VOLUME OF AIR POLLUTION

FACT 1. TXI's Midlothian cement plant is the largest point source of air pollution in north Texas, with actual emissions of 24,096,200 pounds of five major contaminants in 1995. (Source: Texas Natural Resource Conservation Commission, January 1996 State Emissions Inventory Database.)

FACT 2. TXI's Midlothian cement plant was responsible for a full 26% of all the major industrial air pollution in the Dallas-Ft. Worth region in 1995. It was responsible for 42% of the region's major industrial Sulfur Dioxide pollution, 22% of the region's major industrial Nitrogen Oxide pollution, 19% of the region's major industrial particulate matterpollution, 13% of the region's major industrial Carbon Monoxide pollution and 4% of the region's major Volatile Organic Compound pollution. (Source: Texas Natural Resource Conservation Commission, January 1996 State Emissions Inventory Database.)

FACT 3. The Midlothian TXI plant was the region's second largest particulate matter polluter in 1995 with a total of 826.8 tons. (Source: Texas Natural Resource Conservation Commission, January 1996 State Emissions Inventory Database.)

FACT 4. TXI is permitted to emit more than 77,694,329 pounds of air pollution annually. (Source: TXI permit, Texas Natural Resource Conservation Commission, Revised, August, 1994)

FACT 5. According to its own data, TXI's Midlothian cement plant has increased its particulate matter pollution from 123,000 pounds in 1993 to 709,000 pounds in 1995. This has occurred as it has also increased the amount of hazardous waste burned at the plant. (Source: Texas Natural Resource Conservation Commission, 1994 and January 1996 State Emissions Inventory Database.)

FACT 6. TXI is one of North Texas' largest point sources for Volatile Organic Compounds (VOCs) air pollution, an ingredient of ozone pollution. In 1995 TXI emitted 122,200 pounds of VOCs and is permitted to release up to 271,200 pounds a year. TXI is also the region's single largest polluter of Nitrogen Oxides, another ingredient in Ozone pollution, emitting 10,860,200 pounds in 1995. (Source: Texas Natural Resource Conservation Commission, January 1996 State Emissions Inventory Database.)

FACT 7. In its recent draft permit for TXI's waste-burning, the Texas Natural Resource Conservation Commission proposed increasing toxic metals emissions by almost 800%, from a total of 37,223 pounds per year to 290,104 pounds per year. (Source: Texas Natural Resource Conservation Commission, May,1996 draft permit for TXI Midlothian plant, No. HW-50316-001, Attachment H)

FACT 8. In its recent draft permit for TXI's waste-burning, the Texas Natural Resource Conservation Commission proposed allowing dioxin emissions from TXI to exceed proposed federal standards by 300%. (Source: Texas Natural Resource Conservation Commission, May,1996 draft permit for TXI Midlothian plant, No. HW-50316-001, Attachment H) 

VOLUME OF HAZARDOUS WASTE

FACT 9. With four separate kilns permitted to burn hazardous waste, TXI has become Texas largest for-profit hazardous waste incineration facility, burning over 131,000 tons of hazardous waste in 1995 alone. (Source: Randy Jones, TXI Environmental Resources Manager and TNRCC list of Texas commercial hazardous waste incinerators and volume of waste burned, 1995)

FACT 10. TXI is pursuing a permit that would

FACT 11. For the years 1989 through 1992, TXI and North Texas Cement (also located in Midlothian) burned more than twice as much hazardous waste than any of the 26 other cement plants burning waste in the U.S. - a total of 710,000,000 pounds. They also burned more hazardous waste than any other single commercial incinerator in the country during the same time. (North Texas quit burning hazardous waste in 1991 and has not resumed as of 1996) (Source: EI Digest, June 1990, August 1992 and September 1993; Rollins Environmental Services 1994 and EPA 1993)

FACT 12. TXI continues to increase the volume of waste it is burning every year. In 1994 it burned over 180,000,000 pounds of hazardous wastes alone, in 1995 it burned 260,800,000 pounds. In 1993, TXI representatives told state officials it would never burn over 100,000 tons of hazardous waste a year.(Source: Texas Natural Resource Conservation Commission, 1994; Randy Jones, TXI Environmental Resources Manager, 1995; 1993 Texas Air Control Board Task Force on Kiln Incineration of Hazardous Waste)

FACT 13. According to the Texas Natural Resource Conservation Commission, Texas has more than twice as much incineration capacity at its commercial incinerators on the Gulf coast as it needs to meet demand for disposing of in-state generated wastes. (Source: 1993 Texas Air Control Board Task Force on Kiln Incineration of Hazardous Waste)

