north-san-gabriel-alliance

How To Protect Yourself During the Next Chemical Emergency

cris@brightsocialagency.com (Cris Haest) — Fri, 28 Jul 2023 19:18:19 GMT

Texas has already seen 25 chemical emergencies this year. Here’s how to protect yourself during the next one.

BY ALEJANDRA MARTINEZ AND ERIN DOUGLAS JULY 26, 2023 5 AM CENTRAL

The Liberty Hill Independent Recent News Coverage: TCEQ grants contested case hearing for Exfluor permit

cris@brightsocialagency.com (Cris Haest) — Fri, 10 Feb 2023 15:32:43 GMT

"Round Rock-based chemical plant Exfluor Research Corporation has hit a hurdle on its way to construct a new facility in northern Williamson County."

From the article:

"Patricia Mulvihill, president of the North San Gabriel Alliance, said the Alliance and the community have succeeded in delaying Exfluor’s construction since April 2022. Alliance members are hopeful the upcoming hearings will continue to delay construction until at least December. Mulvihill added that her organization was thrilled when they learned the contested case hearing had been granted.

“This was the end game—to get in front of a judge and get this permitting process shut down,” she said. “We are just pushing back as hard as we can push back. Exfluor needs to be in an industrial zone location where their products can be properly regulated. We will continue to fight against the chemical plant’s relocation until the end. We are not going away.”"

Click the image above to read the full article on The Liberty Hill Independent's page here !

The Exfluor Case

cris@brightsocialagency.com (Cris Haest) — Fri, 23 Dec 2022 23:44:40 GMT

December 23rd, 2022

Click Here for video of the 12-14-2022 TCEQ Commissioners Meeting, and details of their unanimous decision on Youtube.

Click here to see the TCEQ Interim Order dated 12-22-2022.

We again send our profound THANKS to everyone for fighting Exfluor's proposed perfluorocarbon manufacturing plant.

Remember what we are fighting for. The land around 1100 County Road 236 could become a chemical industrial sacrifice zone.

NSGA and the community have succeeded in delaying Exfluor's construction since April 12, 2022. It is probable that the upcoming case hearings will delay Exfluor's construction until December 2023.

While we wish Exfluor would take the hint, withdraw their permit application and move to an appropriate industrial location, it appears from their TCEQ filings that that they will not.

Now we see the true intent of Exfluor. Far from being a good neighbor, their intent is to win at all costs, smash this perfluorocarbon manufacturing plant into our pristine, environmentally fragile, rural, residential neighborhood, even if it means stooping to such trivial levels as challenging the land ownership of our residents, relying on extremely narrow aspects of the air quality permit, pretending that the potential pollution will not travel more than 1/8 mile, while completely disregarding the extreme hazards to the environment, people, animals, crops and livelihood of our community, and the greater downstream watershed of the North Fork of the San Gabriel River.

We are grateful for the broad support from the North San Gabriel Community! We received more than 290 entries on the TCEQ site, opposing the proposed Exfluor specialty chemical manufacturing facility on County Road 236. Our petition received more than 3,300 signatures. We received front page coverage from 3 newspapers, and multiple TV spots. Click here for a brief summary of this effort.

We are succeeding. NSGA asks for your financial support. Lawyers, environmental consultants, website updates and maintenance are expensive. As a Texas non-profit 501(c)(4) organization, all donations are used to support the Purpose of NSGA. We are 100% volunteer managed with no compensation.

Please click here to DONATE NOW.

We will keep you informed regarding this case. Read more here.

September 13th, 2022

Following the conclusion of the June 16, 2022 Texas Commission on Environmental Quality (TCEQ) public meeting held at Florence High School, TCEQ staff started work on preparing the Response to Comments.

The Response to Comments was released by the TCEQ on September 13. Click here to see the Response to Comments.

The deadline for an affected person to request a reconsideration, or a contested case hearing, is October 13, 2022.

NORTH SAN GABRIEL ALLIANCE will review the Response to Comments. We await the TCEQ decision regarding our request for a Contested Case Hearing.

We are grateful for the broad support from the North San Gabriel Community! We received more than 290 entries on the TCEQ site, opposing the proposed Exfluor specialty chemical manufacturing facility on County Road 236. Our petition received more than 3,300 signatures. We received front page coverage from 3 newspapers, and multiple TV spots. Click here for a brief summary of this effort.

We will keep you informed regarding this case. Read more here.

EXFLUOR states: "The proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants, nitrogen oxides and organic compounds."

Facts About Hydrogen Fluoride (Hydrofluoric Acid) - Centers of Disease Control and Prevention

Hydrogen fluoride goes easily and quickly through the skin and into the tissues in the body. There it damages the cells and causes them to not work properly.
The seriousness of poisoning caused by hydrogen fluoride depends on the amount, route, and length of time of exposure, as well as the age and preexisting medical condition of the person exposed.
Breathing hydrogen fluoride can damage lung tissue and cause swelling and fluid accumulation in the lungs (pulmonary edema).
Skin contact with hydrogen fluoride may cause severe burns that develop after several hours and form skin ulcers.

Immediate signs and symptoms of exposure to hydrogen fluoride

SOURCE: CDC Advisory

ISSUE: Exfluor Research Corporation is one Texas Commission on Environmental Quality (TCEQ) Air Quality Permit approval away from construction.

Click here to see all of Exfluor's Permit Statuses

Exfluor Research Corporation uses fluorine gas to convert hydrocarbons to fluorocarbons.

In the Notice for this proposed facility Exfluor states : “The proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants, nitrogen oxides and organic compounds.”

The manufacturing process is dangerous and has produced documented leaks at other facilities. Many of these manufactured fluorocarbon compounds are referred to as “forever chemicals” because they do not degrade in nature.

JUNE 15, 2022. “Agency officials assessed two of the most common ones, known as PFOA and PFOS, in recent human health studies and announced Wednesday that lifetime exposure at staggeringly low levels of 0.004 and 0.02 parts per trillion, respectively, can compromise the immune and cardiovascular systems and are linked to decreased birth weights.”

EPA'S LIFETIME HEALTH ADVISORIES ALSO TAKE INTO ACCOUNT OTHER POTENTIAL SOURCES OF EXPOSURE TO THESE PFAS BEYOND DRINKING WATER (FOR EXAMPLE, FOOD, *AIR* , CONSUMER PRODUCTS, ETC.), WHICH PROVIDES AN ADDITIONAL LAYER OF PROTECTION.

In June 2017, the discharge of GenX and other PFAS directly into the Cape Fear River by a Chemours chemical plant became public knowledge when the Wilmington Star News broke the story of the widespread contamination. Wells miles away —upriver but downwind — had also been contaminated when PFAS emitted into the air fell back to earth in rainwater.

Substantial cattle ranches are nearby. Commercial beekeepers operate within one-quarter mile of this site.

The North Fork of the San Gabriel River runs through the area, and downstream to Lake Georgetown and Lake Granger, then into the Brazos River and on to the Gulf of Mexico.

The City of Georgetown and the City of Round Rock obtain drinking water from Lake Georgetown.

AIR POLLUTION BECOMES WATER AND FOOD POLLUTION

While drinking water is believed to be the highest risk for exposure, PFAS can be found in some foods and in the environment, so Public Health encourages residents to take steps to reduce exposure to PFOA and PFOS compounds as much as possible. Some examples may include:

If you live near known sources of PFAS contamination or your drinking water contains PFAS above the EPA health advisory levels, you may want to use a different water source or filter your water before drinking, cooking, and preparing infant formula.

Learn more about private testing and filtration options. Boiling water does not remove PFAS.

Reduce your use of products containing PFAS (packaged foods, products with non-stick or stain resistant coatings, and some personal care products). If you have questions about the products you use in your home, contact the Consumer Product Safety Commission at (800) 638-2772.

Additional actionable steps can be found at epa.gov.

Toxic chemical pollution from Exfluor Research Corporation could permanently affect people, homes, land, and agriculture

nearby, as well as downstream in the river drainages.

More than 3,300 people have signed a petition against this Exfluor facility.

TCEQ has received more than 290 comments against this Exfluor facility.

PUBLICITY. Opposition to the proposed Exfluor plant has received front-page coverage from three newspapers, along with coverage in several TV news segments.

The TV news segments have video footage from the Exfluor 2014 toxic gas leak. Click here to read about other known Exfluor Leaks .

Letters from Elected Officials

Fire is a serious threat to rural structures.

The Exfluor site on County Road 236 would contain explosive chemicals. A fire could be catastrophic, and the toxic plume could extend for miles.

July 26, 2022

San Gabriel Wildfire east of Liberty Hill in Williamson County burned 451 acres.

While the room was filled with neighbors, most of them against the facility, only a relative handful made their opinions known. However, some of those opinions came with roaring applause.

"I just have to wonder why, why would you go through all that trouble? Why would you not build in an industrial park?"

The crowd applauded loudly before Exfluor executives could answer.

"It felt like the responsible thing to do, because of the business that we're in, is to locate ourselves in an area where there's a buffer between us and population centers," Kevin Bierschenk, the Head of Production for Exfluor, said.

Most of the crowd laughed or booed in response.

“Continue to defend this community.”

AIR QUALITY . These chemicals are serious and forever. They can escape into the air and then fall back to earth in rainwater, affecting drinking water, the local environment, and agriculture. Any gas discharge could easily

impact the nearby family homes. Wildfires are common in the area. Plumes from a chemical fire or explosion could travel very long distances.

COUNTY ROAD 236 IS NOT A SPECIALTY CHEMICAL MANUFACTURING AREA . Exfluor’s chemical manufacturing should take place in an industrial park served by adequate power, natural gas, water supplies, sewer, roadways, law enforcement, and emergency responders.

POWER OUTAGES ARE COMMON . While Exfluor may be planning on backup diesel-powered generators, what happens when water wells are not functioning? What happens to critical manufacturing and chemical waste filtration systems when power fluctuates?

POTENTIAL FOR A CHEMICAL AND INDUSTRIAL SUPER SITE . Exfluor’s 48-acre site has enough land for other chemical companies and suppliers to build additional facilities, possibly creating a chemical and industrial super site. The anticipated number of passenger vehicles, delivery trucks, and tanker trucks which could pour into this area could generate congestion, vehicle accidents, and increased calls to the Sheriff's Department, in addition to increased risk of chemical spills, fires and explosions.

“Continue to defend this community.”

✓ ANY SPILLS AT THE EXFLUOR FACILITY COULD WASH INTO THE WATERSHED OF THE NORTH FORK OF THE SAN GABRIEL RIVER.

✓ STOP THIS CHEMICAL MANUFACTURER FROM FORCING ITS WAY INTO A RESIDENTIAL AND AGRICULTURAL AREA, AFFECTING THE HEALTH AND LIVELIHOOD OF THE FAMILIES WHO LIVE HERE.

✓ TAKE ACTION. REMAIN INVOLVED. IF YOU DO NOT, IMAGINE A CHEMICAL INDUSTRIAL SUPER SITE IN OUR COMMUNITY.

NSGA Granted a Contested Case Hearing by the TCEQ!

cris@brightsocialagency.com (Cris Haest) — Fri, 23 Dec 2022 19:36:31 GMT

December 23rd, 2022

NSGA and 9 individuals, with combined 10 issues, were granted a Contested Case Hearing by the TCEQ Commissioners on December 14, 2022. We are now waiting to receive the date for the preliminary hearing.

Click Here for video of the 12-14-2022 TCEQ Commissioners Meeting, and details of their unanimous decision on youtube or click the video below.

Click here to see the TCEQ Interim Order dated 12-22-2022

We again send our profound THANKS to everyone for fighting Exfluor's proposed perfluorocarbon manufacturing plant.

Remember what we are fighting for. The land around 1100 County Road 236 could become a chemical industrial sacrifice zone.

NSGA and the community have succeeded in delaying Exfluor's construction since April 12, 2022. It is probable that the upcoming case hearings will delay Exfluor's construction until December 2023.

While we wish Exfluor would take the hint, withdraw their permit application and move to an appropriate industrial location, it appears from their TCEQ filings that that they will not.

