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any action is taken on this application unless all requests for contested case hearing or reconsideration have been withdrawn before that meeting.”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.
BURNING PET COKE IN KILNS
Email sent to Midlothian Breathe 10/3/2019 from Joel Stanford, Team Leader – Expedite Team, Air Permits Division.
"We’ll get some data to back it up, but it looks like burning petcoke would be either a better situation or the same (vs. coal) in terms of impurities (metals) in the PetCoke. The whole process is very unlike what you would see with a power plant or straight combustion. The reason is that many of the metals in the petcoke would be volatized in the kiln, but then react/bond with the clinker and also cool back down into particulate in the clinker (cement) mixture as it cools and moves through the system. In a power plant those emissions would be superheated and go out the stack before cooling back down and settling onto the lands surrounding the source. Here the combination of the clinker and the cooling process plus the filtration prior to the stack are the factors which indicate it wouldn’t be a concern.
An interesting way that petcoke would benefit the process is that it has higher sulfur in it than coal. The clinker absorbs and needs this sulfur to function as cement. The petcoke reduces the amount of high-sulfur gypsum they have to add to the mixture. That gypsum is mined elsewhere and has to be trucked in. Reducing the amount of gypsum they need to add could then be viewed as having other extraneous benefits, dependent on one’s perspective – especially those who live next to a gypsum quarry."
Comments from Jim Schermbeck with Downwinders at Risk about bonding in the clinker and sulfur absorption.
"Just to be clear...when those metal "volatize" in the kiln, 100% of the metals don't go in the clinker. On average a third go into the cement/clinker, a third to the cement kiln dust that gets buried onsite, and a third is released up the stacks. Current "filtering" at Holcim doesn't keep them from being the PM-dirtiest plant in Texas (by almost 100 tons a year) and it won't keep the metals out of the emissions released into the atmosphere that are latching onto that PM. If the clinker absorbs too much sulfur or metals, it ruins the clinker product "
ROLE IN PERMIT REQUEST
Email requesting input on permit request sent 9/26/2019 to Joel Stanford, Team Leader – Expedite Team, Air Permits Division. Response received 09/26/2019.
"Our task at the TCEQ is to review the application in accordance with state and federal law. I will direct you to the application itself, as that is what we are reviewing. We cannot offer opinions or perspectives, as our job is technical and legal and opinions do not come into play. I would suggest you attend the public meeting, when scheduled, as a means of being able to easily ask specific questions about the application. Otherwise, most questions would be treated as public comments and answered formally in the Response to Comments."
NOTE: Midlothian Breathe requested a public meeting, which was held virtually in April 2020.
Downwinders at Risk
Email requesting input about the Holcim permit sent 9/26/19 to Jim Schermbeck, Director.
In the 25 years Downwinders at Risk has been addressing air pollution from the cement plants in Midlothian, citizen scrutiny of their operations has been essential. Lack of sufficient oversight from any level of government in Texas means that protection of one’s family and property from industrial trespass is a Do-It-Yourself proposition.
Midlothian Breathe is performing a public service in asking hard questions about the new Holcim cement plant permit. - hard questions that won’t be asked by any one else because the permit writers don’t live next door to Holcim. Unlike government, Midlothian Breathe is sticking up for Midlothian families.
Director, Downwinders at Risk