Increases Predicted in Air Pollution, including 100 more tons of PM a Year
Holcim Cement’s Midlothian cement plant has requested a permit application to the Texas Commission on Environmental Quality to release an additional 2700 tons per year of Carbon Monoxide and burn 100% Petroleum Coke in its Kiln #2. Holcim estimates these change will set of federally-mandated reviews for increases in emissions of Particulate Matter (PM), Nitrogen Oxide (NOx), Sulfur Dioxide (SOx), and Carbon Monoxide (CO).
Notice of the company’s permit amendment was published in the Midlothian Mirror earlier in the month.
Holcim is one of three very large cement plants doing business just south of I-20 in Midlothian in what is the largest concentration of cement manufacturing in the U.S. The other two are TXI and Ash Grove. These are not batch plants. These are where the batch plants get their product. With annual air pollution emissions in the thousands of tons, any one of these kilns would easily be the largest “stationary” industrial source of air pollution in North Texas. Combined, they represent a mega source of air pollution for DFW.
Review of the numbers in the permit application show the company wants to scrap its current limit of a little over 4000 tons a year for Carbon Monoxide and replace it with a higher 7112 ton per year ceiling. In addition, the difference between actual emissions and proposed changes could result in 100 tons more of Particulate Matter, 260 more tons of smog-forming Nitrogen Oxide, and 1700 additional tons of Sulfur Dioxide.
Missing from the permit analysis is the impact of the changes on CO2 climate crisis pollution. Petroleum Coke is nothing but carbon. It releases a lot of CO2 when burned. Burning 100% Petroleum Coke at Holcim will significantly increase this kind of air pollution. Cement plants are already a huge source of CO2 worldwide and Texas leads the country in CO2 pollution.
Overall, it’s the largest requested air pollution increase from any of the three Midlothian kilns in a very long time. And it reveals how badly the snake-bit 20th Century Holcim plant is aging.
Holcim’s current air pollution levels are already way out of sync with the other two, newer cement plants in Midlothian, and the Holcim facility has had a long troubled history with what its owners claim is a problem with the area limestone – the same patch of limestone the other two plants use. Holcim is already releasing 14 times the amount of four major air pollutants compared to Ash Grove’s 2014 renovated plant, and three times the amount of those same pollutants as TXI. This permit amendment would make the difference even starker.
Clearly Holcim has a problem child cement plant. Since Kiln #1 opened in 1999 it’s never performed to expectation. Because it would otherwise have set off a national non-attainment area for Sulfur Dioxide, Holcim had to add scrubbers to the plant before it even opened. When Kiln #2 was added in 2000, Holcim predicted it would cut pollution in half. Instead it doubled air pollution and by EPA decree the company had to add new pollution controls and buy Downwinders at Risk an independent scientist to monitor their operations. Now Holcim is saying their longstanding plan to reduce Carbon Monoxide pollution at that second kiln just didn’t work out and they need to increase their CO “permit allowables” by over 2700 tons a year.
Even for a very large cement plant, that’s a significant increase in pollution. CO pollution is a red flag for poor combustion, which is always worrisome when you’re looking at a facility of Holcim’s size that’s burning a flame at 2400 degree flame 24/7/365. Poor combustion at a cement plant burning tires and industrial waste, as Holcim does, or even coal and Petroleum Coke, means the creation of more “Products of Incomplete Combustion,” or “PICs.”
PICs are bad news. Dioxin – the poison in Agent Orange – is a PIC but there are thousands more. Some are extremely toxic. Holcim is already releasing 168 times more CO than the newer Ash Grove plant – located just across Highway 67, and nine times more than former Bad Boy TXI. That’s a lot of potential PICs. Something isn’t right in the basic design of the plant to make it so inefficient, but instead of investing in a new plant, Holcim just wants to increase its pollution levels.
There’s a second part of Holcim’s request that’s even more disturbing. Besides the increase in CO pollution, Holcim is seeking approval from the State to burn 100% Petroleum Coke as a fuel for its Kiln #2.
Cement kilns need a cheap source of fuel. Since 1960 the Midlothian kilns have burned gas, coal, hazardous waste, tires, used oil, car inards, plastic packaging, and other “industrial wastes” to keep a flame at 2400 degrees F or hotter. But never 100% Petroleum Coke.
Pet Coke is a refinery waste high in BTU value and sulfur content. It’s very dirty. It’s basically solid carbon. In the application submitted by Holcim, the company says Particulate Matter pollution could go up by 100 tons per year. There’s also a very good chance of increases in smog-forming Nitrogen Oxides and Sulfur Dioxide pollution. Separately there’s also a significant but undocumented increase in CO2 that will occur because of Pet Coke’s composition, so this is a very bad Climate Crisis move as well.
Holcim says not to worry – most of these increases are on paper only and they’re not really changing the emissions, just “refining them.” But with the plant’s history, it’s more likely air pollution will increase, and not by a little bit.
TCEQ’s permit engineer assigned to the Holcim case says this is only a preliminary application and that the company will have to answer more questions about pollution increases, and more importantly will have to stage a “test burn” to see what the impact of burning 100% Pet Coke will actually be (under ideal conditions when everyone is looking over their shoulder). Many long time observers of the modern TCEQ under Governor Greg Abbott are skeptical any of this will happen before Holcim gets their permit however.
Because of the increased volumes of pollutants, this application will be generating an official response from Downwinders requesting at least one public meeting for a briefing on the permit and objecting to any increase in PM and NOX, insisting on test burns using 100% Pet Coke before the permit is approved, and protesting any increase in Climate Crisis pollution.
There’s two responses you can take right now to oppose Holcim’s permit amendment:
1) You can request a public meeting in Midlothian to have the TCEQ and company brief the public on the permit amendment and have the opportunity to ask questions
AND ALL LOCAL STATE REPRESENTATIVES AND SENATORS
Requests should be addressed to the Texas Commission on Environmental Quality as well as local State Representatives and Senators – not just those representing Midlothian.
TCEQ, Office of the Chief Clerk, MC-105, P.O. Box 13087 Austin, Texas 78711-3087
Texas State Senators
St. Senator Brian Birdwell/Midlothian: Brian.Birwell@senate.texas.gov, 512-463-0122
St. Senator Royce West/Southern Dallas County: firstname.lastname@example.org 512-463-0123
St. Senator Beverly Powell/ Southern Tarrant County: email@example.com 512-463-0110
Texas State Representatives
Rep. John Wray/Midlothian: firstname.lastname@example.org 972-938-9392
Rep Yvonne Davis/ Southern Dallas County: email@example.com 512-463-0598
Rep. Carl Sherman/Southern Dallas County: firstname.lastname@example.org 512-463-0953
Rep. Chris Turner/ Southern Tarrant County/Arlington: Chris.Turner@house.texas.gov 512-463-0574
Contact all of these folks individually, or you can send them and the TCEQ the same email requesting a public meeting on Holcim’s permt via Downwinders’ ClickNSend feature. Leave your own personal message too.
2) Request a Contested Case Hearing
If you feel you’ll be affected by Holcim’s new air pollution, you have a right to ask for a contested case hearing – a formal legal proceeding that sets a higher bar for Holcim to get a permit. In order to request a Contested Case hearing, you must send the TCEQ Chief Clerk:
1) YOUR NAME, or GROUP NAME
2) MAILING ADDRESS AND TEL #
3) APPLICANT’S NAME AND PERMIT #: Holcim, Air Quality Permit 8996 and PSDTX454M5
4) THIS EXACT STATEMENT: ” I/We request a contested case hearing.”
5) A DESCRIPTION OF HOW YOU WILL BE HARMED BY HOLCIM’S AIR POLLUTION
6) THE LOCATION OF YOUR HOME OR BUSINESS AND THE APPROXIMATE DISTANCE TO THE HOLCIM CEMENT PLANT TO THEM.
7) A DESCRIPTION OF HOW YOU USE THE PROPERTY AFFECTED BY HOLCIM’S AIR POLLUTION (HOME OR BUSINESS OR RECREATIONAL)
8) A LIST OF DISPUTED ISSUES
Example: 1. Any increase in PM Pollution from Holcim will be harmful to my health and enjoyment of my property, 2. There has been no evaluation of the PM, NOx, SOx, or CO emissions of burning 100% Petroleum Coke in Kiln #2, 3. There has been no evaluation of the burning 100% Petroleum Coke in Kiln #2 on increase in CO2 4. Holcim’s cement plant isn’t applying Best Practices and Best Available Control Technology for emission reductions of PM, CO, NOx, and SOx.
Send your request to the TCEQ’s Chief Clerk:
TCEQ, Office of the Chief Clerk, MC-105, P.O. Box 13087 Austin, Texas 78711-3087
Not quite two weeks ago, on Thursday October 19th, something happened to throw local air quality conditions into the red zone for most of the day.
There was a inexplicable smokey haze extending along the limestone escarpment from Midlothian to Dallas and then north to Denton, sending Particulate Matter pollution soaring to Beijing levels and ozone readings so high the whole regional average went up a part per billion. Countless downwind residents complained to officials, FaceBooked, and Tweeted about “the smell of burning plastic” enveloping their neighborhoods with the smoke, which was so thick many thought the problem was just down the street.
The 24-hour standard for Particulate Matter Pollution is 150 ug/m3. The annual standard is 12.
70 ppb is the new ozone standard.
The events took the Texas Commission on Environmental Quality completely by surprise. Commission computer forecasting had not predicted an Ozone Alert Day or warned of heavy PM pollution. Officials were playing catch-up for the rest of the day.
Now almost two weeks later nobody official knows what caused this Really Bad Air Day. Not the EPA. Not the Texas Commission on Environmental Quality. Not the DFW area citizens who breathed in the dirtiest air their lungs have seen all year.
Despite the sophisticated technology available to us in 2017, a single unexpected incident upwind of DFW can throw the entire North Texas air shed into the danger zone with no warning and no clue as to what initiated it.
Readings from state monitors were of no help until damage had already been done. As usual they were two hours or more behind in reporting. The numbers they were displaying at 12 noon were actually taken at 10 am. You had no idea what was going on in real time so that you might better protect yourself or family.
There are only three or four Particulate Matter pollution monitors in all of DFW. Even if you’d wanted to use the state’s current monitoring system to track this mystery plume, you couldn’t have done so. It doesn’t have that capability.