FACT 14. The Task Force found that the capacity of one of the state's commercial incinerators - Rollins Environmental Service of Deer Park - is adequate to meet the entire state's demand for liquid incineration. (Source: Letter from Texas Air Control Board Chairman Kirk Watson to EPA Administrator Carol Browner summarizing a recommendation of the Air Control Board's Task Force on Kiln Incineration, May 1993)

FACT 15. Out-of-state hazardous waste is being shipped to TXI from across the country, including companies from California, New Jersey, Louisiana, Illinois, Arizona, Colorado and Arkansas. Recently it was discovered that TXI has been burning waste shipped from Puerto Rico. (Source: 1992 and 1993 TXI shipper/supplier manifests, Texas Natural Resource Conservation Commission, April 18th edition of 1996 San Juan Star)

FACT 16. The Public Interest Counsel of the Texas Natural Resource Conservation Commission has stated that There is no current shortage of capacity for incineration of wastes by already permitted facilities. Therefore, any burning of hazardous wastes in cement plants is not a necessity, but rather a way of making money. (Source: Memo to Margaret LiGarde from Charles Thrash of the Public Interest Counsel's Office, Texas Natural Resource Conservation Commission, May 26, 1992) 

AIR POLLUTION FROM WASTE-BURNING

FACT 17. In its 1989 federal permit application, TXI estimated that at least an additional 304,000 pounds of air pollution would be emitted by the burning of hazardous waste at its Midlothian cement plant. (Source: EPA, TXI RCRA Permit Application, 1989)

FACT 18. TXI is permitted to emit up to 37,000 pounds of metals every year, including lead, arsenic, cadmium, chromium, selenium and thallium as a result of burning hazardous waste. TXI is seeking to increase this to 293,639 pounds in its new permit request. (Source: TXI state permit, Texas Natural Resource Conservation Commission, 1994; Texas Natural Resource Conservation Commission, May,1996 draft permit for TXI Midlothian plant, No. HW-50316-001, Attachment H)

FACT 19. TXI is allowed to emit up to approximately 2000 pounds of lead every year while burning wastes.

FACT 20. According to the EPA's Science Advisory Board, as much as 1% of the waste burned at TXI could be released into the atmosphere as Products of Incomplete Combustion during malfunctions, upsets or routine operation. At current volumes of waste being burned at TXI, this means almost 1,800,000 pounds of this waste could be emitted annually. If TXI reaches its permit maximum, this figure could increase to 5,493,571 pounds a year. (Source: EPA, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee, Science Advisory Board, 1985)

FACT 21. TXI reported releasing up to 200 times more dioxin and twice as much Carbon Monoxide while burning hazardous waste compared to burning coal. TXI also reported a higher level of Opacity or smoke when it burned hazardous waste compared to coal. (Source: 1992 TXI test burn, Metco Environmental, Inc.)

FACT 22. EPA has concluded that 99 percent of all known dioxin emissions originate in waste combustion. (Source: Dallas Morning News, September 12, 1994)

FACT 23. In comparison with the last commercial hazardous waste incinerator to open in Texas, TXI can emit 34 times more dust, 112 times more Sulfur Dioxide, 41 times more Nitrogen Oxide, 49 times more Carbon Monoxide, 3 times more Hydrogen Chloride and 15 times more Volatile Organic Compounds. (Source: TNRCC permits for Chem Waste Incinerator and TXI, 1994)

FACT 24. TXI's toxic air pollution increased 1636% from 1993 (3000 pounds) to 1994 (52,000 pounds). In 1990 total toxic air pollution from TXI was 1700 pounds. (Source: USEPA Toxic Release Inventory Data, September 29th, 1995)

FACT 25. The Texas Natural Resource Conservation Commission has proposed a draft permit for TXI's hazardous waste-burning that would triple the amount of hydrogen chloride emissions currently allowed, increase Barium emissions by 265%, increase Beryllium emissions by 1,750%, increase Chromium emissions by 2,830%, increase Mercury emissions by 408%, increase Selenium emissions by 56,600% and increase Zinc emissions by 3,859%. (Source: Texas Natural Resource Conservation Commission, May,1996 draft permit for TXI Midlothian plant, No. HW-50316-001, Attachment H) 

