly high VOC pollution numbers when it actually sampled the West Dallas factory’s releases in real time.

Instead of reducing the amount of VOCs coming from GAF by choosing another, more effective method of pollution control for the fumes, the company will simply write the amendment to cover the higher VOC pollution. There’s no incentive to decrease the air pollution.

The Stack Test results show GAF’s VOC pollution is almost twice as high as their permitted levels allow.

2006 -07: “Best Available Control Technology?”

April 5, 2006

GAF Submits Permit Amendment for 25 tons of “Unreported” VOC Pollution

“The Dallas Plant…is a major source with respect to the federal oeprating permits program (Title V) due to potential emisisons of Particulate Matter….”

“With this permit amendment application, GAF is requesting an increase in permitted emissions of Volatile Organic Compounds generated by the Asphalt Coaters and released from the Electrostatic Precipitator (ESP) vent.…It was determined from the stack testing that the internal estimate of potential VOC emissions was not sufficient to cover actual emissions exiting the ESP. Therefore, GAF is requesting an increase in permitted VOC emission rates from the ESP. “

GAF conducted VOC emissions testing from the ESP in May 2005.

Despite the technology being ineffective, the company tries to rationalize its commitment to an ESP for the control of fumes:

“GAF operates a thermal oxidizer that receives emissions generated from two blowing stills and asphalt and asphalt compound tanks. These VOC emissions sent to the current thermal oxidizer are considered ‘high concentration.’ Emissions from the coater would be collected over the coater and subsequently mixed with large quantities of air; therefore, they would be considered “low concentration.” GAF has determined that mixing “high concentration” and “low concentration” VOC streams prior to combustion in a thermal oxidizer is undesirable since the vapors will mix and create an explosive environment. Therefore, routing the coating emissions to the existing thermal oxidizer is technically infeasible.”

“GAF has performed an abbreviated economic analysis for the combustion of ‘low concentration’ VOC emissions in a new thermal oxidizer. Since the thermal oxidizer will need to be fired with natural gas, operating costs based on on the continuous combustion of natural gas are used to determine annual operating costs per ton of VOC emissions removed. In its economic evaluation GAF considered a thermal oxidizer achieving 99 percent control at a heat input capacity of approximately 14.5 MMBtu an hour. Using a natural gas price of $8.00 per MMBTu, the abbreviated economic analysis revealed a cost of $40,778 per ton of VOC removed. This expense does not consider capital costs and is considered economically infeasible. It is GAF’s position that proper Asphalt Coater opertion is considered BACT for this permit application.”

Using a thermal oxidizer could eliminate 25 tons of VOC a year and cost only a million dollars doing it. But GAF decides to spend no new money on pollution control and release that 25 tons of air pollution into the atmosphere every year.

This is what GAF and the State of Texas call “Best Available Control Technology.”

April 26, 2006

Request for Comments on VOC permit amendment from TCEQ to City of Dallas

Despite describing GAF as a “High” Nuisance and Hazard Potential, and citing it for excesive emissions, the City of Dallas tells TCEQ to proceed with the VOC permit amendment.

May 4, 2006

TCEQ: GAF submitted no air modeling for its VOC permit amendment

TCEQ email to GAF Consultants

“I’ve been assigned to reveiwed the amendent of Permit No 7711A, which would authorize anincrease inVOC emissins from the electrostatic precipitator. Short-term emissions would change from the current allowable 3.20 pounds per hour to 5.76 pounds per hour. “

“Reading the file I didn’t find any modeling submitted with this application. Since there is an increase in hourly emissions, you need to demonstrate that these emissionswould meet all federal and state standards, as well as TCEQ health effects guidelines.”

May 31, 2006

GAF to TCEQ: modeling shows no problem

….please find attached the screening modeling analysis for the Electrostatic Precipitator. Please note, the permit amendment application requested a short term emissions increase from the current allowable of 3.20 pounds per hout to 5.76 pouns per hour. As a result, only the increase in emissions (5.76 pounds per hour – 3.20 pounds per hour = 2.56 pounds per hour) was modeled….

The GAF screening analysis resulted in a maximum ground level concentration of 22.69 ug/m3. The (TCEQ) asphalt vapors short term ESL is 350 ug/m3…therefore no furher analysis should be requred.”