Now we see the true intent of Exfluor. Far from being a good neighbor, their intent is to win at all costs, smash this perfluorocarbon manufacturing plant into our pristine, environmentally fragile, rural, residential neighborhood, even if it means stooping to such trivial levels as challenging the land ownership of our residents, relying on extremely narrow aspects of the air quality permit, pretending that the potential pollution will not travel more than 1/8 mile, while completely disregarding the extreme hazards to the environment, people, animals, crops and livelihood of our community, and the greater downstream watershed of the North Fork of the San Gabriel River.

We are grateful for the broad support from the North San Gabriel Community! We received more than 290 entries on the TCEQ site, opposing the proposed Exfluor specialty chemical manufacturing facility on County Road 236. Our petition received more than 3,300 signatures. We received front page coverage from 3 newspapers, and multiple TV spots. Click here for a brief summary of this effort.

We are succeeding. NSGA asks for your financial support. Lawyers, environmental consultants, website updates and maintenance are expensive. As a Texas non-profit 501(c)(4) organization, all donations are used to support the Purpose of NSGA. We are 100% volunteer managed with no compensation.

Please click here to DONATE NOW!

We will keep you informed regarding this case.

Submitting a Request for a Contested Case Hearing on Exfluor Research Corp’s Application for a New Air Permit No. 165848

cris@brightsocialagency.com (Cris Haest) — Tue, 11 Oct 2022 21:41:44 GMT

Submit your hearing request by 5:00 PM on October 13.

The easiest method is to submit your request online: https://www14.tceq.texas.gov/epic/eComment/

First, enter Exfluor’s draft permit number 165848. Then, after providing your contact information, you’ll be able to

upload one Word or PDF document.

You can also mail your comments, but you’ll want to mail them in ASAP, because they must be received by TCEQ

by October 13 to be considered. Mail to:

Laurie Gharis, Chief Clerk

TCEQ, MC-105

P.O. Box 13087

Austin, Texas 78711-3087

The following template provides the minimum information you should include in your request. You may use this

template as a guide, but you must fill in the personal information. Provide as much detail as you can about the

location of your property relative to the Exlfuor site, how you use your property, and how you feel your use

would or could be impaired by the Exfluor operation, if the permit were granted.

Re: Urgent health and environmental concerns over PFAS and HF chemicals North San Gabriel Alliance for public release

cris@brightsocialagency.com (Cris Haest) — Tue, 11 Oct 2022 21:34:50 GMT

Read the full six page letter by clicking the image below

Fluorine-carbon bonds in PFAS are very tough chemical bonds to destroy and I am concerned that Exfluor may emit unburned PFAS compounds along with Hydrogen Fluoride (HF) which is an extremely toxic substance by itself. It appears that HF will not be continuously monitored (Exfluor could install HF CEMS) and, in my opinion, the only truly safe level is zero. HF emissions could impact local vegetation, animals, and more leaving trace residues.

In my view, Exfluor’s new plant should not be built due to the risk of Thermal Oxidizers failing to destroy the fluorine-carbon bonds, and HF and other toxic chemicals escaping and turning the surrounding community into a chemical industry sacrifice zone. I would encourage Exfluor to either expand its current Round Rock plant or look for another site in an industrial park.

Neil Carman, PhD
Clean Air Program Director and former TCEQ field investigator
Lone Star Chapter Sierra Club
6406 N IH-35, suite 1806
Austin, Tx 78765

Exfluor: TCEQ Response to Comments is Out

cris@brightsocialagency.com (Cris Haest) — Thu, 15 Sep 2022 14:42:40 GMT

The Executive Director has made the Response to Public Comment (RTC) for the application by Exfluor Research Corporation for NSR Permit No. 165848 available for viewing on the Internet. You may view and print the document by visiting the TCEQ Commissioners’ Integrated Database at the following link:
https://www.tceq.texas.gov/goto/cid

Decision of the Executive Director.

The executive director has made a decision that the above-referenced permit application meets the requirements of applicable law. This decision does not authorize construction or operation of any proposed facilities. This decision will be considered by the commissioners at a regularly scheduled public meeting before any action is taken on this application unless all requests for contested case hearing or reconsideration have been withdrawn before that meeting.

Enclosed with this letter is a copy of the Executive Director’s Response to Comments. A copy of the complete application, draft permit and related documents, including public comments, are available for review at the TCEQ Central Office. A copy of the complete application, the draft permit, and executive director’s preliminary decision are available for viewing and copying at the Eula Hunt Beck Florence Public Library, 207 East Main Street, Williamson County, Texas.

If you disagree with the executive director’s decision, and you believe you are an “affected person” as defined below, you may request a contested case hearing. In addition, anyone may request reconsideration of the executive director’s decision. The

procedures for the commission’s evaluation of hearing requests/requests for reconsideration are located in 30 Texas Administrative Code Chapter 55, Subchapter F.

A brief description of the procedures for these two types of requests follows.

How to Request a Contested Case Hearing.

It is important that your request include all the information that supports your right to a contested case hearing. You must demonstrate that you meet the applicable legal requirements to have your hearing request granted. The commission’s consideration of your request will be based on the information you provide.

The request must include the following:

Your name, address, daytime telephone number, and, if possible, a fax number.
If the request is made by a group or association, the request must identify:
one person by name, address, daytime telephone number, and, if possible, the fax number, of the person who will be responsible for receiving all communications and documents for the group;
the comments on the application submitted by the group that are the basis of the hearing request; and
by name and physical address one or more members of the group that would otherwise have standing to request a hearing in their own right. The interests the group seeks to protect must relate to the organization’s purpose. Neither the claim asserted nor the relief requested must require the participation of the individual members in the case.
The name of the applicant, the permit number and other numbers listed above so that your request may be processed properly.
A statement clearly expressing that you are requesting a contested case hearing. For example, the following statement would be sufficient: “I request a contested case hearing.”

Your request must demonstrate that you are an “affected person.” An affected person is one who has a personal justiciable interest related to a legal right, duty, privilege, power, or economic interest affected by the application. Your request must

describe how and why you would be adversely affected by the proposed facility or activity in a manner not common to the general public. For example, to the extent your request is based on these concerns, you should describe the likely impact on your health, safety, or uses of your property which may be adversely affected by the proposed facility or activities. To demonstrate that you have a personal justiciable interest, you must state, as specifically as you are able, your location and the distance between your location and the proposed facility or activities. A person who may be affected by emissions of air contaminants from the facility is entitled to request a contested case hearing.

Your request must raise disputed issues of fact that are relevant and material to the commission’s decision on this application that were raised by you during the public comment period. The request cannot be based solely on issues raised in comments that

you have withdrawn.

To facilitate the commission’s determination of the number and scope of issues to be referred to hearing, you should: 1) specify any of the executive director’s responses to your comments that you dispute; 2) the factual basis of the dispute; and 3) list any

disputed issues of law.

How to Request Reconsideration of the Executive Director’s Decision.

Unlike a request for a contested case hearing, anyone may request reconsideration of the executive director’s decision. A request for reconsideration should contain your name, address, daytime phone number, and, if possible, your fax number. The request must state that you are requesting reconsideration of the executive director’s decision, and must explain why you believe the decision should be reconsidered.

Deadline for Submitting Requests.

A request for a contested case hearing or reconsideration of the executive director’s decision must be received by the Chief Clerk’s office no later than 30 calendar days after the date of this letter. You may submit your request electronically at www.tceq.texas.gov/agency/decisions/cc/comments.html or by mail to the following address:

Laurie Gharis, Chief Clerk

TCEQ, MC-105

P.O. Box 13087

Austin, Texas 78711-3087

Processing of Requests.

Timely requests for a contested case hearing or for reconsideration of the executive director’s decision will be referred to the TCEQ’s Alternative Dispute Resolution Program and set on the agenda of one of the commission’s regularly scheduled

meetings. Additional instructions explaining these procedures will be sent to the attached mailing list when this meeting has been scheduled.

How to Obtain Additional Information.

If you have any questions or need additional information about the procedures described in this letter, please call the Public Participation and Education Program, toll free, at 1-800-687-4040 .

Click here to view the full EXECUTIVE DIRECTOR’S RESPONSE TO PUBLIC COMMENT

Update Regarding Exfluor

cris@brightsocialagency.com (Cris Haest) — Tue, 13 Sep 2022 18:29:21 GMT

September 13th, 2022

Following the conclusion of the June 16, 2022 Texas Commission on Environmental Quality (TCEQ) public meeting held at Florence High School, TCEQ staff started work on preparing Responses to Comments.

Responses to Comments have not been sent out by the TCEQ as of September 13. Click here to see the status of Air Permit 165848.

NORTH SAN GABRIEL ALLIANCE will review the Comments. We await the TCEQ decision regarding our request for a Contested Case Hearing.

We are grateful for the broad support from the North San Gabriel Community! We received more than 290 entries on the TCEQ site, opposing the proposed Exfluor specialty chemical manufacturing facility on County Road 236. Our petition received more than 3,300 signatures. We received front page coverage from 3 newspapers, and multiple TV spots. Click here for a brief summary of this effort.

We will keep you informed regarding this case.

How to: Register for a Texas Legislature Online Account

cris@brightsocialagency.com (Cris Haest) — Tue, 13 Sep 2022 18:25:50 GMT

Be aware of all of the upcoming environmental bills for the 2023 Legislature Session: Set up your Texas Legislature Online Account Now

Click on New User? and create your account with your personal information. Once your account is registered, then select the committees you are interested in, for the Texas House and Texas Senate, such as:

Environmental Regulation House
Natural Resources House
Natural Resources & Economic Development Senate
Water, Agriculture & Rural Affairs Senate

Killeen Daily Herald's Recent News Coverage: Furious in Florence: Residents voice their outrage over proposed chem plant

Fri, 17 Jun 2022 20:00:29 GMT

“I live right on the corner near the plant,” said Elizabeth Williams, who is a member of the North San Gabriel Alliance, during the informal question-and-answer period of the meeting. “My family has been there for seven generations, so we’re pretty scared.”

KVUE'S RECENT NEWS COVERAGE: Neighbors frustrated with answers after questioning permit for new chemical facility in rural Williamson County

Fri, 17 Jun 2022 19:47:33 GMT

Exfluor Research Corporation needs an air quality permit to build its new facility in the Florence area. The public voiced their concerns if the facility leaks.

A top EPA official announced new, more stringent health advisories for four PFAS chemicals

Wed, 15 Jun 2022 19:43:53 GMT

Exfluor Research Corporation lists perfluorooctanoic acid as a product on line 10 of the attached product information page downloaded from http://www.exfluor.com/bycategory.php?cat=acids . This compound is identified in the June 15, 2022 EPA health advisories .