As inquiring reporters called, the TCEQ staff found a variety of things to blame. TCEQ suggested the smoke was from a Bastrop forest fire near Austin. But readings from monitors between Bastrop/Austin and Dallas show there was no problem south of Midlothian that day, while there was a huge problem north of there at the same time. Eyewitnesses who saw the plume on Thursday reported a thick narrow ribbon of a plume you’d see coming off a near-by source, not the sort of diffused cloud you’d expect to witness after traveling more than a hundred miles downwind. And then there’s that “burned-plastic smell.”
Then it was maybe one or more “controlled burns” in the Midlothian-Mansfield area. As it turns out, neither fire department found evidence of any permitted controlled burns in their own jurisdictions that could have cause so much pollution. Midlothian’s single permitted fire for the day was “the size of a coffee table” according to a department employee.
According to the Mansfield Fire Department “a fire” was reported to be located at Kimball Road and Hwy 287 just north of the Midlothian city limits. This is what’s at that intersection:
Please note the caution against open flames. Could a fracking site have produced the kind of particulate matter pollution and haze we saw on October 19th without methane or other kinds of pollution being released en masse as well? It doesn’t seem like it could. But what if the fracking site had been turned into a temporary waste incineration site for the day?
That’s not all. A satellite pic of the intersection and what’s around it reveals Kimball and Hwy 287 to be a kind of rogue’s gallery of potential suspects:
Besides the fracking sites you can be see in mid-drilling on this Google street level tour, the road leads to a Trinity River Authority Wastewater Treatment plant and the back door of the giant Ash Grove cement plant.
TRA is a shadowy, 60-year old regional bureaucracy that owns millions of acres of land, reservoirs, landfills, and wastewater-treatment facilities. It’s been in environmental hot water before. Wastewater treatment accumulates a lot of solids, and the TRA handles a lot of trash. It’s not inconceivable that it had something to do with the October 19th incident by thinking it could get away with an open burn on its own property.
Ditto for Ash Grove. Like the other two cement plants in Midlothian, Ash Grove’s kiln is allowed to burn industrial waste, including used oil, tires and plastics – remember the oft-cited “smell of burning plastic” citizens reported on the 19th? Waste-burning cement plants have had their wastes combust and cause huge fires before and each plant has its own emergency response crew which might be able to put out a fire without calling Midlothian.
There’s no proof Ash Grove, TRA or the fracking sites were the cause of the October 19th public health disaster. But there’s also no proof yet they didn’t cause the problem.
The truth is: there’s no official explanation for what made the air so dangerous to breathe on October 19th .
More truth: As of Friday, October 27th the TECQ had not even opened an official investigation into this matter – which again, sent Particulate Matter pollution to levels not seen outside SE Asia and single-handedly raised the regional ozone level.
This is why Downwinders at Risk filed the first of what we’re sure will be a series of Texas Open Record Act requests last Friday seeking:
“Any and all printed or electronic documents and electronic media containing information concerning or related to ozone, particulate matter and/or haze air pollution readings and levels in the Dallas-Forth Worth non-attainment area on Thursday, October 19th 2017, including official ozone action warnings issued, complaints filed about air quality in the Dallas-Fort Worth area that day, photographs, satellite images, computer modeling, as well as all material related to any questions, inquiries, or investigations about air quality in DFW on October 19th anyone in the TCEQ, or contracted by TCEQ has been tasked to perform since October 19th or is still performing currently, and e-mails, letters, reports, telephone logs and notes, memos and all other material about October 19th air quality from 6 am Tuesday October 19th to Wednesday October 25th, 2017.”
TCEQ has until November 10th to respond. We’ll keep you posted.
In the meantime, this episode becomes Exhibit A in why DFW needs to catch-up with other metro areas and build its own network of high tech air quality sensors.
If such a grid had been in place, there would have been a real time warning of the PM and ozone pollution being generated shortly after the it started. There would have been a way to locate the source of the pollution right away and do something about it before it got worse, and there would have been a way to predict the plume’s course and warn those in its path before it got there – not two hours after it arrived.
In this sense a modern sensor grid is actually a pollution prevention device, an investigative tool, and an early warning system all rolled into one.
In a metropolitan area that’s been out of compliance with the Clean air Act for 27 years and counting over 14 million lungs are being held hostage by a state air quality monitoring system left over from the 1990’s. It’s being maintained by a state agency that’s run by polluters, officially thinks smog isn’t bad for you, and is cutting its air monitoring budget.
There’s no desire in Austin to update this obsolete system and no money to do so. If DFW officials want to utilize 21st Century technology to help them clean their air, they’re going to have to build their own network of air monitors – exactly the proposal the DFW Air Research Consortium was trying to get funded with a National Science Foundation grant. Close, but no cigar.
Without the NSF grant, local officials are going to need to get creative. Are there private businesses who might want to sponsor an app that could tell give you useful air quality info in exchange for naming rights: “Brought to you by the Nissan Leaf DFW Clean Air Network.” Are there local foundations that would contribute? What about local high-tech billionaire Mark Cuban? For less than a million bucks, DFW could have 500 Particulate Matter sensors that would be capable of of pinpointing a problem down to the street address.
Baltimore, Chicago, Chattanooga, Louisville, L.A. , Oakland, and Lafayette, Louisiana are all way ahead of DFW in building out their own local dense grid of air sensors. They’ve done it with a combination of private, government and academic know-how and financing.
We have as much, or more technical expertise and money than any of those locales and we should have more incentive given our chronic air pollution problem. There’s no reason we can’t build our own modern, more protective, more useful way of monitoring air pollution – even if the state isn’t interested. Not only can we do it, but in light of the events of October 19th, it should be considered a necessary act of public health self-defense.
Anti-Litter Group “Keep America Beautiful” Teams-Up with Dow and Hefty to Burn Plastic Bags Full of Plastic Garbage in Cement Kilns
And They Want To Do It Here…
We’ve been warning you for a while that garbage burning was coming to North Texas one way or another.
What we didn’t anticipate was that “Keep America Beautiful” would bring it.
That’s right. The same group that gave you Oscar “Iron Eyes” Cody crying over litter is now prepared to make your own eyes water and sting from the air pollution it wants to encourage by burning municipal solid waste, especially “hard-to-recycle” plastics.
Touting bright orange “energy bags” as a quick and easy alternative to throwing those plastics away, a news release issued by the Keep America Beautiful folks, your friends at Dow Chemical, and Reynolds, the makers of “Hefty” trash bags, claims they’re “a convenient way to collect plastic materials that would otherwise end up in the landfill and offers a platform to promote positive behaviors to prevent this material from being wasted.”
What they don’t tout as much is their alternative to throwing these plastics into a landfill – throwing them into a furnace.
As long as cement kilns need a high-temperature flame to make their product, they have large energy costs. Typically, 30% or more of the costs of running a cement plant is in buying the flammable materials necessary to keep that flame lit.
History has taught us that cement kiln operators will burn anything, including the kitchen sink, if they think it will help reduce those high fuel costs.
Kiln flames in Texas used to be powered by natural gas exclusively. Then it was coal. Then it was hazardous waste and coal. Then industrial wastes. And now municipal solid wastes. In bright orange plastic bags.
Cement plants don’t have to pay for the wastes, now termed “fuel,” for regulatory loophole purposes. In fact, because it’s now a “fuel,” they often get the waste for free or even get paid to burn it. It becomes a new center of profit in the company besides making cement. Maybe even more important. In the 1990’s, there were plenty of rumors about how the TXI cement plant in Midlothian would burn a lot of hazardous waste they got paid a handsome fee to take, but not have much cement product to show for it.
While garbage burning cement kilns have been on the rise in the developing world, the practice hasn’t caught on in the U.S.
Dow’s and Keep America Beautiful’s friendly neighborhood “Energy bags” are a way to jump start it.
This is already happening in Omaha, where 8,500 homes have filled 13,000 “Hefty Energy Bags” since the program’s launch in October. That’s resulted in more than 13,000 pounds of plastics being burned in a near-by Ash Grove cement kiln. They’re so excited about burning plastics at Keep America Beautiful that they’re not only endorsing the practice, they want to bring it to a cement kiln near you.
At a news conference to announce the offering of cash money grants to local communities who wanted to try the option, they unveiled a contiguous states map of the US where they’d like to see the “energy bag” concept implemented. The approximately 50 locations on the map identified by a red (not orange?) star are almost all sites adjacent to large cement plants – including Midlothian, immediately south of the Dallas and Tarrant Counties line, and home of the largest concentration of cement manufacturing in the nation.
Local candidates for eager participation in the project include TXI, the cement plant that burned hazardous waste by the thousands of tons from 1987 to 2008, Holcim, which has sought permits to burn carpet scraps and shingles, and Ash Grove, the same operator as the one burning Omaha’s plastic bags now.
BURNING PLASTIC IS BAD FOR PUBLIC HEALTH AND PUBLIC POLICY
1. It replaces real recycling with burning.
Once you have a hungry garbage burner, you have to keep feeding it with more and more garbage, decreasing the market for real recycling.
This is already happening with tires. There are good tire recycling programs that can’t stay afloat because local governments have promised the local cement kilns a certain volume every year.
2. It gives an incentive to the plastics industry keep to just making plastics that you can’t recycle.
Burning plastic garbage is like a relief valve on the growing piles of “hard to recycle” plastics that industry is producing. Just throw it in a bag and send it to the kiln. Out of sight, out of mind. There’s no question it reduces the percentage of plastics going to landfill…only to increase the percentage of plastic going into your lungs.
The real answer is to reduce and quit producing those “hard-to-recycle” plastics, not giving them a cheap way to get out of doing so.
3. Burning plastic produces lots of toxic air pollution – and all of DFW is downwind of Midlothian
Burning plastics produces toxic air pollution, a percentage of which escapes the smokestack and ends up in the air you breathe, the soil in your garden, and the food you eat and drink. Specifically, burning plastic creates lots of Dioxins and Furans – the same ingredients that made Agent Orange so toxic. The same poisons that made the State of Missouri evacuate the town of Times Beach in 1983.
Burning plastic also releases metals into the air, like cadmium and lead.
Other chemicals released while burning plastics include benzo(a)pyrene (BAP) and polyaromatic hydrocarbons (PAHs), which have both been shown to cause cancer. If plastic film or containers are contaminated with pesticides or other harmful substances, those will also be released into the air. If plastics are burned with other materials, whole new toxic chemicals may be created from the interaction of the different substances.
But wait! Don’t you want to divert more garbage from going to landfills?
Yes you do, but by eliminating, reducing and recycling the garbage – not taking a match to it.
Landfills are nasty things. They’re big and smelly and they leak. Sometimes they leak and contaminate ground and surface water. But these days you usually can trace the plume of those leaks and contain them before they get in drinking water.