AIR POLLUTION TOXICITY

FACT 26. Of the 708 different wastes TXI is permitted to burn, 462, or 65% are characterized by EPA as toxic, wholly or in part, 3 are characterized as reactive, 1 as corrosive and only 38, or 5%, are classified as exclusively ignitable. (Source: Hazardous Wastes and Management Activities, TXI RCRA permit, revised Dec. 17, 1992)

FACT 27. TXI is now accepting waste with up to 30% solids mixed into it. These solids include toxic heavy metals such as lead, arsenic, cadmium, chromium, thallium, mercury and selenium. In fact, there are so many solids mixed into the waste coming to TXI, the plant has to operate agitators inside its waste storage tanks to prevent solidification of the wastes altogether. (Source: TXI state permit information, 1995)

FACT 28. TXI has and is accepting metals-bearing wastes for disposal. Shipping manifests for 1992 and 1993 show that TXI accepted landfill leachate which was a combination of water and lead, cadmium and arsenic dust, sludge containing flammable solvents, "still bottoms" from hazardous waste blenders and inorganic sludge which had no energy value at all. (Source: Receiver Monitoring Reports, Texas Natural Resource Conservation Commission, 1992 and 1993)

FACT 29. Arsenic is a human cancer-causing agent. It is a potential mutagen, causing genetic defects. Cadmium is a probable human cancer-causing agent. In animal experiments cadmium has caused cancer, birth defects and reproductive problems. Chromium in its hexavalent form causes cancer in humans. When inhaled, lead is a probable human cancer-causing agent. Lead also is responsible for a number of neurological effects. Mercury causes birth defects. It can also cause central nervo

FACT 30. Even very low-level exposure to incinerator emissions can cause harm. "Detection of subtle effects can have significant consequences to individuals and populations. Effects on behavior and on physiological functions often occur at exposures that are significantly lower than those producing acute observable effects." (Source: EPA Science Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee, 1985)

FACT 31. EPA has determined that cement plants are the second largest source of dioxin emissions in the U.S. with 117 to 1200 grams of dioxins emitted every year. In contrast, EPA recorded that U.S. hazardous waste incinerators emitted 11 to 110 grams of dioxin a year. TXI has estimated releasing over 12 grams a year when burning hazardous waste. 10 grams of Dioxin represents EPA's "acceptable" dose for one year for 69 billion people - over 13 times the entire population of earth in 1995. (Source: EPA, "Estimating Exposure to Dioxin-Like Compounds," 1994, TXI test burn data from 1991)

FACT 32. There appears to be no "safe" threshold for dioxin exposure. EPA has concluded that "Exposure to dioxin, even at minute levels, poses cancer risks and health concerns wider than previously suspected, including possible damage to the immune and reproductive systems." (Source: Dallas Morning News, September 12, 1994)

FACT 33. EPA has concluded that "children of women exposed to low le

FACT 34. Dr. Cate Jenkins, former research scientist for EPA has written that "During EPA's April 28th, 1992 public meeting, Dr. Linda Birnbaum, a key scientist in EPA's dioxin reassessment, stated that doses of dioxin currently being received by the U.S. public, primarily through the diet (1 picogram per kilogram per day), are estimated to be capable of causing immunological and reproductive effects. Thus, any dioxin exposure through the presence of a cement kiln or other type of incinerator in any community is unacceptable, because it would increase the exposure to dioxins over those which are already too high." (Source: Letter from Dr. Jenkins to Dr. Mary Money, May 13, 1992.)

FACT 35. There is no "safe" threshold for particulate pollution. A 1995 study by the Harvard School of Public Health states that adverse health effects were evidenced down to the "lowest measurab

FACT 36. The American Lung Association has reported identifying a 28% increase in asthma attacks when ozone levels reach only half the current federal "safe" threshold. (Source: Ft. Worth Star-Telegram, April 29, 1995)

FACT 37. In June of 1996, Tulane University scientists discovered that industrial pollutants linked to breast cancer and male birth defects may be up to 1000 times more toxic when combined with other pollutants than when working alone. Neither the state of Texas nor the EPA take this "synergistic" effect of toxins into account when estimating health risks from TXI's waste-burning. (Source: Science, June 6th, 1996)

FACT 38. The only tools presently used by the Texas Natural Resource Conservation Commission for evaluating health harms from exposure to toxic chemicals - "Effects Screening Levels" are based on

FACT 39. "The reality is that for the vast majority of chemicals, we have little or no chronic toxicity data. Even when we do, we usually don't know the chemical's effects on lung function, nervous system function, immune or endocrine system function, reproductive function, or other vital bodily functions. Without such data, claims that we know what exposures are permissible and will not harm...are false." (Source: Eileen Tarlau, American Hygiene Association Journal, January 1990)

