A Fundamentally Altered GAF

West Dallas is at Risk of a Catastrophic Explosion

GAF is Not the Same Factory it was in 1987

GAF’s self-reported emissions when it became a non-confroming use in the mid- 1980’s are qualitatively and quantitatively different from GAF emissions in 2022. Its total air pollution releases are almost four times larger and include more toxins.

GAF has gone from being a minor source of Sulfur Dioxide air pollution in Dallas County to becoming the largest Sulfur Dioxide polluter in Dallas County (Source: Texas Commission on Environmental Quality 2020 Emission Inventory). It has also become a Major Source for Particulate Matter (PM), ranking as the 2nd largest industrial PM polluter in Dallas County (Ibid.). During this same period, GAF began reporting the releases of specific Hazardous Air Pollutants, including Polycyclic Aromatic Compounds, Benzo(g,h,i)perylene, and Lead (Source: Environmental Protection Agency, Form Rs – 2010-2020).

Going hand-in-hand with this enormous increase in emissions is an associated increase in public health risks and environmental hazards. In 2022 GAF poses a far greater risk to far more West Dallas residents than it did in 1987.

In making substantial changes to both the volume and chemical composition of its air pollution releases over the years, GAF has increased by nearly 4 times the adverse pollution effect on nearby properties today from the adverse effect that already existed in 1985.

GAF’s Normal Operations are Inherently Incompatible with the Surrounding Neighborhood

The Main Ingredient for GAF’s Shingle Product is Oil Refinery Waste

All asphalt shingle factories use the same basic ingredients to produce their products. The main ingredient of the asphalt itself is the hazardous waste from oil refineries called “Flux.” Every asphalt shingle GAF produces in West Dallas contains a coating of Flux.

Material Safety Data Sheets for Asphalt Flux submitted by GAF to the State of Texas note that the waste is “listed in the Toxic Substances Control Act (TSCA) inventory of Chemicals in Commerce.” They list Flux as an “Acute Health Hazard, Chronic Health Hazard, Known Animal Carcinogen, Known Animal Mutagen, Known Animal Tumorigen, Known Human Irritant,” and “Known Human Target Organ Toxin (eyes, respiratory tract irritation).” Some of the public health concerns include in the safety sheet are detailed below.

“Fumes from hot asphalt may cause nausea, headache, dizziness, and irritation to the respiratory tract.”

“During storage or transit of hot asphalt, hydrogen sulfide may accumulate in enclosed spaces such as tank cars and tank trucks. Open tank car and tank truck hatches with caution. Avoid inhalation.”

Because it is oil refinery waste, Flux contains a long list of petrochemical compounds in various concentrations. Flux must be constantly heated or it will become a sludge. But when it is heated, it releases more petrochemical compounds and produces more pollution.

GAF’s West Dallas factory is solely in business to receive this Flux waste in heated railcars, store and process it in heated tanks, use heated pipelines to coat its own shingles, and export it off-site in heated railcars to other GAF factories so they can coat their shingles with it. Everything GAF does at its factory in West Dallas depends on the constantly heated transportation, handling, and processing of dangerous oil refinery waste.

Next: Character of the Neighborhood