April 13, 2007

GAF proposes to replace its Electrostatic Precipitator (dust collector) with two “Coalescing Filter Mist Elimination Systems”

“With this registration, GAF is proposing to install two (2) Coalescing Filter mist Elimination Systems to replace the existing ESP controllign emisions from Line 1 and Line 3 Asphalt Coaters.”

Total emission of PM 10 and VOCs from the proposed coalescing Filter Systems will be similar to the current ESP.”

“Stack test data from a similar filter system on an asphalt coater line at GAF’s Minneapolis plant was used for emissions of PM. Stack testing on the Minneapolis plant did not include VOCs. Therefore, GAF is proposing to show the currently authorized VOC emissions from the ESP will be similar to the VOC emissions from the Coalescing Filter System based on emissions factors developed for AP 42.

“Based on GAF’s experience, the VOC emissions for the proposed pollution control project will be lower than the current VOC permitted emissions.”

What’s a “Coalescing Mist Elimination System?

An Electrostatic Precipitator (ESP) is a dust/PM collector. It’s not supposed to capture Volatile Organic Compounds – even though for much of its history in West Dallas GAF has used theirs as if it were.

An ESP operates by creating electrical charges on large metal plates that attract and collect small particles.

On the other hand, a Coalescing Mist Filter System (CMFS) is a series of fine fiber filters used for controlling aerosol emissions and separating liquid waste from air pollution streams. Exhaust fans send the dry air waste stream out of the factory via vents or stacks. Unlike ESPs, Mist Filter Systems are meant to deal with liquid aerosol droplets like those produced in the Asphalt Coater, so both VOC and PM pollution from the West Dallas factory should decrease with this change.

GAF proposes to replace its single ESP device for two separate Filter Systems – one each for Line 1 and Line 3 .

September 21, 2007

TCEQ grants GAF its VOC Permit Amendment

Based on Stack Tests GAF says its new Filter Mist Elimination System reduces VOC emissions from 54.03 tons per year to 48.82 tons per year – just below the 50-tons -a-year federal regulatory floor for becoming a “major Source for VOC” and requiring more pollution controls measures.


The Agreed Board Order

In 2000 GAF began what it believed would be a routine permit renewal process for NSR permit 7711. By 2008 that permit renewal is still on hold and the renewal process itself has revealed violations at the West Dallas factory that must be resolved before any renewal can occur. Despite the lack of a renewed operating permit, production and pollution totals at the GAF factory have steadily risen.

The Texas Commission on Environmental Quality has cataloged five major violations identified from 2005 to 2008 for which GAF will have to pay a fine and take corrective action. Four involve exceeding their permitted amount of specific kinds of air pollution: Particulate Matter, Sulfur Dioxide, and Nitrogen Oxide. The fifth is a failure to submit stack test results for the Cooling Section of Line 1 by the agreed deadline of April 2005.

These violations are summarized in what’s called an Agreed Board Order. Most of 2008 is spent assembling the langauge of this Board Order. By the fall, it’s getting ready to be finalized.

In the Board Order TCEQ alleges GAF:

Failed to comply with the permitted Maximum Allowable Emissions Rate Table (MAERT) for the Line 3 Cooling Section as determined during stack testing…Specifically..the permited allowable hourly particulate matter (PM) emission rate is 6.00 pounds per hour and during the stack test conducted on May 16th through May 27th, 2005 the actual hourly PM emission rate was 29.84 pounds per hour

“Failed to comply with the permitted MAERT for Thermal Oxidizer stackas detrmined during stack testing… Specifically…the permitted allowable hourly sulfur dioxide (SO2) emission rate is .73 pounds per hour and during the stack test conducted October 30 and 31, 2006, the actual hourly rate for SOX was 38.49 pounds per hour.

“…the permitted allowable hourly oxides of nitrogen (NOx) emission rate is .72 pounds per hour and the actual hourly rate for NOx was 2.15 pounds per hour.…”

“…the permitted allowable carbon monoxide (CO) emission rate is 1.26 pounds per hour and the actua lhourly rate for CO was 22.46 pounds per hour.

Failed to conduct stack testing on Emission Point No. COOL 1…by April 19th, 2005

September 19, 2008

GAF signs-off on Texas Commission on Environmental Quality Agreed Board Order

December 18, 2008

GAF Submits New Amendment for Permit 7711

The new permit amendment addresses the violations in permitted emissions – by raising those permitted emission limits to match the results in previous stack tests.

GAF proposes to raise total limits for Particuate Matter, Sulfur Dioxide, Nitrogen Oxide and Carbon Monoxide pollution. Already three years late, GAF proposes stack testing for Line 1 Cooling Section will be required 180 days after the approval of this permit amendment.