FACT 40. "The National Academy of Sciences has estimated that fewer than 2% of the chemicals in commerce have been tested well enough to support a complete health hazard assessment." (Source: Working Group on Community Right-To-Know, March, 1995)

FACT 41. A Texas Natural Resource Conservation Commission employee became ill for 36 hours after being caught in a TXI plume despite instruments showing that the concentrations of chemicals he was exposed to should have been too small to make him sick. (Source: TACB Memo, December 16, 1991)

FACT 42. TXI's own consultant, Kathyrn Kelly, has stated that there is no safe level of exposure to carcinogens. "Very little is actually known about the health effects of stack emissions from such facilities on off-site populations....EPA considers carcinogens to be non-threshold substances, i.e., any dose or exposure to a carcinogen is assumed to present some increased risk to an individual of developing cancer. As a result there are no regulatory safe levels of exposure to carcinogens....It is generally not possible to determine a threshold (i.e., a no effect level) for humans with any degree of certainty. There is no widely accepted methodology currently available to quantitatively estimate the amounts of non-carcinogenic effects (of incineration)." (Source: Kathryn Kelly, "Health Risk Assessment of Hazardous Waste Incineration Stack Emissions," Hazardous Waste and Hazardous Materials, Vol. 3, Nov. 4, 1986)

FACT 43. Downwind medical professionals have linked emissions from Midlothian's cement kilns to health effects among their patients. Dr. Jay Gartner, a certified allergy and asthma specialist in Duncanville stated in a 1994 letter to EPA Administrator Carol Browner that "I have seen an increase in the number of visits to my office by patients complaining of eye, nasal, and sinus irritation, more frequent sinus infections, exacerbations of asthma, emphysema and bronchitis as well as pneumonia. I have had an increase of hospital admissions for exacerbations of asthma and emphysema from patients living in proximity to the plants. I personally have lived about seven miles from the plants and I myself have had more frequent episodes of asthma and sinusitis which I feel may be from exposures to the toxins. I have been so concerned about the health hazards that I have sold my house and moved about 35 miles away. others have done the same." Dr. Lee Walters, a family practitioner from Duncanville also wrote the EPA's Browner in 1994 and stated "I have had an increase in the number of visits to my office by patients complaining of sinus, asthma, bronchitis, emphysema and severe headaches. I myself live in Cedar Hill, which is near Duncanville, and have noticed that my own family and I are suffering from an increase in headaches and sinus problems." Dr. Mikel Athon, a veterinarian based in Cedar Hill has stated that in a neighborhood directly downwind of the Midlothian plants, "there appears to be abnormally high incidence of reproductive problems (with area horses) for such a small area and population of horses." (Sources: March 2, 1994 letter from Dr, Gartner to Carol Browner, March 4, 1994 letter from Dr. Walters to Carol Browner, March 7, 1994 letter from Dr. Athon to Carol Browner.)

FACT 44. At a 1992 hearing in Austin of the Texas Air Control Board Cement Kiln Incineration Task Force, approximately 20 individuals from Midlothian, Cedar Hill, Duncanville and Mansfield gave testimony that their health was being affected by the pollution from Midlothian's cement plants. (Source: Transcript of August 1992 Texas Air Control Board Cement Kiln Incineration Task Force Public Hearing)

FACT 45. TXI is permitted to burn at least 11 chemicals that scientists have identified as "endocrine and reproductive disrupters." In a statement signed by 18 U.S. and foreign scientists, including U.S. government scientists, these chemicals are said to "undermine neurological and behavioral development and subsequent potential of individuals exposed in the womb.... There may not be definable thresholds for responses to endocrine disrupters." That is, any amount of exposure to these chemicals, no mater how small may cause some adverse effect. (Erice Statement, May 30, 1996, in Rachel's Environment and Health Weekly #501) 

METALS POLLUTION

FACT 46. Metals don't incinerate. "Any metals in the waste feed will be found in the stack effluent, the captured fly ash,...and the

FACT 47. Metals emissions from incineration pose a significant health risk. "Risks from the burning of metal-bearing hazardous wastes in incinerators can be unacceptable under reasonable worst-case circumstances....Clearly, metals can pose significant health risk." (Source: EPA, Standards for Owners and Operators of Hazardous Waste Incinerators and Burning of Hazardous Wastes in Boilers and Industrial Furnaces, April, 1990)