We do not want a known toxic leaker that is also known for failing to comply with permit conditions building a speciality chemical manufacturing facility in a residential area!

https://www.northsangabrielalliance.org/perfluorooctanoic-acid-a-toxic-exfluor-product

"EPA'S LIFETIME HEALTH ADVISORIES ALSO TAKE INTO ACCOUNT OTHER POTENTIAL SOURCES OF EXPOSURE TO THESE PFAS BEYOND DRINKING WATER (FOR EXAMPLE, FOOD, AIR , CONSUMER PRODUCTS, ETC.)." - JUNE 15th EPA ANNOUNCEMENT

"Today, the U.S. Environmental Protection Agency (EPA) released four drinking water health advisories for per- and polyfluoroalkyl substances (PFAS) in the latest action under President Biden's action plan to deliver clean water and Administrator Regan's PFAS Strategic Roadmap. EPA also announced that it is inviting states and territories to apply for $1 billion - the first of $5 billion in Bipartisan Infrastructure Law grant funding - to address PFAS and other emerging contaminants in drinking water, specifically in small or disadvantaged communities. These actions build on EPA's progress to safeguard communities from PFAS pollution and scientifically inform upcoming efforts, including EPA's forthcoming proposed National Primary Drinking Water Regulation for PFOA and PFOS, which EPA will release in the fall of 2022. EPA is issuing interim, updated drinking water health advisories for perfluorooctanoic acid (PFOA) and perfluorooctane sulfonic acid (PFOS) that replace those EPA issued in 2016. The updated advisory levels, which are based on new science and consider lifetime exposure, indicate that some negative health effects may occur with concentrations of PFOA or PFOS in water that are near zero and below EPA's ability to detect at this time. The lower the level of PFOA and PFOS, the lower the risk to public health. EPA recommends states, Tribes, territories, and drinking water utilities that detect PFOA and PFOS take steps to reduce exposure. Most uses of PFOA and PFOS were voluntarily phased out by U.S. manufacturers, although there are a limited number of ongoing uses, and these chemicals remain in the environment due to their lack of degradation. For the first time, EPA is issuing final health advisories for perfluorobutane sulfonic acid and its potassium salt (PFBS) and for hexafluoropropylene oxide (HFPO) dimer acid and its ammonium salt ("GenX" chemicals). In chemical and product manufacturing, GenX chemicals are considered a replacement for PFOA, and PFBS is considered a replacement for PFOS. The GenX chemicals and PFBS health advisory levels are well above the level of detection, based on risk analyses in recent scientific studies. The agency's new health advisories provide technical information that federal, state, and local agencies can use to inform actions to address PFAS in drinking water, including water quality monitoring, optimization of existing technologies that reduce PFAS, and strategies to reduce exposure to these substances. EPA'S LIFETIME HEALTH ADVISORIES ALSO TAKE INTO ACCOUNT OTHER POTENTIAL SOURCES OF EXPOSURE TO THESE PFAS BEYOND DRINKING WATER (FOR EXAMPLE, FOOD, * AIR *, CONSUMER PRODUCTS, ETC.), WHICH PROVIDES AN ADDITIONAL LAYER OF PROTECTION." READ THE FULL ANNOUNCEMENT ON EPA's WEBSITE HERE

“Agency officials assessed two of the most common ones, known as PFOA and PFOS, in recent human health studies and announced Wednesday that lifetime exposure at staggeringly low levels of 0.004 and 0.02 parts per trillion, respectively, can compromise the immune and cardiovascular systems and are linked to decreased birth weights.” - The Washington Post

RECENT NEWS COVERAGE: KILLEEN DAILY HERALD ‘We’ve been stewards of this land for over 150 years’: Florence family not happy about proposed chem plant

Fri, 10 Jun 2022 21:12:02 GMT

CLICK BELOW TO READ THE FULL ARTICLE IN THE KILLEEN DAILY HERALD ‘We’ve been stewards of this land for over 150 years’: Florence family not happy about proposed chem plant

"The roots of the environmental nonprofit North San Gabriel Alliance , which is fighting a proposed chemical manufacturing plant near Florence, run deep into one local family’s history. The McCormick family’s Williamson County ranch, which has been passed down for generations since 1852, could be forever altered if Exfluor Research Corporation becomes their new neighbor."

READ THE REST OF THE ARTICLE HERE.

Killeen Daily Herald News Coverage: Public meeting set for Exfluor chem plant proposed near Florence

Sun, 22 May 2022 16:21:17 GMT

Read the full article by Emily Hilley-Sierzchula on the Killeen Daily Herald site

Public Meeting is to be held: Thursday, June 16 at 7:00 PM Florence High School (Cafeteria) 401 FM 970 Florence, Texas 76527

Thu, 19 May 2022 16:33:33 GMT

The TCEQ Official Public Meeting is to be held on Thursday, June 16 at 7:00 PM in the Florence High School Cafeteria . We hope to see you there! RSVP VIA FACEBOOK HERE

PUBLIC COMMENT/PUBLIC MEETING

You may submit public comments to the Office of the Chief Clerk at the address below. The TCEQ will consider all public comments in developing a final decision on the application. A public meeting will be held and will consist of two parts, an Informal Discussion Period and a Formal Comment Period. A public meeting is not a contested case hearing under the Administrative Procedure Act. During the Informal Discussion Period, the public will be encouraged to ask questions of the applicant and TCEQ staff concerning the permit application. The comments and questions submitted orally during the Informal Discussion Period will not be considered before a decision is reached on the permit application, and no formal response will be made. Responses will be provided orally during the Informal Discussion Period. During the Formal Comment Period on the permit application, members of the public may state their formal comments orally into the official record. At the conclusion of the comment period, all formal comments will be considered before a decision is reached on the permit application. A written response to all formal comments will be prepared by the executive director and will be sent to each person who submits a formal comment or who requested to be on the mailing list for this permit application and provides a mailing address. Only relevant and material issues raised during the Formal Comment Period can be considered if a contested case hearing is granted on this permit application.

INFORMATION

Members of the public are encouraged to submit written comments anytime during the public meeting electronically at https://www14.tceq.texas.gov/epic/eComment/ or by mail before the close of the public comment period to the:

Office of the Chief Clerk, TCEQ,

Mail Code MC-105,

P.O. Box 13087,

Austin, Texas 78711-3087

�� NSGA MEMBER ACTION ITEMS

Submit your comments and questions to the TCEQ! Comments should be "Relevant and material issues" regarding air quality permit 165848. Need a tutorial on how to submit your comment for Exfluor's proposed air permit? Click here!
Join the NSGA Facebook Group here and watch for the Facebook event to RSVP for the Public Meeting to mark your calendars!
Stay informed! Sign up for emails straight from NORTH SAN GABRIEL ALLIANCE HERE!
CLICK HERE TO DONATE TO NORTH SAN GABRIEL ALLIANCE

TCEQ Comment & Public Meeting Request Highlights

Mon, 16 May 2022 14:45:45 GMT

We've Reviewed the Publicly Available TCEQ Database & Hand-Selected Neighbor Complaints Below Highlighting The Growing Concern About Forever Chemicals Being Manufactured in our Rural/Residential Area

"My name is Shannon White-Shubert. My husband, Mike, and I own a 12-acre lot on County Road 236 in Florence. We are actually less than 1,100 feet to the west and downhill from Exfluor's property. In addition to the ethical issues of building a "specialty chemical manufacturing facility" in a rural residential/farming community, we strongly believe that there are critical health and environmental concerns associated with the location of Exfluor's proposed "specialty chemical manufacturing facility."

Mike and I have done a substantial amount of work on our property mainly removing the cedars and trimming the oaks. Our boys (23YO and 21YO) are both in college so we worked there practically every weekend for the last two years until just recently. I am not exaggerating. We average about 40 weekends a year at our property. The Google map of our property has changed considerably in the last two years. First, we bought new Stil Chainsaws including a pole chainsaw, then a Kubota tractor and a few implements including a wood chipper. We chip as much cedar as we can and we burn the stumps and larger branches. Our lot is heavily treed with a lot of live growth and it also has large piles of decaying cedar branches, dead trees cut many years ago, and of course, unfortunately, snakes. Our property is a huge forest with a canopy of large Texas red oak trees and live oak trees, and a beautiful understory of Texas native trees including Mexican Buckeye, Mexican Redbud, Eve's Necklace, Rusty Blackhaw, Desert Olive, Fragrant Sumac, Catclaw Acacia, Yucca and various flowering plants. We are visited often by deer, hogs, wild turkeys, brown skinks and other wildlife. Rumor has it that bald eagles live nearby but we haven't seen them yet. We have 9 thriving beehives which were established on 04/18/2020 and are now known as The Happy Bee Company. The property is gorgeous and someday hopefully, all 12 acres will look like a park with walking/bike trails. This is our dream of where we want to grow old together with our family.

Due to the Coronavirus our plans to build our forever home were temporarily delayed in 2020 and 2021. During this time, we rented a rock saw and dug a trench for underground electricity for over 800 feet. We laid the conduit with the help of our new friends on lot #4. We had a well dug and we had a water pump set up. We built our first structure in 2021 - a 20X25 carport (built on road base) for the tractor and its implements. In 2021 we meet with several builders who could not commit to building our house due to rising building costs and scarcity of building products. At the beginning of 2022 we reached out again to a local builder to plan our forever home. We started sketching plans and meeting with builder for 3 weeks in a row at our land. We measured and moved the garage around in three different areas so that we would not have to remove a treasured oak tree.

We recently had 3 concrete foundations poured on 03/25/2022. The 25x25 concrete foundation is for a well house to include the water pump and a large tank. The smaller 15x25 concrete foundation is for a commercial greenhouse. The larger 50x60 concrete foundation was poured for a metal building/workshop and there is an additional 650 square feet for covered patios on this structure. These projects have also been delayed recently due to several tornadoes in the Round Rock area and in the Florence/Salado area. We also ordered 3 park benches for the walking/biking trail around the property. Everything in our little world was going great… and then the worst thing ever happened! On April 8, 2022 we received a certified letter from the North San Gabriel Alliance. www.northsangabrielalliance.org informing us of Exfluor's plans to build a 'specialty chemical manufacturing facility" less than 1,100 from our property. We had no idea this was happening.

And now we don't know what to do. We certainly don't want to build our forever home by a "specialty chemical manufacturing facility." We are health conscious individuals who planned to move to CR236 for an even healthier lifestyle with bees, organic herb and vegetable garden, berries and fruit trees, chickens and maybe peacocks. Again, this is our dream. This is what we have been working for.

These are the facts as I know them:

The property Mike & I purchased was part of a 224.71-acre tract that was being held in a charitable trust for Richard A. Box, Trustee of Box Place Charitable Remainder Unitrust. This trust was set up in "Consideration: Love of, and appreciation for Texas A&M University, its purposes, its students and its importance to the Grantor." The trust was formed 03/14/2019 (Williamson County document number 2019021158).

On a side note: Dr. Richard Box is salt of the Earth. This donation is a small part of the legacy of a great man. https://www.txamfoundation.com/News/Never-Stop-Learning.aspx I firmly believe that the Texas A&M Foundation should investigate how County Road 236 Investments, LLC handled these property transactions. In addition to the ethical issues of actually permitting an industrial company to build a "specialty chemical manufacturing facility" in a rural residential/farming community, I strongly believe that there are critical health and environmental concerns associated with the location of the proposed "specialty chemical manufacturing facility."

On 04/18/2019 Dr. Box set up a Partition Deed (Williamson County document number 209032454) removing the 224.71-acre tract from the parent tract consisting of 258.66 acres. The 224.71-acre tract was transferred to the Box Place Charitable Remainder Unitrust. This left a 35.07-acre tract remaining in Box's name. Before the land was sold to County Road 236 Investments, LLC on 08/13/2019 - another document called the Correction Warranty Deed (document number 2019075031) was signed by Dr. Box which voided the Partition Deed and made the Correction Warranty Deed effective 03/14/2019, the date the trust was formed.

Prior to selling the 224.71-acre tract and the 35.07-acre tract to County Road 236 Investments, Dr. Box removed the Restrictions from the two 15.0-acre tracts which are adjacent to the 224.71-acre tract. These tracts were previously sold by Dr. Box in 2001 to the Moore's (currently the Waller's) and the Barksdale's (currently the Thurman's). In addition, Dr. Box removes any restrictions that were placed on Box's 224.71-acre tract and his 35.07-acre tract in a document titled "Agreement to Release All Existing Restrictions and Impose New Restrictions Upon a Portion of the Property" (document number 2019064108 dated 07/15/2019). When Dr. Box sold the property to County Road 236 Investments, LLC on 08/13/2019 the only restrictions on Box's tracts (224.71 acres and 35.07 acres) were the 12 acres (from the 224.71-acre tract) that my husband and I purchased (Lot #1/AKA Tract E on this particular document). This document states that the "restrictive covenants are to run with the land in favor of the owners of Tract A & B (Box), C (Waller), D (Thurman) and E (now Shubert) as well as their heirs, executors, administrators, successors or assigns." When the land was sold to County Road 236 Investments on 08/13/2019 there were 2 Warranty Deeds (2019075033 & 2019075032) and neither mentioned the previous document placing Restrictions specifically on Lot #1. The 35.07-acre tract was sold by Richard Box (personally) and the 224.71-acre tract was sold under the name of the Box Place Charitable Remainder Unitrust. Both convey "all presently recorded restrictions, reservations, covenants, conditions and mineral severances that affect the property."