In justifying higher Sulfur Dioxide pollution limits in 2008, GAF argues that its a 1997 federal clean air law that’s to blame:

“Asphalt roofing manufacturers utilize an asphalt waste stream, called Flux, from refineries as a raw input. Emission increases associated with SO2 emission increases are the result of variances in the refinery waste stream. Due to the 1997 Low Sulfur Diesel Fuel requirements, refineries are required to reduce sulfur in fuel. As a result, the extra sulfur is removed from the fuel and moved to the by-product stream. This asphalt by-product stream (called Flux) is a raw material in the asphalt roofing process. The suppliers of this asphalt by-product stream vary based on economics. Since each refinery has a different by-product stream, the constituents of the waste stream vary….GAF is unaware of any asphalt roofing manufacturing sources that include controls for SO2 emissions…GAF believes that Best Available Control Technology for the sources impacted by this permit amendment application is met ”


Sulfur Dioxide Pollution

January 9, 2009

TCEQ Request for Comments – Site Review

“Summary of recent complaints: “On August 9, 2007 the City of Dallas Air Pollution Control Program received a complaint alleging possible harmful emissions were observed coming from GAF after normal business hours. Minimal odors of tar/asphalt were observed coming from the facility. A downwind odor survey was performed and the odor classified as moderate.”

Surrounding Land Use: Industrial/Residential

School within 3000 feet? yes

“Because of the close proximity of schools and residences the nuisance, odor and hazard potential for this facility are all high.”

January 28, 2009

Texas Commission on Environmental Quality (TCEQ) approves GAF’s Agreed Board Order

April 29, 2009

“TCEQ Permit Amendment Source Analysis and Technical Review” of GAF Permit Amendment

GAF revises its Sulfur Dioxide pollution limits: from 9 tons per to 129 tons a year

As a result of the first stack testing at GAF for Sulfur Dioxide pollution, permitted levels of the pollutant are raised 14 times higher than the company’ previous self-reported highest annual total. For the first time since it began operation, GAF’s annual totals are now reflecting a more realistic level of Sulfur Dioxide pollution. That total will make it the single largest Sulfur Dioxide polluter in Dallas County.

What is Sulfur Dioxide?

Sulfur dioxide is a colorless gas with a pungent odor. The largest source of SO2 in the atmosphere is the burning of fossil fuels by power plants and other industrial facilities.    

Sulfur Dioxide can be hazardous in high concentrations but long-term exposure to low concentrations is also problematic. Short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. People with asthma, particularly children, are sensitive to these effects of SO2. A 2011 study concluded that exposure to sulfur dioxide was associated with premature births.

SO2 emissions that lead to high concentrations of SO2 in the air generally also lead to the formation of other sulfur oxides (SOx). SOx can react with other compounds in the atmosphere to form small particles. These particles contribute to particulate matter (PM) pollution. Small particles may penetrate deeply into the lungs and in sufficient quantity can contribute to health problems.

At high concentrations, gaseous SOx can harm trees and plants by damaging foliage and decreasing growth. SO2 and other sulfur oxides can contribute to acid rain which can harm sensitive ecosystems. 


May 2009

GAF State Air Dispersion Modeling Analysis

GAF submits its consultant’s computer air modeling to TCEQ to prove it will comply with the new larger pollution limits it just wrote for itself in the new permit amendment.

The analysis “considers the emissions associated only with the proposed project to determine whether it will have a significant impact upon the surrounding area.” In other words this computer air modeling will not include ALL of GAF’s pollution, just the pollution authorized by the new permit.

Instead of monitoring what actual background concentrations of pollution are in West Dallas GAF uses monitoring data from an EPA monitor four miles away near I-35 and Mockingbird. This is important because the higher the existing background levels of pollution, the lower the pollution levels from GAF must be to avoid trigger violations of federal air standards.

West Dallas had already been in violation of federal PM standards and hosted many polluting industries. The EPA monitor five miles away was located primarily to track smog and wasn’t near any industry.

Even with these favorable circumstances, GAF’s own consultant’s found that the West Dallas factory would still just barely comply with Particulate Matter and Sulfur Dioxide federal air standards:

“The proposed project will not cause or contribute to a violation of any applicable National Ambient Air Quality Standards or state property line standard or cause or contribute to adverse impacts on human health or the environment.”