On the other hand, once a piece of dioxin-contaminated soot is shot through a smokestack into the atmosphere, you have no idea where it’s going. You’re turning the whole sky into a landfill, full of solid and gaseous residues of refuse. What you didn’t want to drink, you’re now breathing. That’s the opposite of progress.
Taking a look at the Board of Directors for Keep America Beautiful, it’s no wonder they have a soft spot in their heart for large plastics manufacturers. They have not one, but two members from DOW, who, we are sure, thought this was a splendid idea.
Howard Ungerleider is Vice Chairman and Chief Financial Officer of Dow, and Greg Jozwiak is the Business President for the Elastomers and Electrical and Telecommunications businesses for the company. Prior to assuming his current role, he served as North America Commercial Vice President for the Packaging & Specialty Plastics business. Hmmmm.
But wait, there’s more! KAB has a board guaranteed to offend just about everyone. Not content with two Dow executives, it also has two Nestle Corporation members, a representative of Waste Management Inc., McDonalds, Keurig, Anheuser-Busch, and Phillip Morris – yes, that Phillip Morris.
“PEOPLE START POLLUTION. PEOPLE CAN STOP IT.”
Those are the words, spoken in a deep baritone by William “Cannon” Conrad, that ended that famous 1971 Keep America Beautiful commercial in honor of Earth Day. They ring as true now as then.
And so, people, we’re asking you to take action to discourage this kind of BAD IDEA from ever coming-up at a Keep America Beautiful board meeting again – send an email to their new Chair, Helen Lowman.
Ms. Lowman is a former FEMA and Peace Corps executive in the Obama Administration. She’s from Texas, worked at TCEQ, and graduated from Austin College…. So maybe messages from her fellow Texans will have more of an impact.
TELL KEEP AMERICA BEAUTIFUL’s NEW CHAIR YOU DON’T WANT TO BREATHE TOXIC AIR POLLUTION FORM BURNING PLASTICS
And if you want to leave a public message for the group too, here’s the group’s FaceBook site.
Other citizens groups, including some national alliances and networks are gearing up to take on this latest proof that all wastes, no matter how toxic, roll downhill to cement kilns eventually.
Meanwhile, Downwinders is taking the lead and beginning the push back we hope buries this project in the bright orange trash heap of history. Join us in not just saying “No,” but “Hell No.” Send that email now and then find two other people that will do the same. Thanks.
(Half of these people represent industry. Half are environmentalists. Can't tell which ones? That's a good thing.)
Should a bag of concrete be like an organic banana or a new chair made out of recycled wood and get "certified" as being responsibly-sourced, or "sustainable?" And if so, what's the criteria for making such a judgment, and who's making it?
Those are the complicated questions at the heart of a new worldwide initiative by the concrete/cement industry to come up with a way to sell its products in a more environmentally-friendly way.
After a couple of years of working on a scoring scheme, the mostly European-based intra-company group (LaFarge/Holcim, Heidelburg, CEMEX) charged with designing the system was ready to unveil it to the international environmental community for the first time in mid-July at a small meeting in Gland, Switzerland, headquarters of the International Union for the Conservation of Nature, whose staff facilitated the review process. IUCN had performed the same function for the aluminum industry when it went through a similar "green" self-examination.
Nine different environmental groups from at least seven different countries (Britain, Bulgaria, China, India, Lebanon, Switzerland) spent three days assessing and critiquing the industry's proposal – including the lone representative from the U.S., Downwinders at Risk's Jim Schermbeck. Participants not only met during the day, but ate together, and stayed in the same lone hotel in the small, outlying suburb of Geneva. Inside the meeting room, discussions were often frank, funny, and awkward. Outside, conversations ran the gamut, from architecture, to vacation trips, to Texas BBQ.
It's not a surprise that the concrete/cement business wants its relatively messy business to be seen through green-tinted glasses. Old timers will recall the burning of hazardous waste in Midlothian cement plants was relabeled "recycling" in the 1980's and 90's.
But this time around, the pressure is not necessarily to greenwash the transformation of a cement kiln into a waste incinerator, but to give an environmental patina to the final product, concrete, so that it can compete in the marketplace with building materials that already have their own green certification schemes up and running.
In other words, there appears to be new market pressure on the industry to "go green." Wood and Aluminum all now have their own systems for doing so. Concrete/Cement is lagging behind because it can't point to such a system. They want everyone from a construction site manager to a do-it-yourselfer to ask for "certified concrete" in the same way customers want wood that wasn't cut from a rainforest habitat, and aluminum made with Bauxite that wasn't mined at the expense of indigenous peoples.
Congratulations. Consumer demand for green products is so great that even the conservative cement/concrete industry feels the need to respond.
But that's also not news to North Texans. Certainly one reason Downwinders had a seat at the table in Switzerland was our pioneering Green Cement campaign of 2006-2011 which used government procurement policies to reward less polluting Midlothian cement kilns and punish the dirtier plants. That was the first time the marketplace for cement had been used toward greener ends in the US.
While that local effort looked exclusively at the differences in air pollution impacts from the Midlothian cement kilns, this new initiative starts at the limestone quarry, includes the aggregate industry (sand and gravel) goes through the cement kiln, and then continues all the way to the concrete batch plant and the bag of Sakrete at the store. It looks at impacts to water supply and quality, air quality, energy use, climate change, and local populations at each of these stops along the product cycle.
Much of the energy behind the initiative seems to come from a new generation of European industry representatives who've grown up with a different sensibility that takes green values for granted. More than one environmentalist noted a more open and questioning tone to the back and forth conversations. Whether this new attitude can be sustained and allowed to flow into real policy changes, is of course, the acid test of this first round, which must be finished for a pitch to the CEOs of the major industry players in December. Apparently the bosses are not entirely sold on the idea of needing such a certification at all, and, at times the whole idea had the air of being a kind of end-run around the Establishment by some Young Turks, albeit, corporately-backed.
And there are some very large challenges that could sabotage any good intentions, primarily, the continued reliance on burning wastes for the substantial fuel needs of a cement kiln. As much as kilns have modernized, making cement still involves cooking rock at very high temperatures provided by a very hot, continuous flame. Something has to fuel that flame day after day, year after year. Just buying the fuel for that flame represents as much as 60% of the operating costs of a cement plant.
This is why companies are always looking for ways to cut those energy costs: by turning themselves into incinerators and charging generators to burn their toxic wastes, by getting subsidies from government to burn wastes like tires, by getting refuse from other industries which would otherwise have to pay to have them hauled away. In terms of large PR problems, none loom larger than the inherent one that goes with the introduction of burning wastes in the local kiln. That's how Downwinders got our start.
But because of the volume of fuel needed as well as the required high temperatures, there are only so many kinds of things a kiln can practically burn. Midlothian kilns began by burning natural gas. If you're only looking at the end result of the flame, and not how the gas got here, it's still probably the cleanest source of fuel. Then there's coal, which is a no-go fuel in 2016 for all kinds of reasons. After that you get to wastes. Even if it doesn't have a permit to burn "hazardous" wastes, a kiln still can burn things like carpet pieces, plastics, shingles, and car "fluff." These are all materials that can release toxic air pollution when burned. Finally there's biomass – wood refuse, agricultural waste, or fuel crops themselves like sawgrass. Originally supported universally by environmentalists, these choices now have climate consequences that make them less desirable.
These are not easy choices for industry….or environmentalists. Schermbeck made the offer to industry to sit down and work on an agreed "hierarchy" of wastes that would establish minimum high BTU value and low toxicity levels, as the group had done over a decade ago with TXI in a private mediation process that never panned out, but showed vast differences in fuel characteristics. At last word, the offer was being mulled over by industry along with all the other suggestions made by environmentalists. By October we should know how first round of assessment has changed the scheme – or not. Then another round of feedback from the environmental community, and a final decision by the end of the year.
At stake is the potential to connect environmental progress and profit-making within one of the most environmentally-disruptive industries around. To establish performance floors, raise best practices, set new precedents. There are large risks and opportunities for both sides.
Besides being close to the corporate headquarters of most of the major companies invovled, and home of the IUCN, Switizerland seemed the appropriate place for this first-time gathering for another reason. At the end, everyone arrived at as if on the edge of a metaphorical mountain precipice with a sizable, but not insurmountable gap separating where the industry is now, from where it needed to be. Whether that gap can be bridged any time soon remains to be seen. But the meeting in Gland was a good keystone to put in place for any future span designed for the job.
Cement plants are among the world's largest sources of CO2. In order to reduce their carbon footprints, either voluntarily or to comply with new environmental regulations, as well as make a buck, owners are trying out different strategies to turn their Greenhouse Gases into just plain green cash.
As far as we can tell, the "SkyMine" pilot-project announced for San Antonio's Capital Aggregates Cement Plant is still on schedule for operation later this year. Employing 50 people, the first-of-its-kind facility will convert the cement plant's carbon dioxide into baking soda and hydrochloric acid that's aimed at oil and gas field use.
Now comes word that a LaFarge Cement Plant in Canada is hooking up with a fuel cell company to make a slightly more progressive product from its GHGs:
"Mantra Energy Alternatives has struck a deal with Lafarge Canada to deploy an electrochemical reduction technology at Lafarge’s No. 9 Road cement plant.
“This will be the first pilot plant of its kind in the world,” said Mantra’s vice-president Patrick Dodd in a press release.
On paper, the technology would convert carbon dioxide, considered the most prolific greenhouse gas, into useful chemicals like formic acid and formate salts. The pilot plant would convert 100 kilograms per day of carbon dioxide emitted from the local cement plant into concentrated formate salts, which sell for about $1,500 per tonne.
Mantra is eying the formic acid for use in its patented fuel cells, which it bills as a significantly less expensive fuel cell with greater power density."
Granted, the manufacturing of oil and gas chemicals sounds more likely for one of the three huge Midlothian cement plants to attempt than diving into the alternative energy business, but at least it's something. The end products can change and adapt but these projects begin to put the infrastructure of a supply and demand system in place while seeing potentially large decreases in CO2 output. In 2014 America, the fastest way to get reductions in GHGs is to make it profitable to do so. These experiments pave the way for that to happen.
There's no question that the TX/ Martin-Marietta, Holcim and Ash Grove cement plants are the largest stationary sources of CO2 in North Texas, or that together, they form a huge GHG hotspot. All the old coal-fired power plants that would have challenged them have been shuddered or converted to gas.