As far as I know there are no documents filed with Williamson County which establish this property or community as a planned unit development (PUD) or any type of development. The realtors do not refer to themselves as developers only as the declarant on the CCRs. No HOA was formed.

The first property was, sold to Balaraju Velupula on 10/24/2019. It included the 3 lots closest to Highway 183 and it was comprised of 33.9 acres (Lots 20, 21 & 22). The CCRs for that property were signed 10/21/2019 (document number 2019100615) by Stewart Pate of County Road 236 Investments, LLC. Under paragraph 1.01 of this CCR it's Uses include: "Light commercial uses including a plant nursery or similar use which does not generate excessive traffic is an approved use on all or a portion of the Property. No use can conflict with Paragraph 1.10 herein. Home-based businesses of any kind must be approved in advance by the Declarant. Not more than two single-family residences may be constructed or placed in a tract. The term "single family residence" shall include only site-built homes, barnominiums, mobile homes or modular homes which are not older than a 2014 model year based upon its date of manufacture. Move-on homes are allowed as long as they are site-built homes and any remodeling is complete within twelve (12) months of the closing date of the tract." Document number 2019100615 was the first CCR written and recorded in Williamson County for any of the properties sold by County Road 236 Investments, LLC. On a side note: I firmly believe that if the CCRs are actually written for the purpose of creating a unified plan (as it is written in the CCRs), then all of the CCRs for a particular community would be exactly the same as the first one recorded. But that didn't happen here.

The second property sold also included 3 lots. These lots totaling 36.07 acres (Lots 5, 6 & 7) were purchased by Exfluor Research Corporation on 12/13/2019. The CCRs were signed 11/25/2019 (document number 2019113872) by Stewart Pate. Under paragraph 1.01 of this CCR it's Uses include: "Single family residential is an approved use of the property. Home based businesses or light commercial and light industrial/manufacturing uses maybe permitted if the Declarant has given written consent of any such use in advance. The specialty chemical manufacturing facility proposed by Exfluor Research Corporation is an approved use. No use can conflict with Paragraph 1.10 herein…"

One item of interest on Exfluor's Warranty Deed (document number 2019120557) is that it refers to its associated CCRs as recorded document number 2019116579 dated 11/25/2019. Document number 2019116579 was actually signed on 11/06/2019. That document number refers to 12.27 acres presently owned by Kyle & Shannon Gehrer (Lot 4). The CCRs referenced on Exfluor's Warranty Deed is actually Gehrer's CCR. So basically the Warranty Deed has the current date that the CCR for its property was signed but the Warranty Deed refers to the wrong document number. Side note: this is the only mistake I have uncovered in all the documents recorded with the Williamson County for County Road 236 Investments. I, personally, find it very suspicious that the mistake actually happened with this particular document. Again, this is the only document which states that light commercial and light industrial/manufacturing is an approved use for any of the properties in this community.

Five additional tracts were sold prior to our closing. According to the CCRs filed with the county, none of these lots received any special consideration for a home based business or light commercial use. All five read the same under Uses "Single family residential is an approved use of the property. Home based businesses or light commercial uses may be permitted if the Declarant has given written consent of any such use in advance. No use can conflict with Paragraph 1.10 herein. Not more than two single-family residences may be constructed or placed on a tract. The term "single-family residence" shall include only site-built homes, barnominiums, mobile homes or modular homes which are which are not older than a 2014 model year based upon its date of manufacture. Move-on homes are allowed as long as they are site-built homes and any remodeling is complete within twelve (12) months of the closing date of the tract."

Gehrer (Lot 4) CCR dated 11/06/2019; Warranty Deed dated 12/06/2019
Ellis (Lot 3) CCR dated 12/06/2019; Warranty Deed dated 12/11/2019
Johnson (Lot 2) CCR dated 12/06/2019; Warranty Deed dated 12/13/2019
Smith (Lot 11) purchased small house with 18-acre lot;
CCR dated 12/30/2019; Warranty Deed dated 01/07/2020
Campbell (Lot 15) CCR dated 01/17/2020; Warranty Deed dated 01/21/2020

The original CCR for our property (Lot 1) was dated 01/28/2020 and signed by Stewart Pate (document number 2020008836). The Original CCR for Lot 1 read exactly like the CCRs for other lots. We were told that they forgot to put the Special Restrictions on our property when they wrote it. The Special Restrictions include this property can only have site built homes; structures must be set back 50 feet from the front and the western property lines; structures must be set back 25 feet from the rear and the eastern property lines; lot may never be subdivided; and no temporary structures shall be used as a residence. On 01/29/2020 Stewart Pate signed the First Amendment to the Declaration of Covenants, Conditions, Easements and Restrictions (document number 2020009688) to make the changes to the CCR specifically for Lot 1. No other Amendments have been written by County Road 236 Investments for these properties. No Amendment was written for any property to include light industrial/manufacturing uses. This use is specified on only one CCR, the one written for Exfluor's three lots. Again, no one had any idea that an industrial company or a manufacturing company would build here because light industrial/manufacturing uses wasn't mentioned on any other CCR.

After we purchased our property on 01/31/2020, nine additional lots were sold in 2020. Schneider (Lot #19) is the only one with a CCR that differs from the others. Their CCR is dated 01/28/2020 (document number 2020008830). Their CCR reads "Single Family residential is an approved use of the property. Home based businesses or light commercial uses may be permitted if the Declarant has given written consent of any such use in advance. An air conditioning and heating company as well as an insulation business is an approved use. No use can conflict with Paragraph 1.10 herein…"

Special Environmental Concerns:

There is so much to mention regarding the environmental concerns but here are the highlights: The soil here is unique. It is fertile. According to a soil survey conducted in 1983 our soil is classified as Brackett-Eckrant-Doss Soil. It makes up only 3% of Williamson County. It is characterized as "shallow and very shallow, calcareous, loamy and clayey, gravely, stony and cobbly soils formed in indurated limestone and marl; on uplands." https://texashistory.unt.edu/ark:/67531/metapth130329/m1/1/

According to Ronnie McCloud, a rancher whose family has raised cattle on the property for many years, we have springs. There is also plenty of evidence of mossy green vegetation in areas where the springs are located although they haven't been active since we purchased the property. Ronnie says the springs run all throughout the heavily treed lots 1-7. Again, Mike & I own lot 1 and Exfluor owns lots 5,6 & 7. A 2010 map from TWDB and THI shows that our area is within the spatial distribution of springs in Texas.

Williamson County has more known caves than any county in Texas; in 2018 there were 675 known caves in Williamson County. The largest cave in Williamson County is a few miles away near Andice. We are also located in the Karst region for the Balcones Fault Zone. Our land is in a subcrop of the Edwards Aquifer and the Trinity Plateau. Millions of people get their water from the Edwards Aquifer including the city of San Antonio and the surrounding communities. We are also in the North San Gabriel River Watershed. Discharge into the North San Gabriel River flows into Lake Georgetown, Lake Granger, the Brazos River, and eventually into the Gulf of Mexico. Lake Georgetown is a source of water for many people in the Georgetown and Round Rock area.

Exfluor Notes from the Town Hall meeting:

The first reason given by Exfluor to a local community on why they chose this particular location: they said it was because of the beautiful trees. Honestly, it was hard to listen after this. It was filmed by a local news outlet. https://www.kxan.com/news/local/williamson-county/chemical-company-hosts-town-hall-to-address-concerns-over-planned-florence-area-facility/

A representative from Exfluor stated during the meeting that they have done an environmental study but added that they would not disclose it to the public.

Related News articles:

https://www.lhindependent.com/news/business/chemical-manufacturer-opening-facility-north-of-liberty-hill/article_2c41a9a9-8de7-577c-b39c-3ff5d8777b10.html
https://www.lhindependent.com/news/cr-236-residents-form-group-to-oppose-planned-chemical-facility/article_2953d324-b76d-11ec-a81d-9fe402e39c45.html
https://www.kxan.com/news/local/williamson-county/williamson-county-residents-battle-to-halt-planned-chemical-facility/
https://www.kvue.com/article/news/local/williamson-county/exfluor-concerns-mount-chemical-research-facility-rural-williamson-county/269-e99939ab-52b2-41cf-9855-5236cabe719e
https://www.fox7austin.com/news/williamson-county-environment-chemical-plant
https://www.statesman.com/story/news,/2022/04/26/florence-tx-williamson-county-neighbors-worried-exfluor-facility-pollution/7294446001/
https://www.change.org/p/block-the-toxic-chemical-pollution-in-the-area-of-the-north-fork-of-the-san-gabriel-river
https://online-engineering.case.edu/blog/disastrous-engineering-failures-due-to-ethics
https://petpedia.co/bee-statistics /

After Exfluor purchased their 36.07-acre tract NO ONE was informed, either verbally or written, with any type of disclosure concerning Exfluor's plans to build a "specialty chemical manufacturing facility" nearby. County Road 236 Investments sold five additional properties prior to closing on our Lot # 1 on 01/31/2020. A few neighbors, including us, were told about the plans for a plant nursery on the lots near Highway 183. We were told that the only lot which had any special restrictions was Lot # 1 (ours). No one was informed that Exfluor was given any special permissions. Specifically, we and a few other property owners also asked if all the CCRs were the same. And everyone was reassured that only Lot # 1 had Special or different restrictions. Up until a month ago no one knew that County Road 236 Investments gave anyone permission to use their property for light industrial/manufacturing uses. Exfluor's CCR (which is not attached to their Warranty Deed) is the only CCR among all of the properties sold by County Road 236 Investments that includes light industrial/manufacturing uses.

As I previously stated, Exfluor's CCR is the only CCR that includes light industrial/manufacturing uses. It is my understanding that CCRs are basically considered the rules among a community and that they are like contracts between private parties that can be enforced in court. I also understand that, primarily, CCRs are used to maintain property values. Every single CCR in this community specifically states that they are for "the purpose of carrying out a uniform plan." I do not understand - how the CCRs written for Exfluor carry out a uniform plan if Exfluor is allowed to use their property for light industrial/manufacturing uses. This is a major conflict within our CCRs as they were written for Exfluor. A "specialty chemical manufacturing facility" does not belong in a rural community of Single Family Residential/Agricultural properties.

Also, I do not understand how the CCRs will protect anyone's property value if a "specialty chemical manufacturing facility" is allowed to be built here. This is another major conflict within the CCRs as they were written for Exfluor. No property values will be maintained if a "specialty chemical manufacturing facility" is allowed to be built here. In fact, the neighbors we have spoken to unanimously agree that they would have never purchased their property if they had known that a "specialty chemical manufacturing facility" would be built nearby. We agree completely.

My neighbors and I firmly believe that this particular "use" for Exfluor's property conflicts with Paragraph 1.10 - the Nuisance paragraph. This paragraph addresses "Nuisances: No noxious, noisy, offensive, undesirable, unlawful or immoral activity shall be conducted on any tract, nor shall anything be done or permitted to be done thereon which may be or become a nuisance or annoyance to the owners of adjacent tracts. Any determination by the Declarant that an activity is noxious, noisy, offensive, undesirable or immoral shall be final and binding on all parties." Per US Legal a nuisance is "a substantial interference with the right to use and enjoy land, which may be intentional, negligent or ultra-hazardous in origin, and must be a result of defendant's activity." Ultra-hazardous is the key here. Some of the chemicals Exfluor works with are perfluorocarbons; they are called "forever chemicals" due to the fact that they are extremely stable. They do not break down in the environment. Their life cycles can last from 10K to 50K years! For this reason, Tom Bierschenk of Exfluor has reassured his neighbors, Kyle and Shannon Gehrer (Lot #4), that they (meaning Exfluor) "will have no air emissions and they have decided not to release any water." However according to their recent TCEQ application "the proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants,, nitrogen oxides and organic compounds." According to Dr. Robert F. Harris Sr., retired Dow Chemical research scientist , "the critical effects of inhalation exposure to hydrogen fluoride are respiratory tract irritation and the induction of respiratory disease, even low level emissions. At higher levels, as what happens in the inevitable accidental or unexpected release, fatalities are possible." Dr. Harris concludes that "Exfluor, by its own admission, will emit hydrogen fluoride if this plant is built. Hydrogen fluoride should never be released into the air where people live. This is a DEADLY dangerous gas." www.NorthSanGabrielAlliance.com has additional information regarding the types of chemicals used by Exfluor.

