Holcim permit
In June 2019, LaFargeHolcim (Holcim) submitted a permit amendment request to the Texas Commission on Environmental Quality (TCEQ) to allow the plant to:
Increase the maximum allowed output of carbon monoxide from about 4,300 tons per year to 7,100 tons per year
Increase their use of controversial petroleum (pet) coke rather than use more expensive, cleaner sources of fuel
Why?
From what we gathered:
Technology exists to decrease emissions, but it's expensive. TCEQ asserts that the cost associated with Holcim actually using best available control technology is too prohibitive despite the plant's proximity to a growing number of families. Money over people.
Petroleum companies have an overabundance of the toxic waste product, pet coke, and many are paying cement companies to take it off their hands. We don't know what the arrangement is with Holcim, but pet coke is cheaper than cleaner fuels.
The limestone that Holcim utilizes is naturally higher in organic compounds than the limestone of the other cement plants in Midlothian, which has led to consistently less efficient combustion with higher release of CO, sulfur compounds and VOCs as compared to the other plants. This makes it harder for Holcim to decrease emissions, even when using similar technology to the other plants. See Comparison of plants.
LOOK BACK: Data collected on Holcim in our effort to stop them from burning more dirty pet coke
Holcim permit application to TCEQ: Permit 8996, PSDTX454M5
full permit request Holcim.pdf
Draft of air modeling for Holcim permit
CompressedAQA 021420.pdfThe air modeling document submitted in February 2020 showed that PM 2.5 would increase to within 1 point of the maximum allowed by the EPA's NAAQS regulations if the permit is approved (see below).
table of air modeling predictions.docxRevised air modeling for Holcim permit
Response to TCEQ 2020-05-15.pdfThe air modeling document submitted in May 2020 dropped the level of PM 2.5 emissions from 34.1 to 31.6.
WELCOME RECENT NEWS
The EPA is taking comments in 2023 about setting the NAAQS maximum for 24-hour PM 2.5 averages as low as 25. The deadline for current public comments on lowering the primary annual standard from 12 micrograms per cubic meter to 9–10 micrograms is March 28, 2023. Find out more on our Facebook page @MidlothianBreathe.
Current maximum allowable emission rates for Holcim
MRT-8996 Holcim (Renew).docxCarbon emissions of petroleum coke compared to other fuels
EPA emission-factors various fuels_2014.pdfKnow more
From Canada to Midlothian? Find out more information on pet coke.
INDEPENDENT REVIEW
As Midlothian residents, we were asked to accept the science endorsed by the Texas Commission on Environmental Quality (TCEQ). Why didn't we?
In our interaction with TCEQ staff, they acknowledged they were not familiar with all technical aspects of the permit (i.e., air modeling, engineering aspects, best available control technology, in-depth knowledge of cement industry).
In the early 2000s, when Holcim last asked to increase emissions, TCEQ withheld knowledge that better technology was available to reduce emissions. They also tried to protect Holcim from having to submit a New Source Review (NSR) permit.
TCEQ repeatedly fails to forcefully enforce permit violations.
In 2018, there were 4,950 unauthorized air pollution events in Texas, resulting in double the unauthorized emissions over the previous year. However, only 57 penalties were issued. Over the past five years, TCEQ has issued similarly low rates of penalties.
When fines are issued, the dollar figure of the penalty is so low (well below what TCEQ is authorized to issue) that it is more profitable for companies to continue to violate their permits and pay the fines than correct the problem. In 2018, TCEQ fined companies just $0.013 per pound of unauthorized emissions.
That’s why we hired Dr. Ron Sahu
We wanted an independent expert review of Holcim’s permit application. Here are Dr. Sahu's credentials:
Doctorate in Mechanical Engineering
Qualified Environmental Professional (QEP)
Confirms that he has in-depth knowledge of his profession, has demonstrated the ability to solve complex environmental problems and has a broad understanding of environmental issues
Certified in Energy Management (CEM)
29 years in engineering (environmental, mechanical and chemical)
25 years in project management and consulting, representing public sector (i.e., EPA, Department of Justice, state governments) and private sector (i.e., cement manufacturers, petroleum refineries)
Has followed Midlothian’s challenges with the cement industry for decades
Has written many articles and expert reports and given many presentations and depositions every year for situations such as ours in Midlothian
VALIDATION OF OUR CONCERNS
Dr. Sahu reviewed LaFargeHolcim's permit application and identified many issues with the permit that still remain relevant — despite permit approval.
Evidence that Holcim's equipment and pollution controls are functioning poorly
Misapplication of EPA terms to understate pollution increases and avoid more extensive EPA oversight
Lack of supporting evidence for company conclusions, including non-validated, tenuous predictions for highly toxic PM 2.5, showing Holcim will be taking PM 2.5 levels to the very maximum allowed levels
Unexplained increases in carbon monoxide compared to other emissions
Use of old meteorological data from as far away as Corsicana and Shreveport (rather than more recent data from more proximate locations) to model what will happen to emissions with the new permit
Want more info?
DRAFT Sahu Report Holcim Midlothian Permit (5.9.20).docxRESPONSES FROM TCEQ
TCEQ EXECUTIVE DIRECTOR RESPONSE TO PUBLIC COMMENTS AND FINAL DECISION LETTER
Re. Holcim Permits 8996 and PSDTX454M5
Excerpt of Final Decision Letter
“The executive director has made a decision that the above-referenced permit application meets the requirements of applicable law. This decision does not authorize construction or operation of any proposed facilities. This decision will be considered by the commissioners at a regularly scheduled public meeting before any action is taken on this application unless all requests for contested case hearing or reconsideration have been withdrawn before that meeting.”
See the Response to Public Comment below.
TCEQ response to comments.pdf