While (forced) modernization at all three plants like the conversion from wet to dry kiln technology has brought all emission totals down, particularly CO2, the fact remains that the huge scale of operations in Midlothian means there's no other facilities that churn it out as much. And yet not one creative idea for how to reduce those huge local emissions has been announced from any of those companies. You can't just use the Texas excuse because the San Antonio experiment is happening despite no immediate government mandate, especially on existing facilities. And you might think that the first company to do so would receive some needed good PR. But nope.
This has been another chapter of "Why Don't We See This in Midlothian?"
There was a great deal of official news fluttering last Thursday when the EPA and Department of Justice announced a national settlement with Kansas-City based Ash Grove Cement that confirmed the company's Midlothian plant, site of The Last Wet Kilns in Texas™, would shut down and covert to one large dry process kiln by September of next year. Both dailies reported like it was 1999, with front page headlines and lots of column inches (ask your parents).
But the newsworthy part of last week's developments was not that Ash Grove was converting its wet kilns to a dry kiln. In February of last year, Downwinders at Risk reported that the company was seeking a permit from the Texas Commission on Environmental Quality to do just that. The Star-Telegram, bless their hearts, even wrote a story about it. Ash Grove's planned conversion was so widely-known that it was the subject of Midlothian Rotary Club meeting speeches this last Spring. So, you know, not news.
It wasn't news because those new national EPA air pollution rules for cement plants that we all drove out to DFW Airport in 2009 to testify in favor of and then to Arlington last year to defend, were expected to put the final nail in the coffin of Ash Grove's wet kilns by the time they took effect in September 2013. TCEQ granted the company a lame one-year extension to the 2013 deadline, but by September 2014, it was pretty clear that Ash Grove's Midlothian wet kilns would have to be converted or replaced to meet those new EPA standards coming down the pike. That's why last year's permit application for the conversion wasn't a surprise, but a confirmation.
And then the Obama Administration decided to stop the standards from coming down the pike. Just as those rules and that 2013 deadline was about to be signed into law, the President changed his mind and put them on hold. His EPA weakened the air pollution standards as proposed and delayed the deadline until 2015 or later – against overwhelming public opposition. All of a sudden, that 2014 deadline for an Ash Grove conversion looked to be in trouble. Would The Last Wet kilns in Texas™ just keep chugging along?
But what do you know? As part of that national settlement announced last Thursday, Ash Grove committed to the government to make the conversion and run the new dry kiln starting in….September 2014, or the original date of dry kiln conversion before the Obama u-turn on the new rules. What a coincidence!
So what was REALLY newsworthy about last week's announcement was that the national EPA managed not to screw-up a very good thing that its now-abandoned tougher rules were already putting in motion on the ground in Midlothian. Lucky us, huh?
The luck had some help from Downwinders. We knew the EPA was looking at Ash Grove for the kind of national enforcement settlement it had cut with LaFarge and other cement companies as part of its multi-year spotlight on the industry. We knew that the former Regional Counsel for the EPA office in Dallas, Larry Starfield, who spent decades dealing with all three Midlothian cement plants, was now in DC as EPA Deputy Enforcement Director, and probably in line to sign-off on any agreement. And we knew the original 2014 deadline for Ash Grove's conversion was in trouble with the Administration's reversal on the new air pollution standards.
We made inquiries, We made pitches. If Ash Grove were the subject of such a national enforcement effort, would it be possible for EPA to please consider requiring Ash Grove's Midlothian plant to firmly commit to its 2014 conversion deadline as part of any settlement? Turns out, it was possible.
How likely would it have been without our intervention? Best not to ask. But if you think, as we do, that our showing-up and making the case made a difference in securing progress that was in danger of being further delayed, here's the tip jar.
So yea for our side, although the victory seems a little less satisfying than what it should be when you know it's simply maintaining the status quo. Still, it's better than another couple of years of pollution from the area's dirtiest smokestacks.
$2.5 million in fines plays well in headlines until you realize how small it is compared to company's annual profits (almost $900 million n 2010). Beside the fines, nine Ash Grove plants will have to better control their smog-causing Nitrogen Oxide, Particulate Matter and Sulfur Dioxide pollution better, including the installation of Selective Non-Catalytic Reduction, or SNCR technology. The Midlothian plant was already scheduled to have this included in its conversion in order to meet those now-abandoned new air pollution standards. There's also a strong possibility that Ash Grove's other wet kilns will follow Midlothian's lead and also be converted to dry kiln technology.
Unfortunately, EPA didn't require any new testing of Selective Catalytic Reduction Technology, as it had in previously announced cement company settlements. SCR is twice as effective at cutting cement plant pollution as SNCR and has been used on kilns in Europe for over a decade. It's state of the art. But it's still not required in the US, although the results from two EPA-mandated pilot tests on kilns in the Midwest are due this year. One good thing about Ash Grove's conversion is that the plants can no longer use their continued operation of obsolete wet kilns as an excuse not to install modern equipment like SCR as it has in the past – although we know they'll find a new excuse now.
Here's the consent decree if you want to read all the details of the settlement. And here's the original complaint, which chronicles the alleged misdeeds of the company, plant by plant, including the sins of the Midlothian facility. A lot of the legal case depends on parts of the Clean Air Act that says any "major modification" to a plant must not increase pollution. Ash Grove ignored this law. Repeatedly. Over the last 20 years. According to the complaint, the violations in Midlothian originally occurred in 1995. That's right, it's taken almost 20 years for EPA to enforce a basic Clean Air Act violation.
"Kilns 1, 2, and 3 at Ash Grove's facility in Midlothian, Texas: 1) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 1 to the coal mill and performed a project to enable Kiln 1 to burn waste whole tires as a fuel source; 2) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 2 to the coal mill and performed a project to enable Kiln 2 to burn waste whole tires as a fuel source; and 3) in or around 1995, Ash Grove performed a project to re-route ductwork that transports hot air from Midlothian Kiln 3 to the coal mill and performed a project to enable Kiln 3 to burn waste whole tires as a fuel source."
Downwinders has always argued that tire-burning increases emissions, not decreases them as the industry maintains. We were saying this in 1995 as these illegal changes were taking place and Ash Grove officials were saying what a great air pollution control strategy it was to burn whole tires.
The implications of these kind of very common violations hang heavy over the current industry transition to new and more exotic industrial wastes being burned in kilns, some of which make tires look like Grade-A fuel oil. Plastics, shingles, car parts. All of the Midlothian cement plant are now burning things that they shouldn't be with no more assurance they aren't breaking the law than there was in 1995 when they were changing fuels then. But don't worry, EPA's on the case and you can expect any such violations to be prosecuted in….2033.
Everything in italics and "quotation marks" below is a direct quote from the latest chapter of the ATSDR's (Agency for Disease Registry and Toxic Substances) "health consultation" on the impact of certain kinds of industrial air pollution on the local population.
You should take five minutes to glance over the sentences. They've taken a better part of a decade and a great deal of citizen persistence to make it to print. You can read them now only because of a petition to ATSDR by local Midlothian residents, spearheaded by Sal and Grace Mier in 2005, prompted the Agency to get involved.
They're also rarer than hen's teeth. Because the words actually come together in sentences to conclude human health was likely harmed by the pollution from Midlothian's three cement plants and steel mill, as well as recommend decreasing that pollution.
Among grassroots activists, ATSDR has a notorious reputation for issuing reports that are "inconclusive by design." The joke is that the agency never met a facility it couldn't learn to live with. And sure enough, previous chapters in this saga have disappointed. Just two years ago, ASTDR's shoddy work in investigating health impacts in Midlothian and elsewhere across the country was the subject of a Congressional hearing.
These ATSDR reports generate no new data. Instead, they are retrospective looks back at the available sampling/monitoring information and a piecing together of possible exposure paths and levels. As such, they're only as good as the data they can digest. In Midlothian's case, that means they're completely dependent on state monitoring – criticized by citizens for years as being inadequate. Nevertheless, with this latest report, citizens have been somewhat vindicated because of what even that inferior sampling revealed.
The health impacts described in this latest report are also limited to what are called "Criteria Pollutants" – old school substances like lead, soot, sulfur dioxide, and ozone that have been regulated by the Clean Air Act for decades. They do not apply to more exotic kinds of air pollution like endocrine disruptors, which there's little or no monitoring for at all.
So there are a lot of missing pieces, but the ATSDR's conclusions and recommendations have an impact on your lungs and maybe your own local fight, even if you don't have a Midlothian zip code. For the first time a federal agency known to avoid coming to any conclusion about anything was forced to say that human health was adversely affected by the operations of industry in Midlothian.
There's a public meeting on this report on December 6th from 7 to 8:30 pm at the Midlothian Conference Center.
Health Consultation/Assessing the Public Health Implications of the Criteria (NAAQS) Air Pollutants and Hydrogen Sulfide MIDLOTHIAN AREA AIR QUALITY MIDLOTHIAN, ELLIS COUNTY, TEXAS
NOVEMBER 16, 2012 U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
Agency for Toxic Substances and Disease Registry
Division of Community Health Investigations
"Texas Commission on Environmental Quality (TCEQ) should take actions to reduce future SO2 emissions from TXI to prevent harmful exposures."
"TCEQ should take actions to reduce future PM2.5 emissions from TXI and Gerdau to prevent harmful exposures."
"TCEQ should continue efforts to reduce regional ozone exposures."
"TCEQ should insure that levels of these air pollutants do not increase to levels of concern in the future."
"TCEQ should conduct ambient air monitoring to characterize exposures to persons located downwind of the Ash Grove and Holcim facilities and take actions to reduce SO2 emissions from these facilities if harmful exposures are indicated."
"TCEQ should conduct appropriate ambient air monitoring to characterize exposures to persons located downwind of the Ash Grove and Holcim facilities and take actions to reduce PM2.5 emissions from these facilities if harmful exposures are indicated. In addition, particulate matter monitoring is needed in residential areas that are in immediate proximity to the facilities’ limestone quarries."
"In ATSDR’s judgment, one notable gap in monitor placement is the lack of monitoring data for residential neighborhoods in immediate proximity to the four industrial facilities, where fugitive emissions (those not accounted for in stack emissions) likely have the greatest air quality impacts."
Human health was likely harmed, and is still threatened by industrial pollution from Midlothian
From Sulfur Dioxide:
"Breathing air contaminated with sulfur dioxide (downwind of TXI's cement plant and the Ameristeel steel mill) for short periods could have harmed the health of sensitive individuals.…ATSDR cannot determine if harmful exposures to SO2 have been occurring downwind of the Holcim and Ash Grove facilities."
