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TXI is Now More than
Just an Air Polluter,
It's a Target
Whether you feel "everything changed" after
September 11th or not, one thing that should have changed for DFW residents
is the perception that TXI's waste-burning cement plant in Midlothian is
only a problem because of its air pollution.
With almost a million gallons worth of storage
tanks holding up to 700 different hazardous and toxic substances, TXI has
also become the region's largest potential chemical weapon.
Only a short distance upwind of populous
southern Dallas and Tarrant County suburbs and within sight from Downtown
Big D, TXI poses a new threat to tens of thousands of local residents.
TXI has burned toxics for "fuel" in its obsolete 40 year-old industrial
cement kilns since 1987. Chemical plants, refineries and other facilities
send their hazardous waste to TXI because it's cheaper than burning it in
better regulated hazardous waste incinerators. There are approximately 16 of
these waste-burning cement plants across the country, out of a total of 120
cement plants in the U.S. TXI is the only one burning waste in Texas.
So that it would always have a ready supply
of waste to burn, TXI built its own 863,120 gallon tank farm on-site in
Midlothian. On any given day, these tanks hold poisons that could cause
illness or death to whoever breathed them in the event of a catastrophic
release.
However, unlike most other toxic chemical
facilities, TXI's threat of disaster is completely unnecessary. TXI could
return to burning natural gas or coal in its kilns and still manufacture
cement. But then it wouldn't be able to make a tidy profit on disposal fees
moonlighting as a waste incinerator.
Since 1996, large chemical facilities have been
required to file studies of what would happen if the most toxic material
they handled escaped and headed toward the most people in the quickest way.
You might have read where the EPA pulled previously public information about
these studies of chemical threats off the shelves after September for fear
of it winding up in the wrong hands. However, EPA's action to suppress that
kind of risk assessment didn't affect TXI. TXI never filed one.
The story of TXI's undone
emergency management paperwork starts back in 1990, when Congress sought to
build on the successes of the Toxic Release Inventory program that required
disclosure of toxins released into the environment by industry.
That year, legislation
amended the Clean Air Act to give EPA oversight of risk management planning
at facilities that handle extremely hazardous chemicals, including
submitting annual Risk Management Plans to EPA .
If certain "threshold
levels" for approximately 80 chemicals are exceeded, Risk Management Plans
are required. These threshold levels range from 500 to 20,000 pounds.
Information on the potential effects of an accidental release, including
so-called worst-case scenario are supposed to be included.
But as with any other
legislation, there are loopholes. The largest one exempts a facility from
submitting Emergency Plans if a regulated chemical is under one percent by
weight in a mixture with other chemicals.
Of course, TXI and other waste-burning cement
plants mix all their incoming wastes together into a kind of toxic soup
inside their own huge tanks. The specifics of the mix vary day-to-day but
are never supposed to go outside certain permitted parameters. Who makes
sure? TXI.
In addition, if, like TXI,
the plant has more than one tank, and they add up to almost a million
gallons of storage, 1% by weight equals over 16,000 gallons. Not an
insignificant amount.
To make things even more
complicated, there's an exception to the exception that states this loophole
doesn't apply to three different kinds of Toluene - chemicals TXI lists as
among those they receive for burning at Midlothian.
Besides these Toluenes,
TXI also deals in at least 17 more of the 80 chemicals that trigger
Emergency Management Plans, including Acrolein, Allyl alcohol, Arsine,
Carbon disulfide, Chloroform, Chloromethyl, Cyanogen, Ethyleneoxide,
Formaldehyde, Furan, Hydrazine, Hydrogen fluoride, Hydrofluoric acid,
Hydrogen sulfide, Methyl chlorine, Nitric Acid, Phosgene and Piperidine.
If past experience is any
indicator, a catastrophic explosion and fire at TXI's tank farm could
endanger large portions of the Metroplex. In 1995, a used tire facility
literally across the street from TXI caught fire and burned for days. The
smoke blotted out the sun in Dallas skyscrapers and could be seen all across
the I-20 corridor. Is there any doubt that the smoke from a 860,000 gallons
of burning liquefied hazardous and toxic waste at TXI could also waft into
heavily populated areas of DFW given predominately southern winds?
In 1985, EPA’s own Science
Advisory Board stated that, “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.”
So does TXI have to submit
a Risk Management Plan or not? Local EPA officials have expressed the casual
opinion that the mixture loophole allows TXI and other waste-burning cement
plants to opt out of the requirement. But not all the waste-burning cement
plants seem to think so.
Before 9-11, a quick
search of the EPA's own web site found at least three waste-burning cement
and aggregate plants that had filed Risk Management Plans - albeit sunny
ones.
Continental in Hannibal,
Missouri, Keystone in Bath, Pennsylvania and Carolina Solite in Norwood
North Carolina (which has since stopped burning waste) all stated they did
indeed store "regulated substances that could potentially (although
unlikely) be present in the regulated process above the applicable threshold
quantity" and "the potential to exceed these threshold quantities does
exist."
However, none of these
plant's worst case scenarios included a terrorist attack on the facilities
and simultaneous release of all on-site toxins.
So why did only three out
of 16 waste-burning cement /aggregate plants file emergency plans and why
isn't TXI one of those plants? You'd think in a post-attack world, somebody
in government might want to know. As with so many aspects of waste-burning
in cement plants, it will only be public pressure that brings these
shortcomings to light. TXI and the EPA would seem to prefer we all remain in
the dark. |