FACT 48. Greater air emission of volatile metals with increased chlorine content havee in Cement Kilns" Environmental Progress, 1984) 

EPIDEMIOLOGICAL EVIDENCE OF HARM

FACT 49. A 1992 University of South Carolina study reported a 50 to 100% greater prevalence of coughing phlegm, wheezing, sore throat and eye irritation among the population l

FACT 50. A 1993 University of North Carolina at Chapel Hill study reported more diagnosed emphysema, sinus trouble and sleep-rousing or morning cough in the population living downwind of a hazardous waste incinerator compared to an upwind population. (Source: Science News, May 22, 1993)

FACT 51. A 1992 Federal Agency for Toxic Substances and DiseaseRegistry study reported that the population living downwind of a hazardous waste incinerator experienced nine times more coughing and wheezing, two and a half times more neurological disease (such a s seizures and tumors) and 40% more neurological symptoms (including tingling, blackouts and in coordination) than a popu

FACT 52. A 1989 British study reported a "marked concentration" of larynx cancer cases among adults in a community within 2 kilometers of a commercial hazardous waste incinerator. (Source: A. Travis, "Waste Incineration Linked to cancer", The Guardian, January 6, 1989) 8

FACT 53. A 1988 Scottish study found an increase in the frequency of human twins in the areas most at risk from air pollution from chemical waste incinerators. During the same time and at the same locations, a "dramatic increase" in twins in dairy cattle was also documented. Scientists conducting the study linked this effectto incinerator air emissions of "polychlorinated hydrocarbons, some of which have oestrogenic properties." (Source: O. Lloyd, M. Lloyd, F. Williams and 

THE MYTH OF COMPLETE DESTRUCTION

FACT 54. EPA has admitted that a 99.99% or greater DRE (Destruction Removal Efficiency) is not possible for smaller concentrations of toxic chemicals. According to an internal EPA memo written by then EPA Office of Solid Waste Director Sylvia Lowrance, these less than 99.99% results are "consistent with our current body of incinerator performance data, which show a very clear trend of decreasing DRE for hazardous wastes with decreasing incoming constituents in the waste feed. The data show that a properly operating incinerator, which reached a 99.99% DRE on higher concentrations of a (chemical) will often achieve less than four nines when the concentration of that (chemical) is less than 1000 parts per million. At this time we have not established a definitive scientific explanation for this phenomenon." (Source: EPA memo, Sylvia Lowrance, Sept 22, 1992)

FACT 55. EPA has stated that "The complete combustion of all hydrocarbons to produce only water and carbon dioxide is theoretical and could occur only under ideal conditions.... Real-world combustion systems, however, virtually always produce PICs (products of incomplete combustion), some of which have been determined to be hig

FACT 56. "Even relatively short-term operation of incinerators in upset conditions can greatly increase the total incinerator-emitted loadings to the environment." (Source: EPA Science Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee, 1985)

FACT 57. From the time TXI's Midlothian cement plant began burning hazardous waste in 1987 until May of 1994, there were 623 reported upsets of various durations. This averages to about once every four days. (Source: TXI Continuous Emissions Monitoring Quarterly Reports to the Texas Natural Resource Conservation Commission, 1987-1994)

FACT 58. "The termination of the waste feed flow to

FACT 59. EPA has stated that "Sampling and analysis techniques are not available to identify or qualify many of the potential compou

FACT 60. EPA has reported that the only air pollution control device used by TXI and North Texas Cement, an electrostatic precipitator, has an average efficiency of only 98.2%. (Source: EPA, Background Document for the Development of Regulations to Control the Burning of Hazardous Waste in Boilers and Industrial Furnaces, 1991)

FACT 61. EPA's Science Advisory Board has concluded that "The current 4 -nines (99.99%) Destruction and Removal Efficiency standard could theoretically allow Products of Incomplete Combustion emission levels which could present significant human

FACT 62. EPA has concluded that "Products of Incomplete Combustion emissions are composed of thousands of different compounds, some of which are in very minute quantities and cannot be detected and quantified without very elaborate and expensive sampling and analytical techniques. Such elaborate work is not feasible in trial burns for permitting purposes and can only be done in research tests. Very few research tests have been conducted to date to identify and quantify all the Products of Incomplete Combustion in a typical emissions sample, and whenever done were unsuccessful because sampling and analysis techniques are not available to identify and quantify many of the potential compounds emitted, nor are toxicity data