"All 24-hour values in Midlothian were lower than EPA’s former standard. However, the World Health Organization’s health comparable guideline is 8 ppb (WHO, 2006). This value was exceeded at both the Midlothian Tower and Old Fort Worth Road stations in most years of monitoring through 2008…"
"Overall, in the years 1999 to 2001, Old Fort Worth Road (monitoring site north of TXI) ranked among the stations with the highest 24-hour average sulfur dioxide concentrations in the state. As sulfur dioxide emissions from TXI Operations decreased in following years, so did the measured concentrations at this station."
From Particulate Matter, or Soot:
"Public health concern is warranted for adverse health effects from long-term exposure to PM 2.5 in Cement Valley"
"In the past (1996–2008), annual average PM 2.5 levels measured were just below the range of concentration proposed by EPA for lowering the annual average standard…Moreover, many of the annual average PM 2.5 concentrations were above the more conservative WHO health guideline (10 μg/m3)."
"No PM 2.5 monitoring data are available to evaluate exposures downwind of the Ash Grove facility. Furthermore, although annual average PM2.5 levels detected at the Holcim monitor indicate possible harmful levels…."
"We estimated that annual average PM2.5 levels in the vicinity of the Gerdau Ameristeel monitor, from 1996 to 1998, could have ranged from about 22.6 to 26.4 μg/m3, which is above both the current and proposed EPA standard. Using EPA’s approach, the 3-year average level might have been above the NAAQS standard of 15 μg/m3 for these years in the vicinity of the Gerdau Ameristeel monitor. Applying this same approach to annual average PM10 data from other monitors suggests that PM 2.5 levels could have been close to the current and proposed PM2.5 standard, especially for the Wyatt Road, Old Fort Worth Road, Gorman Road, and Midlothian Tower monitors."
"Consistent with the other pollutants discussed earlier, the estimated annual PM 2.5 emissions listed for these facilities are among the highest for Ellis County and also rank high among industrial sources statewide."
"Past lead air exposures during the period 1993 to 1998, in a localized area just north of the Gerdau Ameristeel fence line, could have harmed the health of children who resided or frequently played in this area….In the mid-1990s, the lead levels measured in this area ranked among the highest lead concentrations measured statewide."
"Scientific studies indicate that breathing air containing ozone at concentrations similar to those detected in Midlothian can reduce lung function and increase respiratory symptoms, thereby aggravating asthma or other respiratory conditions. Ozone exposure also has been associated with increased susceptibility to respiratory infections, medication use by persons with asthma, doctor’s visits, and emergency department and hospital admissions for individuals with respiratory disease. Ozone exposure also might contribute to premature death, especially in people with heart and lung disease. School absenteeism and cardiac-related effects may occur, and persons with asthma might experience greater and more serious responses to ozone that last longer than responses among people without asthma."
"The Midlothian Tower site recorded ozone concentrations above the level of the NAAQS for several years (TCEQ, 2011b), and the Old Fort Worth Road site has been measuring ozone concentrations close to the level of the NAAQS. Based on the data from both monitors, from August 1997 to September 2011, the 8-hour EPA ozone standard has been exceeded 236 times."
From Breathing Multiple Pollutants:
"ATSDR believes that sufficient information exists to warrant concern for multiple air pollutant exposures to sensitive individuals, especially in the past….The ability of the scientific community to fully and quantitatively evaluate the health effects from the mixture of air pollutants people are exposed to is at least ten years away (Mauderly et al., 2010)……The current state of the science limits our ability to make definitive conclusions on the significance of simultaneous exposures to multiple criteria air pollutants. ATSDR’s conclusions are based on our best professional judgment related to our understanding of the possible harmful effects of air pollutant exposures in Midlothian and our interpretation of the current scientific literature; therefore, these conclusions are presented with some uncertainty."
From New Production:
"Reductions in SO2 levels in Cement Valley have occurred since late 2008 resulting in exposures to both sensitive individuals and the general public that are not expected to be harmful. These reductions may be caused, in part, by declining production levels at local industrial facilities. Future harmful exposures in Cement Valley could occur if production rises to at least previous levels and actions are not taken to reduce SO2 emissions."
Regulatory "Safe Levels" Very Often Aren't
"Past SO2 exposures were not above the Environmental Protection Agency (EPA) standard in place at that time but were above the current standard."
"Past lead air exposures were not above the EPA standard at that time but were above the current standard.…The scientific community now believes that the current standard (15 μg/m3) for fine PM (measured by PM2.5) is a better indicator of possible long-term health effects from PM exposures than was the former EPA annual average standard for PM10 (EPA, 2006b)."
It's always a good darkly-comic read when fierce opponents of clean air take credit for progress even while they're still fighting against it. So get ready from some really twisted pretzel logic as you tackle the official and severely anti-climatic Ash Grove press release that announces the 2-year, $136 million effort to convert the Last Wet Kilns in Texas™ to dry kiln technology, eliminating hundreds of thousands of tons of air pollution by 2014.
This news was first broken by us last January, then Ash Grove applied for the state permit it needed (w/o having to be bothered with public notice or comment), and then again over a week ago when we pointed out they'd ink the engineering contract. Nevertheless, we'll leave it up to the company to have the belated last word. But you're not going to find any mention of Downwinders' seven-year "Green Cement Campaign," or the more than a dozen local governments that overwhelmingly voted for procurement policies that explicitly said they were not buying wet kiln cement because it produced too much air pollution. Or the lawsuit that Ash Grove eventually was forced to file when they lost a 5-0 vote over such a procurement policy at the Tarrant County Commissioners Court. Or how Downwinders successfully intervened last year to protect those procurement policies when Dallas and Arlington were thinking about ditching them over that Ash Grove lawsuit. No, Charles Sunderland the Third and Company would rather drink lye than give us our due.
But the press release does cite the "U.S. Environmental Protection Agency’s (EPA) portland cement National Emissions Standards for Hazardous Air Pollutants (NESHAP) rule, which are scheduled to take effect in Sept. 2013," as a determining factor in the modernization.
That would be the same standard that over 200 local residents supported in-person throughout a day-long hearing at DFW airport in 2008. It was the largest, best-attended hearing on the rules that EPA hosted that year, including stops in L.A. and Washington D.C. , capping over a decade of organized support from Downwinders at Risk. No other single grassroots group did more for so long to make sure those rules got approved because no other group was faced with such a concentration of old, dirty wet kilns that we knew would have to modernize to conform to them. By linking their decision to the NESHAP standard, the company is at least acknowledging a large factor that Downwinders had a large impact on. But the comedy of the Ash Grove press release lies not in what it leaves out, but what it crams in – toasts to its success from all the elected officials who worked do diligently to destroy the NESHAP rule and, or thwart our Green Cement Campaign.
“My colleagues will be delighted, as I am, to know that Ash Grove is making this investment in Midlothian during difficult economic times. The costs that this company is incurring to comply with mandated federal air emissions regulations are incredible while sales are down in the industry by more than 40 percent. We are fortunate that they are 0making this investment in Texas. In my estimation, Ash Grove always has been a leading corporate citizen,' Texas House Appropriations Chairman Jim Pitts (R-Waxahachie) said in his reaction to the decision."
Give him points for consistency: Rep. Pitts was against the federal cement plant rules when the economy was booming too. And he fought any and all attempts to protect the downwind cities from Ash Grove's green cement lawsuit in the Texas legislature. But he's delighted that both evil strategies worked in concert with one another and produced this wonderful result!.
Smokey Joe is merely pleased: “For years, I’ve seen these companies scrutinized by groups who would rather shut them down and force Texans to rely on imported cement. In spite of that, in a bad economy, Ash Grove has chosen to continue to operate in Texas and further improve on its record of reducing air emissions. I am pleased by Ash Grove’s decision and by the knowledge that it will be among the lowest emitting cement producers in Texas,' said U.S. Rep. Joe Barton (R 6)….."
Yes. That's the same Joe Barton still trying to sabotage the very NESHAP rules he's congratulating Ash Grove for following. Don't spend too much time thinking about the hypocrisy in this one, it'll make you pass out. In point of fact, the fight over cement pant pollution in Midlothian has been about citizens dragging an industry kicking and screaming into the 21st Century, being forced to reduce its pollution but also becoming more efficient. Jim Pitts, Smokey Joe, and Charles Sunderland the Third never mention that while pollution has been significantly reduced in Midlothian as a result of all those nasty federal mandates and citizen lawsuits and permit fights, the actual manufacturing capacity to make cement at Midlothian's three cement plants has grown.
TCEQ's War on Public Hearings
Wednesday, April 11, 2012
You already know how much the current Perry-fueled Texas Commission on Environmental Quality has stripped the right of citizens to contest permits being issued like candy to polluters in Austin. In Texas, you can decide to change your entire fuel regimen, from coal to coal and tires, and plastics, and car interiors, as the TXI cement plant in Midlothian recently did, and not face any public questioning at all. Or say you want to tear down your old plant and put up a new one. You don't need any public comment or hearing for that either, as Ash Grove found out when it applied for its "permit amendment" to rebuild its Midlothian cement plant.There has been a very premeditated and methodical campaign to make it impossible for any member of the public to interfere in the least bit with the right of the polluter to do any damn thing they want. Today, TCEQ is voting to go after other state agencies' ability to interfere as well,making it impossible, for example, for the Texas Parks and Wildlife Department to intervene in a case where the state parks might be impacted by a polluter. The proposed rules would "have a significant impact on the TPWD's ability to carry out its statutory and regulatory obligations and its ability to protect the shared public resources of the State of Texas that are under TPWD's jurisdiction," the agency wrote TCEQ in protest. It's just another effort to destroy the checks and balances of a regulatory system that was already gamed toward industry in the first place. By the time this Governor leaves office, it may well be criminal offense to even ask for a public hearing.
Comply or Be Shut Down
Tuesday, April 10, 2012
Public outrage over cement plant pollution has sparked a government ultimatum that the industry must comply with new emission standards in three months or risk being shut down temporarily or permanently. This isn't happening n Western Europe. And because this isn't fiction, it's not the US either. No it's Dubai. It's part of a larger effort to reduce polluiton from cement plants by 50% in three years in that country, which is still experiencing a construction boom. Plus, how's this for nice touches, the plants also have to "ensure 50 per cent of the boundary of their factories be covered with trees and other foliage, to mitigate some of the carbon dioxide emissions and to 'improve the ecology' and appearance of the area."Meanwhile, we're hearing nasty rumors about the EPA possibly backing off its new cement plant emission rules that are due to be implemented in the fall of next year. Never thought we'd say it, but could we just be guaranteed the same kind of environmental protection as a Developing Country?