Bierschenk claims that all of their water will be recycled and reused or purified then evaporated. He adds that (we) "will not use any recycled water to irrigate or even place it in a septic system because we want to be 100% confident that not even a trace gets into the environment." This does not sound like a safe place for Single Family Residences in a rural community where there will be even less regulation and oversite for a "specialty chemical manufacturing facility." The fact is that Exfluor's land was purchased among a group of properties that were primarily sold for the use as Single Family Residences. There were 22 lots sold in this community and only one land sale (which included three lots totaling 36.07 acres) is allowed to use their property for light industrial/light manufacturing uses. I firmly believe that "specialty chemical manufacturing facilities" should be built in industrial parks. Exfluor should not be building a "specialty chemical manufacturing facility" in a rural community of single family residential properties and agriculture. I believe this is a serious moral and ethical issue. There should be laws that protect property owners from situations like this.

In addition, County Road 236 is not equipped to serve industrial or chemical manufacturing needs because the utilities in this rural area are unreliable. There is inadequate water and no sewer available. All nearby properties use well water. There is no natural gas available. Power outages are common in this area. And the most serious issue is that we do not have a fire department or an emergency response team nearby that can handle the type of Hazardous Materials that Exfluor works with. This community is not equipped for a "specialty chemical manufacturing facility." The nearest fire department is in Andice, TX and it is a volunteer fire department. The nearest Level 2 Trauma Center is 25 miles away. The nearest Level 1 Trauma Center is 40 miles away. Again, this area is not equipped to serve the needs of an industrial or a chemical manufacturing facility. I firmly believe that building a "specialty chemical manufacturing facility" in a rural community like Florence is a very serious moral and ethical issue. And I believe it is simply ludicrous that anyone would ignore these concerns.

Per the Williamson County Appraisal District there are 7 properties raising bees in this community (including us on lot 1). The beekeepers are on lots 1-4 and lots 13, 14 & 15. Potentially this means that as many as 70 hives that will be exposed to Exfluor's evaporation pond which WILL NOT BE COVERED. We cannot risk this. Several of our neighbors bottle and sell their honey and honey products. This is also a very serious ethical issue since Bierschenk was well informed of this problem by a neighbor at the Town Hall meeting held 04/25/22. Everyone has a moral compass that helps them to distinguish right from wrong. An engineer's compass should be more finely calibrated than most.

I firmly believe that there are critical health and environmental concerns associated with Exfluor's proposed "specialty chemical manufacturing facility." The term Nuisance has been well defined by the Texas Supreme Court in a recent case. At the very least, it appears that this is Strict Liability Nuisance which occurs when the conduct is an "abnormally dangerous activity."
https://www.texasoilandgasattorneyblog.com/requirements-noise-nuisance-claim-texas/

A "specialty chemical manufacturing facility" does not belong in a Rural community among Single Family Residences and Agriculture. Due to the serious moral and ethical issues as well as the critical health and environmental concerns I urgently request that TCEQ take action to DENY PERMIT NO. 165848, Exfluor Research, 1100 County Road 236, Florence, Texas, 76527.

Thank you for your consideration.

Shannon White-Shubert (Lot #1; 1500 CR 236, Florence)

"I am a property owner in the area (CR 204 in Williamson County), and we plan to build a house and move to our property within the next year. I am also a semi-retired engineer with a Ph.D. in Mechanical Engineering from UT Austin. In my view, chemical plants should not be allowed to discharge into streams that supply large and growing municipal water supplies. While the discharge can be "made safe" and monitored, assuming both are rigorously done, any accidents pose a good deal of danger to a large number of people. In addition, the damage done may be long lasting and difficult to mitigate. For similar reasons, such industries should not be allowed to build immediately adjacent to already established residential areas. Logical locations for such industrial activities are in areas set aside for such activities. This more easily allows multiple operations to be monitored for compliance as well as providing adequate and rapid emergency response if necessary. Allowing such concerns to operate wherever they are able to acquire land spreads out the danger, thus devaluing large areas as opposed to keeping dangerous, albeit sometimes necessary, activities confined to locations predetermined by a well thought out growth plan."

Respectfully submitted, Don T. Berry, Ph.D. of Austin, Texas

"As a 20yr firefighter who has responded to numerous chemical leaks and as a FATHER, I am opposed to air quality permit 165848 and requesting a "public meeting." As a member of NORTH SAN GABRIEL ALLIANCE, I firmly believe that there is great risk of air and water pollution from the hazardous chemical processing plant under development by Exfluor Research Corporation on Williamson County Road 236. This pending Exfluor Research Corporation location is surrounded by 150+ family residences, including historical farms, ranches, and homes, water recreation areas, agricultural lands, and wildlife conservation areas. The North Fork of the San Gabriel River runs through the area, and downstream to Lake Georgetown and Lake Granger, then into the Brazos River and on to the Gulf of Mexico. The City of Georgetown and the City of Round Rock obtain drinking water from Lake Georgetown. Toxic chemical pollution from such a facility could permanently affect people, homes, land, and agriculture nearby, as well as downstream in the river drainages. Such a facility should not be located anywhere in the area of the North Fork of the San Gabriel River. This rural area is primarily residential, agricultural, and widely used for recreation activities. This is not an industrial area. I call upon the Texas Commission on Environmental Quality (TCEQ) to RESCIND its preliminary decision and DENY the draft air quality permit for the announced Exfluor Research Corporation chemical manufacturing facility on County Road 236."

Jerome Palmer of Liberty Hill, Texas

"I am strongly opposed to air quality permit 165848 and requesting a "public meeting." As a Liberty Hill resident residing within 5 miles of the proposed business site I firmly believe that there is great risk of air and water pollution from the hazardous chemical processing plant under development by Exfluor Research Corporation on Williamson County Road 236. This is not an industrial area. This rural area is primarily residential, agricultural, and widely used for recreation activities. A chemical plant has no place among family residences, farms and ranches. Toxic chemical pollution from such a facility could permanently affect people, homes, land, and agriculture nearby, as well as downstream in the river drainages. I call upon the Texas Commission on Environmental Quality (TCEQ) to RESCIND its preliminary decision and DENY the draft air quality permit for the announced Exfluor Research Corporation chemical manufacturing facility on County Road 236."

Cristin Dershem of Liberty Hill, Texas

"This permit should not be issued, Exflour should not be allowed to have a facility next to the North San Gabriel River. In addition, the land they have purchased is in a residential/ranching community, across the street from a planned 600 home neighborhood. If the were to be a spill, it would most certainly contaminate the river. I was in attendance to the meeting held in Liberty Hill to address the community concerns, they started off by bringing the priest from the church in Austin they support and asked him to pray before the meeting, the church has nothing to do with this business other than to continue to receive donations, I thought this practice was appalling. When asked what they would be bringing to the table for the community the only response what 8-10 additional jobs and that they would spend money eating out in our town. I am a 30 year resident of the area and this company has too much risk to be allowed to operate in a residential environment, they need to relocate to an industrial park where if an accident happens, there will be people that and services to address it. Currently Williamson county does not have the ability to handle a possible contamination in this area."

Paul Davidson of Liberty Hill, Texas

"After attending the Exfluor Q&A at the proposed build site last week- it is evident and clear that they fully intend to skirt and avoid all liability and accountability. They are moving out to "the middle of nowhere" in order to avoid peering eyes and to avoid is getting caught when their facility leaks. They did not intend to allow the Roundrock residents or neighbors to find out about the 2014 leak - the company next door called 911 when their employees could not breathe. Exfluor made every attempt to hide this leak and cover it up. It was leaking into the high school located directly behind their plant. The lethal effects and final outcomes of their decision will likely not be seen for decades- they will get away with it as usual. As a local resident of the LH area - I do NOT consent to being slowly poisoned to death. I do not consent to Exfluor poisoning my child just so they can turn a less-regulated profit. You will not do this to our community."

Heather Garcia-Stonehill of Leander, Texas

AUSTIN-AMERICAN STATESMAN'S RECENT NEWS COVERAGE OF NORTH SAN GABRIEL ALLIANCE: Neighbors fear 'forever chemical' business will ruin rural area in Williamson County

Wed, 27 Apr 2022 21:15:18 GMT

Click below to read Claire Osborn's full article in the Austin American-Statesman "Exfluor has a history of spills and leaks, according to reports from the Texas environmental commission and the Brushy Creek Regional Wastewater Treatment System."

KXAN's Recent News Coverage of North San Gabriel Alliance: Chemical company hosts town hall to address concerns over planned Florence-area facility

Mon, 25 Apr 2022 19:44:48 GMT

Were you able to attend the recent Q&A Session held by EXFLUOR?

We want to hear from you! All responses are anonymous unless you identify yourself.

We'd love to hear your thoughts over this meeting here.

C&EN RECENT NEWS COVERAGE NORTH SAN GABRIEL ALLIANCE: Residents seek to stop Exfluor fluorocarbon plant

Sat, 23 Apr 2022 17:01:42 GMT

Click below to read Michael McCoy's full article on the C&EN site: Residents seek to stop Exfluor facility

This is the leading chemical industry trade journal. From C&EN Magazine's website:

"WHO WE ARE

At Chemical & Engineering News (C&EN), we’re committed to keeping you up to date with the chemistry news that matters most. Our reporters and editors track important research advances, business and policy trends, chemical safety practices, career guidance, and more.

We are the world's most comprehensive and authoritative source of news about chemistry and related fields. Our journalists are based in the US, Europe, and Asia, and chemists recognize us for our breaking-news coverage and award-winning features.

C&EN has been published by the American Chemical Society since 1923."

PLEASE ATTEND: 10 AM Saturday April 23rd Q&A MEETING

Wed, 20 Apr 2022 19:10:50 GMT

North San Gabriel Alliance recommends that all concerned area residents should attend the 10:00 AM Saturday April 23rd meeting called by Exfluor on CR 236. This is NOT the TCEQ public meeting, date to be determined. This April 23rd meeting is open to the public. Exfluor's invitation says it will be Q and A. North San Gabriel Alliance asks everyone to respectfully allow the staff and supporters of Exfluor to have their say to the community.

Location:
Lone Star Oaks
3354 Co Rd 236
Liberty Hill, TX 78642

SUGGESTED TALKING POINTS

1) AIR QUALITY

Any gas discharge could easily impact the nearby family homes. Exfluor is a known leaker. (link to the KVUE video and other PROVEN * gas * leaks from Exfluor). Plumes from a chemical fire or explosion could travel very long distances. What if a tornado hit the Exfluor facility? In the past few weeks Williamson County has been hit by three tornados. If a tornado struck an Exfluor site on County Road 236, toxic gas and chemicals could be spread throughout the area.

2) UNRELIABLE INFRASTRUCTURE

The County Road 236 area is not equipped to serve industrial or chemical manufacturing needs because the area’s utilities are unreliable. There is inadequate water, no sewer, no natural gas. Power outages are common.

3) Exfluor has stated that the company is expected to double its business this year, next year and the year after that. If headcount follows, the workforce would grow to 50 people in 2022, 100 people in 2023, and 200 people in 2024. This growth would produce a major chemical manufacturing factory in an agricultural and residential area. A rapidly growing specialty chemical manufacturing facility would have a risk of catastrophic fire and explosion. Exfluor will use hydrogen gas in their manufacturing — an element presenting an elevated risk of explosion. Local firefighters and emergency response teams are not equipped to handle chemical spills or fires.

4) Potential for a chemical and industrial super site. Exfluor’s 36-acre site has enough land for other chemical companies and suppliers to build additional facilities, possibly creating a chemical and industrial super site. The anticipated number of passenger vehicles, delivery trucks, and tanker trucks which would pour into this area would generate congestion, vehicle accidents, and increased calls to the Sheriff's Department, in addition to increased risk of chemical fires and explosions.

