| What Should Be Done About
the Failure of the State Implementation Plan
The Dallas-Ft.Worth “State
Implementation Plan” for smog clean-up is officially dead. A new “SIP” will
be written – either by the state legislature and TNRCC or the EPA.
When the re-writing starts, Dallas
city government should demand more from its neighbor to the South – Ellis
County. Home to almost half of all industrial smog pollution in North Texas
(Collin, Dallas, Denton, Ellis and Tarrant Counties, 1999 TNRCC state
emission inventory, latest available), Ellis County is currently in
violation of the one-hour EPA smog standard - just like Dallas County (TNRCC
Midlothian air monitor results, 1996 thru May 2002). However, because it’s
smog violations are falling through a bureaucratic crack at TNRCC and EPA,
Ellis County is not being included as a “core county” in the Dallas-
Ft.Worth clean-up plan. Same air quality violations, different treatment.
Bad policy.
Three huge cement plants just
south of the Dallas County line in Midlothian – TXI, Holcim and North Texas
Cement, emit the vast majority of industrial smog (nitrogen oxide) in Ellis
County. Their air pollution blows north into Dallas County on a regular
basis.
The smog emissions from these
three cement plants are so large that they convinced representatives of the
City of Dallas and Dallas County on the 1999/2000 North Texas Air Quality
Steering Committee to vote to require at least 50% reductions in smog
pollution from them. The TNRCC ended up only requiring a 30% reduction from
the plants. It was the only recommendation from the North Texas Steering
Committee that was not adopted by the TNRCC.
In rejecting the Steering
Committee's recommendation, the TNRCC said there was no technology available
to cement plants to let them cut more smog pollution. Turns out the TNRCC
was wrong. The truth is that the TNRCC has not required Best Available
Control Technology to be installed in the Ellis County Cement Plants as it
has in other industries. For example, power plants in Dallas County have to
cut their smog emissions
by a state-of-the-art 88%.
Contrast this with the fact that
in regards to the seven oldest cement plants/kilns in Ellis County - those
dating back to the 50's and 60's - the TNRCC has ignored best available
technology. An older plant in Michigan similar to those in Ellis County has
been able to cut emissions by approximately 80% using wet scrubbers and
other retrofitted technology, according to the plant manager. Yet the TNRCC
pretended this operating facility did not exist when it came time to write
the last SIP and required only 30% reductions from the oldest cement plants
in Ellis County.
The TNRCC has also been negligent
in regards to the newest "dry process" plants being built in Ellis County.
Documents released from the TNRCC as part of a recent open records request
show that the TNRCC's contractor for cement pollution control technology
during the SIP process in 1999/2000 ignored at least 18 cement plants in
Europe operating with advanced SNCR (selective noncatylitic reduction)
pollution control technology that is reducing smog emissions by 80% or more.
At least one of these plants is operated by Holcim - a company that also
owns an Ellis County cement plant.
If the TNRCC were to require the
state of the art pollution control technology on the Ellis County Cement
Plants the same way it is requiring it on power plants in Dallas County, we
would go from 30% reductions to at least 80% - an increase in reductions of
50% over the current SIP.
Taking data from the 1999 state
emission inventory (the last currently being made available by the TNRCC), a
cut of 80% smog emissions from the three Ellis County cement plants would
result in a total reduction of 15,191,008 pounds per year of DFW smog
pollution by merely installing pollution control equipment already being
used by the industry. That’s the equivalent of taking hundreds of thousands
of cars off the road.
As a city located directly
downwind of the Ellis County cement plants and their pollution, it is in
Dallas' self -interests to see to it that these plants reduce their
pollution. Dallas should tell the TNRCC and EPA two things when it comes to
Ellis County:
1) Require Ellis County to
officially become part of the re-written DFW SIP, and 2) Require the Ellis
County cement plants to install best available control technology to obtain
at least 80% reductions in smog pollution. |