"There are no safe doses for endocrine disruptors"
Tuesday, March 20, 2012
That's the conclusion of a new report that was three years in the making. Dr. Laura Vandenburg of Tufts University led 12 other scientists in an effort that examined hundreds of recent studies on the effects to people and animals of hormone-changing chemicals that are widely used in industry, including cosmetics, pesticides and plastics. They found that even tiny doses of these chemicals, called "endocrine disruptors," can cause harmful health effects such as infertility, cardiovascular disease, obesity, and cancer. Writing in a separate editorial about the report, Vandenburg stated that "After reviewing hundreds of studies, my colleagues and I have concluded that there truly are no safe doses for these hormone-altering chemicals. We found overwhelming evidence that these hormone-altering chemicals have effects at low levels, and that these effects are often completely different than effects at high levels. For example, a large amount of dioxin would kill you, but a very small dose, similar to what people are exposed to from eating contaminated foods, increases women’s risk of reproductive abnormalities." In North Texas, we're not only surrounded by endocrine disruptors in products we buy, but also in the air we breath. Lead from Exide's Frisco smelter is an endocrine disruptor. Many of the pollutants released by the Midlothian cement plants – TXI, Holcim and Ash Grove – are endocrine disruptors, as are a good percentage of the chemicals emitted by the gas industry when its fracking a well. Like so many other kinds of human-made pollutants, endocrine disrupters were allowed in commerce without full understanding of their possible public health effects. That's why the report also recommends that the way the government tests for a chemical's toxicity be modernized. Currently, there's no evaluation of health effects from endocrine disruptors at the low level of exposure encountered by most people. These chemicals actually can harm you more in smaller doses over a long period of time than really high short term exposures. It's called a "non-linear" response because it doesn't follow the old "the dose is the poison" rule that makes the amount of poison the driver of any possible toxic effects. “Current testing paradigms are missing important, sensitive endpoints” for human health, Vandenburg and Co. said.“The effects of low doses cannot be predicted by the effects observed at high doses. Thus, fundamental changes in chemical testing and safety determination are needed to protect human health.” In other words, we need a system that catches these chemicals before they're widely marketed in consumer products, or released as pollution into the environment; before we become unwitting lab rats.
Six-Year Green Cement Campaign Wins, Ash Grove to Decommission Last Wet Kilns in Texas™
Monday, February 27, 2012
(Dallas)—-Kansas City-based Ash Grove Cement Company has submitted a permit amendment to the Texas Commission on Environmental Quality that seeks permission to convert its Midlothian plant from three wet process kilns operation to a single dry process kiln by 2014. In a cover letter to the TCEQ dated January 13th, Trinity Consultants’ Kasi Dubbs writes that, “With this permit amendment application, Ash Grove is proposing to modify Permit Number 1 to decommission two kilns at the plant, and reconstruct that third kiln from a wet process kiln to a preheater, precalciner kiln system."According to the permit amendment application, total plant manufacturing capacity will decrease by 230, 000 tons a year, from a maximum of 1,182,000 tons of cement to 949,000 tons. Ash Grove claims that this decrease in capacity combined with cleaner dry process kiln technology will reduce pollution from its Midlothian operations by almost 105,000 tons of air pollution a year, including 98,000 tons of CO2, 6,000 tons of Sulfur Dioxide, and 560 tons of smog-forming Nitrogen Oxides. Ash Grove’s decision means that in two years, Texas will no longer host any obsolete wet cement kilns that were the industry standard throughout the 20th Century but whose energy inefficiency and pollution made them disadvantageous in the 21st. As recently as 2008, Midlothian had almost a fifth of the nation’s total wet kilns. Wet kilns depend on massive quantities of water to mix the ingredients of cement and then uses equally massive amounts of energy to evaporate the water out of the cement through exposure to extreme heat. They began to fall out of favor after the second Arab oil embargo of the 1980’s when energy prices climbed significantly. Their numbers have been steadily declining for decades. In 2010, TXI Cement announced they were closing their four wet kilns in Midlothian, almost a decade after operating side-by-side with its huge new dry “Kiln #5”. With Ash Grove’s conversion, there will be only a handful of wet kilns left in the entire U.S. Citizens who had spent years campaigning to close the Midlothian wet kilns were celebrating. “This is truly an end to an era. These kilns have been operating since 1965. They were the dirtiest cement kilns in Texas. They inspired a grassroots rebellion in DFW that forced Ash Grove to court. Their closure is one more step in bringing all of the Midlothian cement plants into the modern era,” said Jim Schermbeck, Director of Downwinders at Risk, the local clean air group founded almost 20 years ago to oppose the burning of hazardous waste in the Midlothian kilns. It was Downwinders who broke the story on January 4th that Ash Grove was finally considering dry conversion in Midlothian, while also being the target of a national EPA enforcement action. The group encouraged it supporters to launch waves of e-mail blasts to both the company’s headquarters and EPA administrators urging Ash Grove to commit to dry conversion, while also seeking to include the switch as part of the agency’s list of demands in any national settlement. Nine days later, Ash Grove submitted its permit amendment to the TCEQ. Regulators admitted that the publicity probably accelerated the final corporate decision in Kansas City. In 2006, Downwinders successfully pushed for inclusion of a recommendation in that year’s DFW smog plan that urged local governments to buy cement exclusively from the state’s dry kilns to provide an incentive for wet kiln operators to modernize. Schermbeck and the group then began their “green cement campaign” that methodically collected agreements from city and county governments that cut Ash Grove off as a potential cement supplier for municipal and county projects. Dallas passed the nation’s first green cement policy in May of 2007 during the last days of Mayor Laura Miller’s term. Over the next two years, Ft. Worth, Arlington, Plano, Denton and the Dallas County School District passed green cement policies – all unanimously. When Tarrant County passed a green cement policy by a vote of 5-0 in November 2008 Ash Grove decided it couldn’t afford to lose any more customers and took the County and all the rest of the green cement cities to court. Last January, when it looked like Dallas and Arlington might be forced to give up their policies as part of a settlement with Ash Grove, Downwinders stepped in and was praised for reaching a compromise that saved the policies’ intent to force modernization, but removed the threat of Ash Grove legal action. Meanwhile, in the 2007 and 2009 state legislatures, green cement bills garnered a bi-partisan group of sponsors including former State Senator Kim Brimer, his successor, State Senator Wendy Davis, and Tarrant County State Representative Vickie Truett. Schermbeck noted that the green cement campaign had been of the few grassroots environmental success stories during the tenure of Governor Rick Perry. Ash Grove’s decision was also just the latest victory in a string of wins by citizens that have transformed each of the three Midlothian cement plants into more modern facilities. In 2005, Holcim Cement reached a settlement with Downwinders that resulted in the first use of a specific pollution control technology that is now standard equipment on new kilns. In 2008, TXI Cement suspended operation and then closed its four wet kilns, and stopped burning hazardous waste. Now Ash Grove is converting the last wet kilns in Texas. Comparing the emissions generated by all of the Midlothian cement plants before and after the changes sought by Downwinders over the last two decades, there’ll be at least 23,000 tons less air pollution when the new Ash Grove kiln goes online in 2014 than at the peak of the bad old days in the late 1990’s and early part of the 21st Century at all three plants – not including the reduction of an estimated hundreds of thousands of tons of greenhouse gases like CO2 that weren’t even officially counted until recently.“I think anyone will be hard pressed to find a more successful grassroots group in the state of Texas over the last 10 years than Downwinders at Risk,” said Schermbeck. “It’s hard work to win even one of these concessions from industry. To be able to reduce this amount of air pollution from all three plants is an accomplishment that will be hard to duplicate. But that doesn’t mean we won’t be trying.”Schermbeck noted that the group has been busy pressing for the adoption of advanced pollution controls at the cement plants that have been used for a decade in Europe but have yet to reach the U.S. He expects to see those controls included in the next DFW clean air plan. “We’re not stopping until every cement plant in North Texas is a state-of-the-art facility.”
EPA releases Non-Cancerous Half of Dioxin Report
Wednesday, February 22, 2012
After 21 years, four Presidents, countless political battles and lots of pollution, the EPA finally released its health reassessment of Dioxin this past Friday. Like so many environmental decisions from this Administration, the report splits important hairs.While confirming that ultra-low exposures (we're talking 1 millionth of a gram or less) to Dioxin can cause damage to a person's immune and reproductive systems, cause skin rashes and liver damage, EPA says that levels of exposure for most Americans have declined so much over the last two decades that there should be no significant risk. To at least one expert, that was an "very odd statement." Arnold Schecter of University of Texas School of Public Health, noted that EPA's assurances really didn't jibe "because some people are more highly exposed than average and some groups, such as fetuses and nursing babies, are more sensitive to the effects." What other populations are more highly exposed to Dioxin? People who live downwind of facilities where its emitted – power plants, cement plants, and lead smelters, to name a few. DFW residents live downwind from all three. Exide's lead smelter in Frisco was the 9th largest dioxin polluter in Texas in 2009, releasing more of the poison than industrial facilities many times its size. While most exposures come through eating or drinking animal products that contain dioxin because the animals themselves were contaminated and store it in their fat, breathing in dioxins directly is also a pathway of exposure when you live near a place that burns hazardous wastes, smelts metals, or deals with a lot of chlorinated materials. Like millions of DFW residents. While there was a lot of disappointment by environmentalists at the lack of follow-through on the report, the food industry is sweating bullets over its conclusions. Last year, food industry groups wrote the EPA, stating that most Americans could “easily exceed the daily [0.7 picogram limit] after consuming a single meal or heavy snack." Now they're afraid safer food advocates will use the report to push for new restrictions on how much of one of the most poisonous substances ever discovered can be included in their food products. Indeed. How unreasonable to expect less human-made poison dreck in your food. No release date for the part of the reassessment dealing with cancer risks.