5) County Road 236 is not a SPECIALTY CHEMICAL MANUFACTURING area. This is a residential, agricultural and natural area. Exfluor’s chemical manufacturing should take place in an industrial park designed for such activity, a place served by adequate power, natural gas, water supplies, roadways, law enforcement, and emergency responders. The people, environment, fire and emergency responders of Northwest Williamson County and the adjoining area of Burnet County are not equipped to handle the risks presented by a possible chemical and industrial super site. However small the possibility may be, any spills at the Exfluor facility could wash into the watershed of the North Fork of the San Gabriel River. Any gas discharge could easily impact the nearby family homes, and a much wider area.

Links available to the public documents filed by Exfluor for their regulated entity information and PERMIT STATUSES below:

Please spread this information.

Click below to read our full position statement.

FOX'S RECENT NEWS COVERAGE FOR NORTH SAN GABRIEL ALLIANCE: Wilco residents fear environmental damage from planned chemical plant

Tue, 19 Apr 2022 21:41:57 GMT

Click below to watch FOX's News Segment over North San Gabriel Alliance efforts to protect and defend the air and water quality of the North Fork of the San Gabriel River and the surrounding communities.

Watch the FOX News Segment covering North San Gabriel Alliance's latest efforts below

KVUE RECENT NEWS COVERAGE FOR NORTH SAN GABRIEL ALLIANCE: Concerns mount over chemical research facility proposed in rural Williamson County

Sat, 16 Apr 2022 17:31:24 GMT

Click below to watch KVUE's News Segment over North San Gabriel Alliance working to protect the North Fork of the San Gabriel River from future air and water pollution.

Click below to watch the KVUE news segment here!

Read & Share KVUE reporter Mike Marut's Twitter Thread:

READ: WILLIAMSON COUNTY PRECINCT TWO COMMISSIONER CYNTHIA LONG'S LETTER TO THE TCEQ

Thu, 14 Apr 2022 17:09:00 GMT

Thank you Commissioner Long for pointing out the lack of public utilities at the proposed Exfluor site, and asking TCEQ to thoroughly review Exfluor's draft air quality permit, while considering neighborhood concerns regarding compatible land use and potential water and air contamination.

Thank you, COMMISSIONER LONG!

CLICK TO READ HER FULL LETTER TO TCEQ BELOW.

"I am elected to represent individuals in Precinct Two of Williamson County, which includes the area on County Road 236 where Exfluor Research Corporation is requesting permit number 165848 to be approved, allowing a chemical manufacturing site to be created. This area of the county is primarily residential and agricultural in nature. There are no public utilities available, therefore, homes in this area of my precinct are on septic systems, with wells for their family's water source. Many of my constituents are concerned that relocation of the Exfluor Corporation's chemical manufacturing site will over tax the water supply and not be a cohesive use with current property owners in the area. Additionally, they are concerned about any spills or biproducts of production that could potentially contaminate the water supply and air. "

EXFLUOR RESEARCH PRIMARY BUSINESS FOR SITE ON CR 236 IS: "SPECIALTY CHEMICAL MANUFACTURING"

Thu, 14 Apr 2022 14:44:20 GMT

EXFLUOR RESEARCH

PRIMARY BUSINESS: SPECIALTY CHEMICAL MANUFACTURING

EXFLUOR Research Corp, AKA Exfluor Labs according to their Edwards Aquifer Permit Appliaction has a Regulated Entity in the Central Registry found on the Texas Commission on Environmental Quality's website here which states that the site near Florence primary business as "SPECIALTY CHEMICAL MANUFACTURING" while also giving us into the Industry Type Codes for the proposed site.

CLICK HERE TO READH OSHA STANDARDS FOR ALL NAICS Code: 325 Chemical Manufacturing

325188 NAICS - All Other Basic Inorganic Chemical Manufacturing

"This industry comprises establishments primarily engaged in manufacturing basic inorganic chemicals (except industrial gases and synthetic dyes and pigments)." - NAICS Code Description from the NAICS Association

325998 NAICS All Other Miscellaneous Chemical Product Manufacturing

"This U.S. industry comprises establishments primarily engaged in manufacturing chemical products (except basic chemicals, resins, and synthetic rubber; cellulosic and noncellulosic fibers and filaments; pesticides, fertilizers, and other agricultural chemicals; pharmaceuticals and medicines; paints, coatings and adhesives; soaps, cleaning compounds, and toilet preparations; printing inks; explosives; custom compounding of purchased resins; and photographic films, papers, plates, and chemicals)." - NAICS Code Description from the NAICS Association

2819 SIC Industrial Inorganic Chemicals

"Establishments primarily engaged in manufacturing industrial inorganic chemicals, not elsewhere classified." - OSHA's Description for 2819: Industrial Inorganic Chemicals, Not Elsewhere Classified

CLICK HERE TO READ A LIST OF INDUSTRIAL INORGANIC CHEMICALS FOR CODE 2918 SIC

2869 SIC Industrial Organic Chemicals

"Establishments primarily engaged in manufacturing industrial organic chemicals, not elsewhere classified." - OSHA's Description for 2869: Industrial Organic Chemicals, Not Elsewhere Classified

CLICK HERE TO READ A LIST OF INDUSTRIAL ORGANIC CHEMICALS FOR CODE 2969 SIC

"Firefighters Responded to a Hazardous Materials Leak at Exfluor Research Corp."

Wed, 13 Apr 2022 20:06:00 GMT

"Christianson Air Conditioning and Plumbing, next door to Exfluor, made the initial call to 9-1-1 after some workers there complained of difficulty breathing."

Exfluor does not have a track record of maintaining leaks. At one leak, they didn't even call 911 themselves. Instead, the responding teams found the Exfluor staff "working to contain the release of the material, perfluorosuccinoyl fluoride. "

According to exfluor.com, perfluorosuccinoyl fluoride is considered an irritant and highly toxic by inhalation , if swallowed or if coming in contact with skin.

The Round Rock Fire Department Hazardous Materials Team and the Williamson County Hazardous Materials Team both responded to the incident. Officials from the Texas Commission on Environmental Quality also responded. Air around the building will be monitored periodically while remediation takes place, which is expected to occur this afternoon and evening. Remediation is the company’s responsibility.

KXAN RECENT NEWS Coverage for North San Gabriel Alliance: Williamson County residents battle to halt planned chemical facility

Wed, 13 Apr 2022 19:38:33 GMT

Watch the KXAN News Segment covering North San Gabriel Alliance below

Read Blake Devine's full article on the KXAN website here: Williamson County residents battle to halt planned chemical facility

READ: TEXAS STATE SENATOR CHARLES SCHWERTNER'S LETTER TO THE TCEQ REQUESTING A PUBLIC MEETING FOR PROPOSED AIR PERMIT FOR EXFLUOR!

Mon, 11 Apr 2022 17:22:23 GMT

Thank you, SENATOR SCHWERTNER!

"As Chair of the Texas Commission on Environmental Quality, you have been tasked with the tremendous responsibility of protecting our state's air, water, and natural resources, while balancing that duty with sustainable economic development policies. I too share those values, while also ensuring the voices of Senate District 5 residents are heard whenever a TCEQ related permit directly impacts their lives."

"This is a DEADLY dangerous gas."

Fri, 08 Apr 2022 20:23:58 GMT

Recent response to the Exfluor Notice from Robert F Harris Sr PhD. Retired Dow Chemical research scientist, organic chemistry.

“Hydrogen fluoride is an extremely dangerous chemical - eats your skin, including tissue in your lungs. You cannot ever get it on your body or breathe it. Vapor inhaled can be fatal. One drop on your fingernail and you’ll lose your nail. This should never be released into the air. This is DEADLY dangerous. Exfluor, by their own admission, will emit hydrogen fluoride if this plant is built.”

Robert F Harris Sr PhD. Retired Dow Chemical research scientist, organic chemistry.

The letter from retired Dow Chemical Company Research Scientist, Dr. Robert F. Harris, PhD reads:

To whom it may concern:

I would like to address the TCEQ proposed air quality permit #165848 for Exfluor, a

hydrogen fluoride based chemical plant that is planned to be built on County Road 236

in Williamson County, Texas.

The notice for the proposed Exfluor facility states, "The proposed facility will emit the

following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants,

nitrogen oxides and organic compounds."

The critical effects of inhalation exposure to hydrogen fluoride are respiratory tract

irritation and the induction of respiratory disease, even with low level emissions. At

higher levels, as what happens in the inevitable accidental or unexpected release,

fatalities are possible.

As a research chemist ( now retired) of 40 years, and with a vested personal interest

because my daughter and her family live within the emissions radius, I believe allowing

the chemical plant to operate so dose to residential homes, ranchettes, farms and

ranches is not only irresponsible, but downright dangerous. Exfluor, by its own

admission, will emit hydrogen fluoride if this plant is built. Hydrogen fluoride should

never be released into the air where people live. This is a DEADLY dangerous gas.

Thank you, Dr. Harris!

LIBERTY HILL INDEPENDENT NEWS COVERAGE for North San Gabriel Alliance

Fri, 08 Apr 2022 19:38:26 GMT

Read Rachel Madison's full article on The Liberty Hill Independent here: CR 236 residents form group to oppose planned chemical facility

READ: TEXAS HOUSE OF REPRESENTATIVES MEMBER TERRY M. WILSON'S LETTER TO THE TCEQ REQUESTING A PUBLIC MEETING FOR PROPOSED AIR PERMIT FOR EXFLUOR!

Fri, 08 Apr 2022 17:31:09 GMT

Thank you, REPRESENTATIVE WILSON!

HOW TO: Submit Your Response to Proposed Air Quality Permit #165848 to the TCEQ

Wed, 30 Mar 2022 20:29:22 GMT

TAKE ACTION AND SUBMIT YOUR RESPONSE TO THE PROPOSED AIR QUALITY PERMIT #165848 to the TECQ

STEP 1: Click on the image below to visit the Texas Commission on Environmental Quality "Comment on a Pending Permit Application" search page and enter the TECQ ID Number for Exfluor's Pending Air Permit Number 165848 and click the blue button "next"

STEP TWO: Select "I accept the privacy policy (required to continue)" and fill out your personal contact information.

STEP THREE: Fill out the comment. Our legal team has provided a comment you may copy and paste as a comment submission below. You may also upload a word document or a pdf (less than 5mb) as part of your comment.

COPY and PASTE THE BELOW LEGAL APPROVED TEXT INTO THE FORM:

I am opposed to air quality permit 165848 and requesting a "public meeting." As a member of NORTH SAN GABRIEL ALLIANCE, I firmly believe that there is great risk of air and water pollution from the hazardous chemical processing plant under development by Exfluor Research Corporation on Williamson County Road 236. This pending Exfluor Research Corporation location is surrounded by 150+ family residences, including historical farms, ranches, and homes, water recreation areas, agricultural lands, and wildlife conservation areas. The North Fork of the San Gabriel River runs through the area, and downstream to Lake Georgetown and Lake Granger, then into the Brazos River and on to the Gulf of Mexico. The City of Georgetown and the City of Round Rock obtain drinking water from Lake Georgetown. Toxic chemical pollution from such a facility could permanently affect people, homes, land, and agriculture nearby, as well as downstream in the river drainages. Such a facility should not be located anywhere in the area of the North Fork of the San Gabriel River. This rural area is primarily residential, agricultural, and widely used for recreation activities. This is not an industrial area. I call upon the Texas Commission on Environmental Quality (TCEQ) to RESCIND its preliminary decision and DENY the draft air quality permit for the announced Exfluor Research Corporation chemical manufacturing facility on County Road 236.

Or file by mail, hand-delivery, or fax:

Please include a TCEQ permit you mail, hand-deliver, or fax comments on a pending permit application. Submit your comments using one of the options below:

Mail to: Office of the Chief Clerk, MC 105

TCEQ

PO Box 13087

Austin, TX 78711-3087

Courier or hand-deliver to: Office of the Chief Clerk

TCEQ

12100 Park 35 Circle, Bldg F

Austin, TX 78753

Fax to: 512-239-3311 ^** Note: If you fax your filing, you must mail or hand-deliver the original document and the appropriate number of copies to the Office of the Chief Clerk within three business days.