FACT 63. "The number of Products of Incomplete Combustion released in the stack gases of hazardous waste combustion units is estimated to range in the thousands by the EPA, however, less than 70% of the total mass of PICs known to be present have been identified. Typically, trial burns and research tests have identified only 1 to 60% of the total mass of unburned hydrocarbons present in stack gases. Specific tests at cement plants that burn hazardous waste have revealed even less identification of contaminants in stack gases." (Source: EPA, Background Document for the Development of PIC Regulations From Hazardous Waste Incinerators, October, 1989)

FACT 64. A 1989 study found that two organic chemicals burned in a boiler were still present in very high concentrations in stack gases being emitted two hours after they were initially fed into the boiler - and were still present at around 50% of their original concentrations a full 43 hours after disposal. Another study found emissions from chemicals in both vaporous and

FACT 65. Stack monitoring of the type TXI use is no guarantee that the cement plants are meeting their Destruction and Removal Efficiency (DRE) goals of 99.99%. "Continuous monitoring for specific absolute levels of emissions of carbon monoxide, oxygen, and total hydrogenated organic carbon cannot guarantee that a 99.99% DRE is being attained." (Source: E. Oppelt, Hazardous Waste Destruction, Environmental Science and Technology, 22:4, 1988)

FACT 66. Higher temperatures found in cement kilns may cause more toxic emissions. Studies have shown a direct link between high kiln temperatures and increased metals emissions. Higher temperatures cause metals to vaporize more quickly, escaping capture by the air pollution control device (Source: G.Carroll, R. Thurnau, R. Mouringhan, L. Waterland, J.W. Lee and D.J. Fournier, Partitioning of Metals in Rotary Kiln, September, 1989)

FACT 67. "Cement kilns tend to have a long lazy flame that could hardly be described as turbulent compared to a hazardous waste incinerator...while the total gas residence time may be 3-5 seconds, residence time in the high temperature zone is much lower...temperatures do drop off rather quickly....Further, in a cement kiln, contrary to good hazardous waste incinerator design, the highest temperature is always at the front end of the kiln, not in the afterburner, which a cement kiln does not even have." (Source: E. Kleppinger and R. Carnes

FACT 68. Incineration performance is impossible to predict. "The complexity of the incineration process, the differences in incinerator designs, and the difficulties in monitoring operating conditions make the accurate prediction of absolute incineration performance an essentially impossible task....Only a very small fraction of the total volume of waste needs to experience...less than optimum conditions to result in significant deviations from the targeted destruction efficiencies." (Source: B. Dellinger, "PIC Formation Under Pyrolytic and Starved Air Conditions", EPA, July 1986) 

CEMENT KILN DUST

FACT 69. "When liquid hazardous waste is burned, as much as 9% of the original volume remains as ash. When solid hazardous wastes are burned, as much as 29% of the original volume remains as ash." (Source: A. Trenholm, P.Gorman and G. Junclaus, Performance Evaluation of Full-Scale Hazardous Waste Incinerators, Vol.1: Executive Summary, EPA November 1984)

FACT 70. A Portland Cement Association study found that lead concentrations in the CKD of cement plants that burn hazardous waste were 250% above the lead concentrations found in the CKD from non-hazardous waste burning cement plants. The same report found cadmium concentrations were 150% higher, chromium concentrations were 50% higher and selenium concentrations were over 100% higher in the CKD of waste-burning cement plants compared to non-waste burners. (Source: J. Delles et al., Trace Metals in Cement and Kiln Dust from North American Cement Plants, Portland Cement Association, Skokie Illinois, 1992)

FACT 71. EPA has found that cement plants that burn hazardous waste produce up to 104% more Cement Kiln Dust waste than cement kilns that do not burn hazardous waste. (Source: EPA, Report to Congress on CKD, December 1993)

FACT 72. EPA has found that cement plants that burn hazardous waste produce significantly more lead contaminated Cement Kiln Dust than cement plants that do not burn hazardous waste. "Overall, certain metals appear to be present at a consistently higher mean concentration in CKD generated by kilns burning hazardous waste than in CKD generated by kilns not using this type of fuel. Lead cadmium and chromium are the most prominent examples." (Source: EPA, Report to Congress on CKD, December 1993)

FACT 73. Based on a study at one waste-burning aggregate plant, as much as 46% of all the metals fed into the kiln will be deposited in the CKD and then into the environment" (Source: D.R. Cox and J.A. Peters, Evaluation of Hazardous Waste Incineration in an Aggregate Kiln: Florida Solite Corporation, EPA, April 1985)