California Heavy Metal
Wednesday, February 08, 2012
In an excellent follow-up to its "Poisoned Places" series, the Center for Investigative Reporting focuses on a Lehigh cement plant in Tehachapi California that has seen its Mercury emissions skyrocket from just over 100 pounds a year to 872 pounds in 2010 – the most of any cement plant in the Golden Gate state and the second-highest among all cement plants in the United States. For comparison, all three Midlothian cement plants just south of Dallas reported a total of 86 pounds of Mercury released into the air in 2010, 50 pounds of which comes from Ash Grove's ancient wet kilns. Relatively speaking, it looks like we're a little better off. Except the Ameristeel Steel Mill (formally Chaparral Steel) right across the street from TXI's cement plant released 606 pounds of Mercury in 2010. That's s lot. It's also a warning sign that could eventually affect TXI's numbers. The kiln has received a new "permit amendment" nt subject to any public participation to burn Auto Shredder Residue (ASR) from Ameristeel – basically all the non-steel parts of a car after they've been through an industrial blender. This waste could have a lot of Mercury (from switches in older cars) in it as indicated by the Steel mill's emissions of the poison. When TXI burns it, that Mercury will be coming out of its own smokestack. New EPA cement plant emission standards being implemented starting in 2013 will require controls for Mercury and other pollutants at all US kilns and they're causing a once-in-a-lifetime modernization of an industry that still relies on a lot of technology from the last century that was never updated. Jane Williams, California's #1 citizen Kilnhead and the folks in Chanute, Kansas that Downwinders has tried to help get a shout-out in the piece, as does Jim Pew with the EarthJustice legal team, who've been indispensable in bringing the industry into the 21st Century kicking and screaming.
New Epidemiological Study: Kids Downwind of Kilns More Likely To Go to the Hospital
Monday, January 23, 2012
Thanks to fellow kilnhead Jim Travers, via our good and old friend Pat Costner, comes word of this new epidemiological studyof the population living adjacent to, and downwind from a cement plant in Italy, published January 14th in Environment International. According to the authors,"Epidemiological studies have shown the association between the exposure to air pollution and several adverse health effects. To evaluate the possible acute health effects of air pollution due to the emissions of a cement plant in two small municipalities in Italy (Mazzano and Rezzato), a case–control study design was used. The risks of hospital admission for cardiovascular or respiratory diseases for increasing levels of exposure to cement plant emissions were estimated, separately for adults (age > 34 years) and children (0–14 years)." It will come as no surprise to most of you that the study found a strong correlation between exposure to the cement plant's plumes and getting sick. "Statistically significant risks were found mainly for respiratory diseases among children…with an attributable risk of 38% of hospital admissions due to the exposure to cement plant exhausts. Adults had a… weaker attributable risk of 23%. Risks were higher for females and for the age group 35–64. These results showed an association between the exposure to plant emissions and the risk of hospital admission for cardiovascular or respiratory causes; this association was particularly strong for children." Lest you think Italian cement plants are any dirtier than US ones, realize that the Italian multinational Italcementi S.p.A, is the 8th largest cement manufacturer in the US, and that Italy has a SCR-equipped cement plant and the U.S. does not. These kinds of studies are extremely hard to do and that's why you don't see them often. That's too bad because they're one of the only ways you can ever put the circular logic of TCEQ and industry "toxicology" to the acid test. Everything leading up to granting an permit to pollute in Texas is based on guesstimates about how the new facility or equipment will operate and what its public health impacts will be. While it's now possible to determine if the plant may or may not be complying with the purely operational aspects of the permit, what check and balance can determine that it's not causing a public health problem? For the TCEQ, it's the theology/hypothesis that it's quite impossible for long-term, low-level chemical exposures to harm people because there's no proof. When citizens directly challenge this belief system with sampling results taken even as they were experiencing adverse health effects, showing the presence of industrial by-products in the air they're breathing, but below "safe levels," the state says that something else must have been causing their health problems. In 2012, TCEQ is the environmental equivalent of a Medieval Pope. Don't confuse them with your evidence, they have a religion to run. Or in their case, an industry agenda to implement. This is why direct, on-the-ground epidemiological studies like this one (or even associative ones like the local Cook Children's Hospital one featured in the graphic above) are so important. They are not guesstimates. They're not an hypothesis. They're real science telling you the system is not performing as predicted. We bet the Italian cement plant's permit promises not to cause a public health nuisance. And yet it appears that it does.
First-Ever U.S. Greenhouse Gas Emissions Inventory Gives a New Picture of DFW Pollution
Thursday, January 12, 2012
Yesterday, the EPA released the first national emissions inventory of Greenhouse Gases from the largest stationary sources. All 2010 releases of CO2, Methane, and Nitrogen Oxides (NOx) from large industrial facilities were self-reported by industry per EPA guidelines In North Texas, that meant a lot of cement plants, power plants, landfills and gas industry compressors and processing plants.Specifically, it's the first time we have a map of the impact of the last ten years of Barnett Shale gas mining. 45 gas plants or compressors with a total of over 2 million tons of GHGs were listed within the DFW "non-attainment area" for smog.Those usually don't show up in traditional Toxic Release Inventories that have been coming out annually since 1989. Totals from the three Midlothian cement plants accounted for almost 2.3 million tons of GHS. The cement plants were #3, 4, and 5 among the top CO2 emitters, and #1, 2, and 3 among the top ten NOx polluters. Ash Grove's dirty old wet kilns were the top NOx polluters in the entire North Texas area.Slightly exceeding the cement industry totals was the combined output of GHGs from regional landfills. While gas sources emitted primarily CO2, landfills released the majority of industrial methane as might be expected. Topping all those categories was the amount of GHG pollution released by the area's power plants, totaling 5.3 million tons in 2010. In all, over 100 facilities reported close to 13.4 million tons of GHGs in 2010. By County, Ellis assumed a top ranking because of the cement plant complex in Midlothian plus some huge emissions from the gas-fired power plant in Midlothian. Wise County was next with power plant and gas facility emissions, then Johnson, Hood, Dallas, Tarrant, Parker, Denton (where Frisco's Exide Lead Smelter was the top CO2 polluter) and then Collin. There were no listings for Kaufman of Rockwall. The placement of more rural counties ahead of Tarrant and Dallas reflects where the larger power plants, gas production facilities, and other large sources have been locating over the last 15 years or so. We're going to have more analysis as we continue to go through the inventory. You can download the entire national emissions inventory at the EPA's site here.
Is Another Local Cement Company Under Federal Scrutiny?
Tuesday, January 10, 2012
As of last week we know that Ash Grove's operations across the country are the target of an national PEA enforcement action similar to ones we've been seeing emerge after a couple of years of focused attention on the entire industry. In response, we asked you to let EPA know there was an opportunity to match that enforcement action with what we also now know to be Ash Grove's consideration of converting it Midlothian wet kilns to dry technology. From EPA comes word that the e-mail messages you sent have been received. But this week begins by Downwinders trying to confirm that the owners of a second Midlothian cement plan is also the subject of one of these EPA national enforcement actions. If true, it gives DFW citizens another chance to win public health concessions from one of the single largest polluters in the region. More to come as we find out what's going on. Please take note – despite the fact that the owners of two large North Texas cement plants look to be the target of federal action, the only place so far you'll find any news about this development is right here. Looking for more reporting on clean air issues in DFW? You found it.
Ash Grove Update and Thanks
Friday, January 06, 2012
As of this week, EPA officials mulling a national settlement agreement over various Ash Grove transgressions across the country know that the company is considering converting their Midlothian old wet kilns to new dry technology and can take that into account when drawing-up the terms of said settlement agreement. Also, as of this week, Ash Grove corporate headquarters knows the cat is out of the bag and the public knows it's considering the switch. That's more than either party knew last week – thanks to citizens. From all available indications, both the Ash Grove VP in charge of Environmental Affairs and the EPA's Assistant Administrator in charge of Civil Enforcement received lots and lots of e-mails yesterday about the subject because so many of you were nice enough to respond to our action alert. Thanks and well done. Having added these new ingredients into the mix, we will now stand back from the stove for a minute and watch to see how things stew. EPA could now make it clear that the national Ash Grove enforcement settlement must include a dry conversion of its Midlothian kilns. Ash Grove could decide to preempt what looks like a forced move by EPA and announce it's already made the decision. Maybe neither. Meanwhile, we're out shaking the bushes for more information. Since the company was supposed to make a decision by early December we can't help but feel some new development is imminent. Stay tuned. And thanks again for being active citizens instead of passive receptors.
Will Ash Grove Decision Bring the End of Old Wet Kilns in Texas? Want to Help Make Sure?
Wednesday, January 04, 2012
Here's a Fighting for Air Exclusive: Rumors out of the Overland Park, Kansas headquarters of Ash Grove Cement indicate that the company is seriously considering converting its three Midlothian wet kilns into one or more dry ones. This would be instead of a piece meal approach of installing a variety of new pollution controls demanded by the new MACT rules going into effect in September, 2013. Apparently out of the running are the less drastic options of closing the plant all together, or building a new DFW plant on the property Ash Grove owns in Grayson, County. According to our source, Ash Grove says it has at least 50 years of limestone left at its Midlothian quarry and the company is trying to decide whether to invest in a dry conversion now or try to make a lot of new equipment demanded by EPA's new rules blend with a very old, out-of-date wet kiln facility.Adding to the company's consideration is the likelihood of coming greenhouse gas regulations for kilns and other changes that are designed for dry kiln adaptation. We haven't taken a recent count, but there are probably not more than 15 wet kilns left in the entire country. Ash Grove operates the Last Wet Kilns in Texas.™ Converting to a dry kiln would cut all kinds of air pollution significantly from Ash Grove's Midlothian cement plant, beginning with smog-forming Nitrogen Oxide, Sulfur Dioxide, Particulate Matter, and Volatile Organic Compounds. It's been done before and there should be no technical obstacle to the change if Ash Grove wants to make it. If you'd like to encourage Ash Grove to make the jump to a dry kiln,please feel free to drop a short and polite e-mail to Curtiss Lesslie, the company's Vice-President for Environmental Affairs at email@example.com. (Example: Dear Mr. Lesslie, as a resident of North Texas I'd appreciate it if Ash Grove would convert its Midlothian wet kilns to dry ones and pollute less. Thanks) But wait, there's an important factor that could help Ash Grove make its decision to convert to dry kiln technology. Downwinders has also learned that EPA is pursuing a nationwide, multi-plant enforcement action against Ash Grove that is now in settlement talks. These are the same kinds of national enforcement actions and settlements that have previously resulted in requiring new controls on kilns across the country and pilot testing of Selective Catalytic Reduction. As part of this national settlement, EPA couldrequire that Ash Grove convert to dry kiln technology or close its Midlothian plant. Will it? We don't know,but we know one way to encourage that result: sending a short e-mail to Cynthia Giles, the EPA Assistant Administrator who oversee these settlement agreements at firstname.lastname@example.org.(Example: Dear Ms. Giles, As a resident of North Texas, I'd appreciate it if, as part of the Agency's nationwide enforcement settlement with Ash Grove Cement, the EPA would require the Ash Grove plant in Midlothian, Texas to convert from wet to dry kiln technology. It would help a lot with DFW air quality. Thanks.) We promise to follow this story as it develops. Stay tuned.