STEP FOUR: To search comments for the Pending Air Permit 165848 click this image and select search two, enter the permit number 165848 into the TCEQ ID Number form area, and check both boxes in step three, then click search.

Exfluor Research Corporation's Fluorinated Products: Alkanes

Thu, 24 Mar 2022 18:22:54 GMT

In the Extensive regional atmospheric hydrocarbon pollution in the southwestern United States found "Light alkane hydrocarbons are present in major quantities in the near-surface atmosphere of Texas" at levels so high they " were comparable to urban smog values "

The study goes on to say "Elevated atmospheric mixing ratios of C1-C4 alkanes and C2-C4 alkyl nitrates (RONO2) were measured over much of the region during both studies. The alkyl nitrate enhancements show that significant photochemistry analogous to urban smog formation is occurring within the source region. The release of hydrocarbons into the atmosphere contributes to photochemical ozone (O3) production, with related adverse health effects , reduction in plant growth , and climate change ."

We need less creation of these harmful chemicals in our residential areas . We should stop any additional water pollution , air pollution , and increased worker exposures before it's too late.

Exfluor Research Corporation's Fluorinated Products: Acrylates

Thu, 24 Mar 2022 18:02:26 GMT

"At low concentrations, acrylates and methacrylates++ have been found to produce not only systemic toxic, but embryotoxic effects. " - from the 1991 published study Effect of acrylate industry wastes on the environment and the prevention of their harmful action

In another published study Aquatic toxicity of acrylates and methacrylates: quantitative structure-activity relationships based on Kow and LC50 stated "Recent EPA scrutiny of acrylate and methacrylate monomers has resulted in restrictive consent orders and Significant New Use Rules under the Toxic Substances Control Act, based on structure-activity relationships using mouse skin painting studies. The concern is centered on human health issues regarding worker and consumer exposure. Environmental issues , such as aquatic toxicity , are still of concern."

Exfluor Research Corporation's Fluorinated Products: Acids

Thu, 24 Mar 2022 17:38:50 GMT

Fluorinated Products: Acids

From the OECD/UNEP Global Perfluorinated Chemicals (PFC) Group site:

"These substances are persistent and distributed ubiquitously in the global environment, biota and humans, and in remote areas (i.e. they have high long-range transport potential); they are bioaccumulative and can cause various adverse effects in wildlife and humans and have been detected in wildlife, as well as in the blood of neonates.

These findings are of particular concern in view of the known behaviour of these compounds, their persistency , the toxicological profile of certain PFASs, and their potential to accumulate in the body and in food chains.

As a result, PFASs are monitored worldwide, both in the environment and in organisms."

With our current labor shortages, we shouldn't build a n ew chemical manufacturing process in a residential area connected and permitted to water aquifers , emitting known hazardous materials that will need constant monitoring since EXFLUOR is a known leaker and known for "Failing to Comply" with permit conditions .

Exfluor Known for "Failing to Comply with Permit Conditions"

Tue, 22 Mar 2022 18:14:58 GMT

COMPANY: Exfluor Research Corporation; DOCKET NUMBER: 2015-0104-AIR-E; IDENTIFIER: RN104386388; LOCATION: Round Rock, Williamson County; TYPE OF FACILITY: specialty fluorocarbon production plant; RULES VIOLATED: Texas Health and Safety Code (THSC), §382.085(a) and (b), by failing to prevent unauthorized emissions; and 30 TAC §116.115(c), THSC, §382.085(b), and New Source Review Permit Number 84719, Special Conditions Number 7, by failing to comply with permit conditions; PENALTY: $4,875; ENFORCEMENT COORDINATOR: David Carney, (512) 239-2583; REGIONAL OFFICE: 12100 Park 35 Circle, Building A, Austin, Texas 78753, (512) 339-2929

Another Known Exfluor Leak

Tue, 22 Mar 2022 18:10:44 GMT

"...ExFluor was in significant noncompliance..."

PUBLIC NOTICE:

"The United States Environmental Protection Agency (EPA) has established guidelines which require the Brushy Creek Regional Wastewater System (BCRWWS) to annually publish Industrial Users that were in significant noncompliance with pretreatment standards.

Based on the information collected by BCRWWS, the following industries have met the EPA criteria for Significant Noncompliance.

ExFluor Research Corporation, located at 2350 Double Creek Drive Round Rock Texas 78664 During the first quarter of the 2019- 2020 pretreatment year, ExFluor was in significant noncompliance for Technical Review Criteria (TRC) violation for the daily average discharge limits for fluoride at Outfall 002. During the third quarter of the 2019- 2020 pretreatment year, ExFluor was in significant noncompliance f or Technical Review Criteria (TRC) violation for the daily average discharge limits for mercury at Outfall 002 and failure to accurately report mercury effluent violation.

During the fourth quarter of the 2019-2020 pretreatment year, ExFluor was in significant noncompliance for Technical Review Criteria (TRC) violation for the daily average discharge limits for mercury at Outfall 002. "

A site study of potential contaminants found Perfluorooctanoic Acid

Tue, 22 Mar 2022 18:05:02 GMT

POTENTIAL SITE CONTAMINANTS

"Contaminants that may be encountered during the RI include PFCs in soil and groundwater and low level solvents (trichloroethene) and metals (antimony) in groundwater. These contaminants may also be present in other media that is planned to be investigated (i.e., sediment, surface water, soil gas, indoor air, and building rooftop residue). Material Safety Data Sheets for the known site contaminants are presented in Exhibit 1."

From the study: "This RI/FS Work Plan is intended to augment the existing data, define the nature and extent of potential contaminant sources, and evaluate the fate and transport mechanisms applied to any identified contaminants so that the Site’s conceptual model can be refined and an appropriate remedy can be developed for the Site. "

EXFLUOR PRODUCT: Perfluorooctanoic Acid product forever chemical PRESENTED IN EXHIBIT 1

Perfluorooctanoic acid

"THE ABOVE INFORMATION IS BELIEVED TO BE CORRECT, BUT DOES NOT PURPORT TO BE ALL INCLUSIVE AND SHALL BE USED ONLY AS A GUIDE. EXFLUOR RESEARCH CORPORATION SHALL NOT BE HELD LIABLE FOR ANY DAMAGE RESULTING FROM HANDLING OR FROM CONTACT WITH THE ABOVE PRODUCT."

This is the last line in the EXFLUOR's safety data sheet that is included in the site study linked above listed for one of the identified site contaminants.

EXFLUOR'S RESPONSE: "We did not produce any of the compounds found at the Saint-Gobain plant."

A Letter from Our Board

Tue, 22 Mar 2022 17:35:25 GMT

Urgent: Block the toxic chemical pollution in the area of the North Fork of the San Gabriel River!

Please join the North San Gabriel Alliance in filing a response requesting the Texas Commission on Environmental Quality (TCEQ) to RESCIND RESCIND its preliminary decision and DENY the draft of the air quality permit for the announced Exfluor Research Corporation chemical manufacturing facility on County Road 236.

If approved, this air quality permit would allow Exfluor Research Corporation to begin construction of this chemical manufacturing facility in northwest Williamson County, Texas .

Exfluor Research Corporation uses fluorine gas to convert hydrocarbons to fluorocarbo ns. In the Notice for this proposed facility Exfluor states: “The proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants, nitrogen oxides and organic compounds.”. The manufacturing process is dangerous and has produced documented leaks of hydrofluoric acid and other chemical products at other facilities. These chemicals are often referred to as “forever chemicals” because they do not degrade in nature.

The pending Exfluor Research Corporation location on County Road 236 is surrounded by 150+ family residences, including historical farms, ranches, and homes, water recreation areas, agricultural lands, and wildlife conservation areas. The North Fork of the San Gabriel River runs through the area, and downstream to Lake Georgetown and Granger Lake, then into the Brazos River and on to the Gulf of Mexico. The City of Georgetown and the City of Round Rock obtain drinking water from Lake Georgetown.

Exfluor Research Corporation has already obtained a wastewater evaporation permit , which would allow them to construct an evaporation pond. The permit notates the "Receiving water body - North Fork of the San Gabriel River. "

We understand that Exfluor manufactures fluorocarbons for NASA and the United States Air Force, among other important end users. However, Exfluor should locate this new manufacturing facility in an existing chemical manufacturing area, NOT adjoining family homes in the residential, agricultural, scenic, and natural area of the North Fork of the San Gabriel River.

Texas Commission on Environmental Quality (TCEQ) and Exfluor Research Corporation have the opportunity to do the right thing and RESCIND the preliminary decision and DENY the draft the air permit for the County Road 236 location.

In addition, TCEQ and other regulators must withdraw and deny other permits for this chemical manufacturing facility, and other polluters and abusers of the North San Gabriel River area. Join the fight!

Sign the petition now!

"A worrying class of persistent chemicals"

Thu, 17 Mar 2022 20:08:35 GMT

"...the water looks unremarkable, but it is contaminated with synthetic compounds called fluorochemicals, which have been generating increasing concern around the world." - The Fluorine Detectives online in the February 2019 Scientific American Chemistry Section

If we do not stop the Exfluor Research Corporation from building out on County Road 236, we should expect to see a rise in pregnancy complications and cancer among our residents according to studies that "linked growing concentrations of two of the most popular fluorochemicals , PFOA (perfluorooctanoic acid ) - a known EXFLUOR product - and PFOS (perfluorooctane sulfonic acid), to a bevy of health issues, including cancers and problems during pregnancies."

Globally companies and countries alike have stated they would "phase out PFOS under the Stockholm Convention, which controls persistent pollutants; this year PFOA is expected to be added to the banned list. "

However, forever chemicals are just that, forever. These toxic chemicals "...don’t naturally degrade, hundreds of millions of people in Europe, the United States, Australia and China are still exposed to levels of these compounds that exceed what regulatory agencies deem healthy. " - Tainted water: the scientists tracing thousands of fluorinated chemicals in our environment on Nature.com

Don't be fooled by a different name. " PFOA has a chain of eight carbons—it is sometimes called, simply, C8PFOA has a chain of eight carbons—it is sometimes called, simply, C8 "

" C8 (perfluorooctanoic acid or PFOA ) is both a toxin and carcinogenic substance . " - Houston Lawyer, Terry Bryant.

Juries aren't the only to agree on this as "...an epidemiological study of almost 70,000 people which, by 2012, had linked C8 to diseases including kidney and testicular cancers, pregnancy-induced hypertension, ulcerative colitis and high cholesterol (see go.nature.com/2wzex8e )." - The Fluorine Detectives

Swirl Hole - North San Gabriel River

What should we as residents and community members do?

"...THE BIGGEST PRIORITY SHOULD BE TO PREVENT PFAS CONTAMINATION..."

&

"...THE DEFAULT POSITION SHOULD BE TO RESTRICT THE USE OF ALL PFASs..." - The Fluorine Detectives

We are too late for the "110 million Americans drink water with PFAS levels that surpass this recommendation, and 6 million have water with higher levels than the EPA’s guidelines." We do not have to be too late for our community.

✍ ️ Sign the petition now!

While EXFLUOR will claim they are doing everything they can to keep the air and water clean... forever chemicals "often end up in wastewater treatment plants that are not equipped to remove PFASs, Knappe [Detlef Knappe, an environmental engineer at North Carolina State University in Raleigh] says, so the chemicals end up in waterways anyway." - T he Fluorine Detectives

Forever Chemicals: These Toxic Chemicals Are Everywhere

Wed, 16 Mar 2022 18:32:56 GMT

What are "Forever Chemicals?"

According to a 2018 Washington Post opinion piece, Forever Chemicals are a "group of toxic chemicals that may be associated with testicular cancer, kidney cancer, high cholesterol and suppression of vaccine effectiveness in children. They are now in nearly all of our bodies, are found in the air and water around the globe, and they never go away."