FACT 74. Southdown, Inc., until recently a cement company that burned hazardous waste in its plants, told its stockholders in 1992 that "CKD infused with water may produce a leachate with an alkalinity high enough to be classified as hazardous, and may also leach the hazardous trace metals present therein" (Source: Southdown Annual Report, 1992)

FACT 75. In 1990, an inspector for the Texas Water Commission wrote about TXI's CKD dump this way: "The landfill is unlined. The quarry itself consists of heavily fractured limestone and shale formations. There was standing water in the quarry bottoms at several near-by locations. The shallow depth to perched groundwater (approximately 30 feet) in the area indicates that the potential of a release via seepage of cement kiln constituents into the groundwater is high. The volume of thedisposed dust and the length of time that the landfilling practice has been occurring raises additional concerns that a release to groundwater of the CKD constituents may have occurred." (Source: Peter Lodde, TWC, August, 1990)

FACT 76. In 1994 the Texas Natural Resource Conservation Commission told the EPA that TXI's Cement Kiln Dust disposal practices have contaminated groundwater resources at their Midlothian plant. "Soil and groundwater have been impacted at the site. The impacts found include concentration of total metal concentrations above background in the soil and increased pH and chromium concentration in a possibly perched groundwater zone." (Source: TNRCC's submittal to EPA's Report on CKD, March, 1994)

FACT 77. In 1993 tests, TXI found elevated levels of lead, cadmium, chromium zinc or barium in 27 out of 32 soil tests. 15 of the soil "borings" encountered groundwater - at as little as 7.2 feet below the surface. (Source: TXI Site Investigation Report MW-3 Area December,1993)

FACT 78. Using TXI's own estimates of the amount of metals in their CKD after burning hazardous waste, there is up to 74,600 more pounds of lead, arsenic and cadmium being deposited in their CKD dump every year. (Source: TXI Materials Balance Sheet, 1991)

FACT 79. TXI's CKD dump was identified by the EPA as a site of potential damage to groundwater after studies showed hazardous pH levels and higher than background levels of lead, zinc and cadmium. In

FACT 80. In 1990, the Texas Water Commission found total lead levels in TXI's CKD of 1160 parts per million, over twice the allowable federal level for soils. In 1991, the TWC found elevated levels of arsenic and chromium and water with a pH of over 12 making it a hazardous substance. A 1992 inspection found quarry leachate with elevated levels of lead and arsenic and a Notice of Violation was issued. Also in 1992, the EPA also cited TXI with violations of federal law, including operating a hazardous waste landfill without a permit. (Source: TWC and EPA Inspection Reports, 1990-1992)

FACT 81. According to EPA's own estimates in its Report to Congress on CKD, children exposed to Cement Kiln Dust derived from the burning of hazardous waste have a greater than 94% chance of developing serum lead levels above the 10ug/dl federal standard. (Source: EPA, Report to Congress on CKD, Additional Data Available September 1994)

FACT 82. According to EPA testing, CKD from cement plants that burn hazardous wastes contain over 700 times more dioxin than CKD from non-hazardous waste burning cement plants. (Source: EPA, Report to Congress on CKD, December 1993)

FACT 83. According to EPA testing, CKD from cement plants that burn hazardous waste has as much as four times the concentrations of lead in it as CKD from non-hazardouswaste burning cement plants. 

TOXIC CEMENT

FACT 84. Home Depot, the nation's largest hardware store chain sent a memo to its suppliers concerning cement from waste-burning cement plants that stated "Specifically, impurities from the standpoint of leaching and product strength, as well as inhalation of heavy metals and chlorinated compounds during use, are questions we believe have yet to be satisfactorily answered and are of serious concern to us, and to our customers." (Source: Letter from Mark Eisen, Home Depot Environmental Marketing Manager to Home Depot Cement Products Vendors, June 28,1993)

FACT 85. The American Concrete Pressure Pipe Association has banned the use of cement made at waste-burning plants in its member's projects. (Source: Amy Porter, "Rutgers University Plans Pilot Study on Quality of Cement Made with Waste Fuel,"

FACT 86. New Braunfels, San Marcos, Austin and Crowley are among the Texas cities that have banned the use of cement made at waste-burning cement plants in their municipal projects. (Source: City Resolutions passed in 1991 and 1992)

FACT 87. In September 1994, a lawsuit has been filed on behalf of a worker in Michigan who claims to have suffered non-cancerous health effects from exposure to the dust of cement made while burning hazardous waste. (Source: Michael Wikaryasz v. LaFarge Corporation and Inland Lakes Management, complaint in Common Pleas Court, Cuyahoga County, Ohio, September, 23, 1994)