Mighty Changes From Little Struggles Flow: Another Downwinders Success Story
Friday, December 30, 2011
This is not a story that will ever make national headlines. It hardly even got a respectably-sized article in the town where it's taking place. But for beat-down citizen-soldiers of the air wars looking for proof that their own local battles can affect national policy, it's a tale worth telling. Yesterday, the Department of Justice and EPA announced a settlement agreement with a multinational cement company called ESSROC. Among other things, the agreement calls for the pilot testing of advanced Selective Catalytic Reduction (SCR) pollution control technology at ESSROC's two obsolete wet kilns in Logansport, Indiana. Wet kilns like the three at Ash Grove's Midlothian plant. It will be the first demonstration of this remarkable technology on wet kilns anywhere in the world. Last year, DOJ reached a similar agreement with LaFarge Cement that's requiring a pilot test of SCR on a dry kiln in Illinois. Those results are due by July, 2013. The results from the wet kilns in Indiana will be due by May, 2015. This will be about the time the DFW area is trying to assemble a new clean air plan to reach the just-announced ozone standard of 75 parts per billion. We'll have pilot tests of SCR on both types of kilns in Midlothian, and Downwinders will be using those tests to advocate finally requiring SCR on all Midlothian cement kilns. In use in European cement kilns for a decade, SCR – basically a huge industrial size version of the catalytic converter every US car has – has been proven to reduce emissions of smog-forming Nitrogen Oxides by 90% or more, while also reducing Particulate Matter pollution, metals, and dioxins. It's considered the gold standard of kiln control technology. When it does end up in Midlothian, SCR will be coming back to the kilns and people that are responsible for its import into the US. That's because Downwinders was the first citizens group in the country to began advocating the use of SCR in cement kilns – way back in the year 2000, as part of a DFW anti-smog plan. Impossible the state and cement companies said. Too expensive. Not technically feasible. We didn't win, but we kept up with information about the technology. A couple of years later, our modest assistance to a group of citizens fighting a proposed Holcim cement plant right on the banks of theHudson in New York gave us access to their hired engineering expertise, which had done its own technical review of SCR in Europe. We took that information and made it a basis for a demand in our own settlementwith EPA and TCEQ over the failed 2000 DFW air plan to do an independent review of SCR for application to the Midlothian kilns. That 2006 study is still the only study of its kind in the nation. Much to TCEQ's lasting chagrin, that report confirmed that SCR was technically and economically feasible for application on the Midlothian cement plants. TCEQ has done its best to run away from that report every since, even having its staff perjure themsleves in state legislature testimony about its conclusions, but it got published and distributed nationwide. Other states and engineers read it, and are still using it. During this same time Downwinders, with the help of funding acquired through yet another settlement, hired its first ever technical expert, a young engineer from SMU named Al Armendariz. One of his jobs was to review the SCR report we'd generated and collect more data on the track record of the technology in Europe. By the end of his stint, he was somewhat of an expert on cement control technology, especially SCR. And then he went to go to work as the Regional Administrator of EPA. As it happens, EPA was in the middle of a national enforcement initiative involving the entire US cement industry. Many of the violations that were found revolved around illegal and excessive emissions of Nitrogen Oxides. Downwinders pressed for SCR pilot tests as part of these agreements. In January, 2010 EPA and DOJ announced the LaFarge settlement requiring a first-ever US pilot test of SCR. In discussions with EPA Midwestern staff afterwards, it was clear that the TCEQ report and Downwinders's efforts were well-known and provided the technical evidence to help drive the settlement talks toward including an SCR provision. Yesterday' announcement of a new round of SCR pilot-testing indicates that influence is still being felt…..Did we need luck? Absolutely. Did we make our own luck? Absolutely. We were opportunistic as hell. We advanced the cause at every turn. We fit square pegs into round holes. Unrelated developments got pulled into relationships that built on previous steps because we saw a path that nobody else did. We slowly built the technical and political scaffolding we needed. And these last two years have seen the fruits of that strategy. What began as a demand for a specific control measure for a local DFW clean air plan has now brought the entire US cement industry to the brink of using a control technology that could bring massive reductions in pollution nationwide. This is a story about the un-sexy, un-Erin Brockovich way of grinding out incremental social change with small groups of very persistent people. And it's the way progress is made most of the time. Want to change the world? Start in your own backyard.
Correction: Explaining the Two "Watch Lists" Featured in NPR's "Poisoned Places"
Tuesday, November 08, 2011
In trying to get the news out quickly about the four-part NPR/Center for Public Integrity series on toxic pollution in America titled "Poisoned Places," we didn't do a very good job of explaining the origin and purpose of the two different "watch lists" that the reporters discovered and publicized. In fact, we're pretty sure we got it dead wrong. So here's a second try. There's a list that was begun by the Bush Administration in 2004 that included what the EPA considered "high priority violators" nationwide. As of September, this list was about 1600 names long. In North Texas, TXI, Holcim, Ash Grove, Exide, Magnablend, the GM plant, the Bell Helicopter plant, and over 100 other sites are included on this longer "high priority violator" list. There's a second, smaller "watch list" of 464 facility names of facilities nationwide with on-going violations, but which no administrative action has been taken to resolve. This is the list that only two North Texas sites are on – GE Engine in Ft. Worth and Ash Grove Cement in Midlothian. National Map of the 1600 sites is here. State map of the Texas sites on the 1600 list is here.
DFW full of "Poisoned Places"
Monday, November 07, 2011
Stung by criticism that it wasn't doing enough about cracking down on chronic polluters, and facing a tough re-election fight, the Bush Administration in 2004 established a secret "watch list" to help it identify the worst bad actors. If, after nine months of knowing about a critical environmental violation at a faclity, there still hadn't been any enforcement action, the facility took its place on the list. As of September of this year, that list had grown to 1,600 facilities. Thanks to NPR and the Center for Public Integrity, you can look at andinvestigate a map of the US identifying those 1600 plants, including over 100 in the DFW area when you use the Zoom tool the NPR website provides. Many names are familiar – TXI, Holcim, Ash Grove and theAmeristeel steel plant in Midltohian all make the list, as does the Exide lead smelter in Frisco, as doesMagnablend, the Waxahachie plant that just blew up, as does places you might suspect like the GM plant in Arlington or the Bell plant in Ft. Worth, However, there are lots and lots of places that maybe you haven't suspected, like the Americhem plant in Mansfield, or Valley Solvents and Chemicals in North Ft. Worth. The sites on the list are rated 1 to 5 on a EPA "Risk Factor Scale," with 5 being the maximum risk. All of those sites we just listed are all rated at Risk Factor 5 – that is the combination and/or volume of chemicals released make them among the most dangerous sites on that "watch list." But wait, there's more. Within this larger watch list, there's a second, more selective list of REALLY bad actors that numbers 464. Almost 10% of those sites are in Texas, but only two are in DFW: GE Engine Services on FAA Blvd. in Ft. Worth and our good friends at Ash Grove Cement. You remember Ash Grove – the owners of the last obsolete wet kilns in Texas that refuse to modernize their cement plant just south of DFW. As we remarked on Monday when DFW officially replaced Houston as the "Smog Capital of Texas," DFW hasn't historically been associated with dirty air and dirty industries the way the Gulf Coast has been. Unfortunately, that's changing.
The View from Midlothian
Saturday, October 22, 2011
Here's a new Salon article on the continuing battle by House Republicans, including Smokey Joe, to roll back the 2008 cement plant emission rules that had overwhelming popular support, with an emphasis on what is means for Midlothian, "the Cement Capitol of Texas." As usual, the Midlothian city leadership distinguishes itself with its aggressive ignorance on the subject of cement plant pollution, and adopts the knee jerk position that any regulation of these facilities is over-regulation. That's the same fearless stand the city fathers took in the 1980's and 90's too – when there wasn't any regulation at all. Good to know they're keeping up with the changing times. One day in the future, Midlothian residents who don't make their living from cement are going to get tired of having their health threatened by people who only have the cement plants' interests at heart. But not today.
Two More Wet Kilns Close: Judgement Day for Ash Grove is Nigh
Thursday, October 20, 2011
Word comes that the 100 year-old LaFarge Fredonia Kansas wet kiln cement plant is closing. There's no current good count, but that must leave less than a dozen such wet kilns left in the entire country. There's no doubt that the recession is to blame for exacerbating the cost disadvantages of these relics, but there's also the new EPA emission rules that are still, despite Republican and and Industry opposition, scheduled to take effect in the fall of 2013. For a couple of wet kilns like those in Fredonia to try and comply would mean a very large investment in new pollution control equipment like scrubbers, a new baghouse, and maybe even SNCR for a facility that is already inherently inefficient and more costly to run. This is the same dilemma faced by DFW's own Ash Grove wet kiln cement plant in Midlothian, whose Kansas-City based owners haven't yet indicated whether they will close it or choose to upgrade its circa 1965 operation. For the amount of new equipment that would have to be installed, there would probably be at least a year to 18 month construction and start-up. Meaning that if Ash Grove isn't doing some heavy duty remodeling by this Spring or next Fall, you can pretty much count them out. What the company may be waiting on, along with the rest of the cement industry, is to see whether President Obama is re-elected. If he's defeated, then you can be sure the new EPA rules, despite already being promulgated, would never be implemented, and Ash Grove can continue to operate its ancient plant without having to do a thing. If he's in for another four years, they're stuck with the rules, and probable closure. Don't think voting makes a difference?
President Says He'll Veto Cement Rules Rollback Legislation
Tuesday, October 04, 2011
It won't come to that because this thing will never make it out of the Senate, but ti's still good to see the President draw the line in the sand somewhere, Here's the complete statement issued by the Administration yesterday:
Another Wet Kiln Bites the Dust
Wednesday, June 15, 2011
Holcim's Catskill plant from the 1960's – circa Ash Grove's wet kilns – decides to throw in the kiln and close.
Kiln cuts Mercury pollution 90 percent complying with new EPA rules
Saturday, June 04, 2011
That's why the new MACT/NESHAP rules for cement plants that take effect in 2013 are so very important. That's why fighting Congressional Republican efforts to repeal them is so important. And that's why Downwinders at Risk spent over a decade fighting for them, in the courts, in the EPA, and in the court of public opinion.