Joseph G. Allen goes on to state that Forever Chemicals are characterized by a " fluorine-carbon backbone" that represents "one of the strongest bonds in all of organic chemistry."

Exfluor announced plans to open a new chemical plant our area . EXFLUOR manufactures carbon-fluorine chemicals currently listed under their website products as " Hydrofluorocarbons ."

PERFLUOROOCTANOIC ACID: A Toxic Exfluor Product

Tue, 15 Mar 2022 20:51:47 GMT

Perfluorooctanoic Acid (PFOA) - Safety Data Sheet from Exfluor

Be sure you take action now ! Stop the building of Exfluor Chemical Plant in our area before these harmful chemicals are released WITH LONG LASTING EFFECTS that are harmful to aquatic life, hazardous if inhaled, and being processed by a company with several known hazardous leaks.

If we do not stop the Exfluor Chemical Plant from being built, be sure to bookmark the following First Aid Measures for known hazardous materials created by Exfluor!

We do not want a known toxic leaker building a speciality chemical manufacturing facility in a residential area that is also known for failing to comply with permit conditions!

Take Action Now!

EXFLUOR EPA REPORT Summary: Exfluor's Release of Toxic Chemicals

Tue, 15 Mar 2022 20:34:29 GMT

More known leaks from the existing EXFLUOR facility

Thanks to the United States EPA Reports, we know Exfluor is aware of and continues to leak hazardous material at their current facilities. Read Exfluor's EPA Report Summary below documenting the repetitive production of - , on site processing of -, and byproducts created - o f Toxic Chemicals. Chemicals they would processing at their new plant in Florence . Chemicals that are forever.

WASTEWATER EVAPORATION PERMIT: "RECEIVING WATER BODY - NORTH SAN GABRIEL RIVER"

Tue, 15 Mar 2022 16:24:38 GMT

An ACTIVE EXFLUOR Wastewater Evaporation Permit notes "receiving water body - NORTH FORK SAN GABRIEL RIVER

The Permitted Site Information states the site location as 1100 CR 236 .

EXFLUOR RESEARCH Regulated Entity RN110969227 Information states

Primary Business: SPECIALTY CHEMICAL MANUFACTURING

EXFLUOR states: "The proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants, nitrogen oxides and organic compounds."

Mon, 14 Mar 2022 19:47:09 GMT

PUBLIC NOTICE on 2/23/2022 - TO ALL INTERESTED PERSONS AND PARTIES:

Exfluor Research Corporation, has applied to the Texas Commission on Environmental Quality (TCEQ) for issuance of Proposed Air Quality Permit Number 165848, which would authorize construction of the Exfluor Research facility located at 1100 County Road 236, Florence, Williamson County, Texas 76527. This application was processed in an expedited manner, as allowed by the commission’s rules in 30 Texas

Administrative Code, Chapter 101, Subchapter J.

EXFLUOR Chemical Manufacturing Site Near Florence Williamson County Burnet County in Texas

The permit application, executive director’s preliminary decision, and draft permit will be available for viewing and copying at the TCEQ central office, the TCEQ Austin regional office, and at the Eula Hunt Beck Florence Public Library, 207 East Main Street,

Williamson County, Texas beginning the first day of publication date of February 23, 2022 . The facility’s compliance file, if any exists, is available for public review at the TCEQ Austin Regional Office, 12100 Park 35 Circle Building A Room 179, Austin, Texas.

As the application states, this upcoming Exfluor Research Facility with PRIMARY BUSINESS: SPECIALITY CHEMICAL MANUFACTURING , aka Exfluor Labs , proposed for our area will "emit the following contaminants : hydrogen fluorides , carbon monoxide, hazardous air pollutants , nitrogen oxides, and organic compounds. "

Take Action Now! Be sure to add your name to the petition or donate to stop this chemical manufacturer from creation. We say no to more Forever Chemicals being added to our environment!

north-san-gabriel-alliance

How To Protect Yourself During the Next Chemical Emergency

The Liberty Hill Independent Recent News Coverage: TCEQ grants contested case hearing for Exfluor permit

"Round Rock-based chemical plant Exfluor Research Corporation has hit a hurdle on its way to construct a new facility in northern Williamson County."

The Exfluor Case

﻿

Facts About Hydrogen Fluoride (Hydrofluoric Acid) - Centers of Disease Control and Prevention

﻿

ISSUE: Exfluor Research Corporation is one Texas Commission on Environmental Quality (TCEQ) Air Quality Permit approval away from construction.

Exfluor Research Corporation uses fluorine gas to convert hydrocarbons to fluorocarbons.

In the Notice for this proposed facility Exfluor states : “The proposed facility will emit the following contaminants: hydrogen fluorides, carbon monoxide, hazardous air pollutants, nitrogen oxides and organic compounds.”

The manufacturing process is dangerous and has produced documented leaks at other facilities. Many of these manufactured fluorocarbon compounds are referred to as “forever chemicals” because they do not degrade in nature.

Toxic chemical pollution from Exfluor Research Corporation could permanently affect people, homes, land, and agriculture

nearby, as well as downstream in the river drainages.

More than 3,300 people have signed a petition against this Exfluor facility.

TCEQ has received more than 290 comments against this Exfluor facility.

PUBLICITY. Opposition to the proposed Exfluor plant has received front-page coverage from three newspapers, along with coverage in several TV news segments.

Letters from Elected Officials

July 26, 2022

San Gabriel Wildfire east of Liberty Hill in Williamson County burned 451 acres.

NSGA Granted a Contested Case Hearing by the TCEQ!

December 23rd, 2022

Click here to see the TCEQ Interim Order dated 12-22-2022

Submitting a Request for a Contested Case Hearing on Exfluor Research Corp’s Application for a New Air Permit No. 165848

Submit your hearing request by 5:00 PM on October 13.

Re: Urgent health and environmental concerns over PFAS and HF chemicals North San Gabriel Alliance for public release

Read the full six page letter by clicking the image below

Exfluor: TCEQ Response to Comments is Out

Update Regarding Exfluor

September 13th, 2022

How to: Register for a Texas Legislature Online Account

Be aware of all of the upcoming environmental bills for the 2023 Legislature Session: Set up your Texas Legislature Online Account Now

Killeen Daily Herald's Recent News Coverage: Furious in Florence: Residents voice their outrage over proposed chem plant

“I live right on the corner near the plant,” said Elizabeth Williams, who is a member of the North San Gabriel Alliance, during the informal question-and-answer period of the meeting. “My family has been there for seven generations, so we’re pretty scared.”

RELATED READING

KVUE'S RECENT NEWS COVERAGE: Neighbors frustrated with answers after questioning permit for new chemical facility in rural Williamson County

Exfluor Research Corporation needs an air quality permit to build its new facility in the Florence area. The public voiced their concerns if the facility leaks.

RELATED READING

A top EPA official announced new, more stringent health advisories for four PFAS chemicals

Exfluor Research Corporation lists perfluorooctanoic acid as a product on line 10 of the attached product information page downloaded from http://www.exfluor.com/bycategory.php?cat=acids . This compound is identified in the June 15, 2022 EPA health advisories .

"EPA'S LIFETIME HEALTH ADVISORIES ALSO TAKE INTO ACCOUNT OTHER POTENTIAL SOURCES OF EXPOSURE TO THESE PFAS BEYOND DRINKING WATER (FOR EXAMPLE, FOOD, *AIR* , CONSUMER PRODUCTS, ETC.)." - JUNE 15th EPA ANNOUNCEMENT

RECENT NEWS COVERAGE: KILLEEN DAILY HERALD ‘We’ve been stewards of this land for over 150 years’: Florence family not happy about proposed chem plant

CLICK BELOW TO READ THE FULL ARTICLE IN THE KILLEEN DAILY HERALD ‘We’ve been stewards of this land for over 150 years’: Florence family not happy about proposed chem plant

Killeen Daily Herald News Coverage: Public meeting set for Exfluor chem plant proposed near Florence

Read the full article by Emily Hilley-Sierzchula on the Killeen Daily Herald site

Related Reading

Public Meeting is to be held: Thursday, June 16 at 7:00 PM Florence High School (Cafeteria) 401 FM 970 Florence, Texas 76527

The TCEQ Official Public Meeting is to be held on Thursday, June 16 at 7:00 PM in the Florence High School Cafeteria . We hope to see you there! RSVP VIA FACEBOOK HERE

PUBLIC COMMENT/PUBLIC MEETING

INFORMATION

�� NSGA MEMBER ACTION ITEMS

TCEQ Comment & Public Meeting Request Highlights

We've Reviewed the Publicly Available TCEQ Database & Hand-Selected Neighbor Complaints Below Highlighting The Growing Concern About Forever Chemicals Being Manufactured in our Rural/Residential Area

AUSTIN-AMERICAN STATESMAN'S RECENT NEWS COVERAGE OF NORTH SAN GABRIEL ALLIANCE: Neighbors fear 'forever chemical' business will ruin rural area in Williamson County

Click below to read Claire Osborn's full article in the Austin American-Statesman "Exfluor has a history of spills and leaks, according to reports from the Texas environmental commission and the Brushy Creek Regional Wastewater Treatment System."

Related Reading

KXAN's Recent News Coverage of North San Gabriel Alliance: Chemical company hosts town hall to address concerns over planned Florence-area facility

Were you able to attend the recent Q&A Session held by EXFLUOR?

We want to hear from you! All responses are anonymous unless you identify yourself.

Related Reading

C&EN RECENT NEWS COVERAGE NORTH SAN GABRIEL ALLIANCE: Residents seek to stop Exfluor fluorocarbon plant

Click below to read Michael McCoy's full article on the C&EN site: Residents seek to stop Exfluor facility

PLEASE ATTEND: 10 AM Saturday April 23rd Q&A MEETING

Location: Lone Star Oaks 3354 Co Rd 236 Liberty Hill, TX 78642

FOX'S RECENT NEWS COVERAGE FOR NORTH SAN GABRIEL ALLIANCE: Wilco residents fear environmental damage from planned chemical plant

Click below to watch FOX's News Segment over North San Gabriel Alliance efforts to protect and defend the air and water quality of the North Fork of the San Gabriel River and the surrounding communities.

Watch the FOX News Segment covering North San Gabriel Alliance's latest efforts below

Related Reading

KVUE RECENT NEWS COVERAGE FOR NORTH SAN GABRIEL ALLIANCE: Concerns mount over chemical research facility proposed in rural Williamson County

Click below to watch KVUE's News Segment over North San Gabriel Alliance working to protect the North Fork of the San Gabriel River from future air and water pollution.

Read & Share KVUE reporter Mike Marut's Twitter Thread:

RELATED READING

READ: WILLIAMSON COUNTY PRECINCT TWO COMMISSIONER CYNTHIA LONG'S LETTER TO THE TCEQ

Thank you Commissioner Long for pointing out the lack of public utilities at the proposed Exfluor site, and asking TCEQ to thoroughly review Exfluor's draft air quality permit, while considering neighborhood concerns regarding compatible land use and potential water and air contamination.

Thank you, COMMISSIONER LONG!

CLICK TO READ HER FULL LETTER TO TCEQ BELOW.

EXFLUOR RESEARCH PRIMARY BUSINESS FOR SITE ON CR 236 IS: "SPECIALTY CHEMICAL MANUFACTURING"

EXFLUOR RESEARCH

﻿ PRIMARY BUSINESS: SPECIALTY CHEMICAL MANUFACTURING

325188 NAICS - All Other Basic Inorganic Chemical Manufacturing

"EPA'S LIFETIME HEALTH ADVISORIES ALSO TAKE INTO ACCOUNT OTHER POTENTIAL SOURCES OF EXPOSURE TO THESE PFAS BEYOND DRINKING WATER (FOR EXAMPLE, FOOD, AIR , CONSUMER PRODUCTS, ETC.)." - JUNE 15th EPA ANNOUNCEMENT

Location:
Lone Star Oaks
3354 Co Rd 236
Liberty Hill, TX 78642

PRIMARY BUSINESS: SPECIALTY CHEMICAL MANUFACTURING