FACT 88. At least three EPA studies conclude that contaminants can leach from cement - one stating that contaminants can be leached from cement by "the presence of even mildly acidic leaching solutions (e.g. rain)." (Source: EPA, Guide to the Disposal of chemically Stabilized and Solidified Waste, September 1982; EPA, Land Disposal, Remedial Action, Incineration and Treatment of Hazardous Waste, July 1988; EPA Handbook, Remedial Action at Waste Disposal Sites, October 1985)

FACT 89. EPA has found the most harmful form of dioxin in the products of cement plants that burn hazardous waste. "(EPA's) October briefing document says that the dioxin molecule known as 2, 3, 7, 8 - TCDD, the most potent poison in the dioxin family, was only identified in samples from kilns burning hazardous wastes." (Source: Rachel's Hazardous Waste News #314, December 2, 1992)

FACT 90. A Portland Cement Association Study found that cement plants that burn hazardous waste had over 80% more chromium and 25% more lead in their cement products than cement plants that did not burn hazardous waste. (Source: J. Delles et al., Trace Metals in Cement and Kiln Dust from North American Cement Plants. Construction Technology Laboratories for Portland Cement Association, Skokie Illinois, 1992) 

ACCIDENTS8FACT 91. According to the EPA's Science Advisory Board, "Catastrophic accidents, especially near incineration sites where large quantities of liquid hazardous wastes are stored and burned, require the ability to mount rapid emergency responses....Typically, an emergency plan will need to consider the probability of chemical spills, fires and explosions, and atmospheric dispersion and exposures of chemicals, and incidences of poisonings and injuries. These plans should also include the development of population evacuation procedures." (Source: EPA Science Advisory Board, Report on the Incineration of Liquid Hazardous Wastes by the Environmental Effects, Transport and Fate Committee, 1985)

FACT 92. Texas was second in the nation in the number of toxic chemical accidents, with a total of 4,532 between 1988 and 1992. (Source: U.S. Public Interest Research Group, Associated Press, Friday August 19, 1994)

FACT 93. TXI is seeking permits to build storage tanks that will hold approximately 1,000,000 gallons of hazardous waste. This would make their plant site the largest depot of hazardous waste storage in north Texas. (Source: TXI and RCRA permit applications, filed 1989)

FACT 94. TXI

ECONOMIC GROWTH HURT

FACT 95. Waste incineration does not promote economic growth. Property values in communities host to incinerators are 38% lower than the national average. Average income in communities with existing incinerators is 15% less than the national average. (U.S. Census Data 1980)

FACT 96. "Residential Property which is found to be contaminated by toxic or hazardous material may suffer a serious decline in market value. If the property is located near a hazardous waste site, it may have a serious decline in value, or no

FACT 97. "...hazardous waste management facilities (incinerators) do not bring about industrial growth. Rather they tend to depress any area in which they are located, from the point of view of economics, public health, the environment and morale." (Source: Letter from William Sanjour, EPA office of Solid Waste and Emergency Response to Mark Woodall, May 10, 1990) 

EMISSIONS VIOLATIONS AND COMPLAINTS

FACT 98. TXI was fined $38,000 by the Texas Natural Resource Conservation Commission in April of 1995 for six violations of state air quality laws dating from 1993. Specifically, the company violated TNRCC Rule 30 TAC 101.4, 382.085 (a) and (b) by "emitting one or more air contaminants or combinations thereof, in such concentration and of such duration as were or tended to be injurious to or to adversely affect human health or welfare, animal life, vegetation or property, or as to interfere with the normal use and enjoyment of animal life, vegetation or property."(Texas Register, April 18, 1995)

FACT 99. From 1988 to 1993 TXI received 86 complaints from residents living downwind of its plumes. 53% of these were health related, 23.8% were odor related, 14.8% were smoke related and 8.2% were particulate matter, or dust related. From January to July 1994, there were six complaints, 4 he

PUBLIC OPPOSITION

FACT 100. Cement kiln incineration is opposed in principle or as practiced by a variety of organizations including Parent Teacher Associations in three states (including 12 PTAs in north Texas alone and the state PTA convention7), the American Lung Association, Clean Water Action, The National Endometriosis Society, Public Citizen, Sierra Club,Environmental Defense Fund, Greenpeace, Washington County Maryland Medical Society, La Salle County Illinois Medical Society and the Association for Responsible Thermal Treatment. In fact, no environmental or public health group supports kiln incineration.