Midlothian Breathe

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GOALS_MidloBreathe-Jan2020.pdf

Past actions

PUBLIC COMMENTS SUBMITTED TO TCEQ REGARDING HOLCIM'S RECENT PERMIT REQUEST

The official public comment period ended in mid-September 2020. For your knowledge, however, take a look at some of the public comments filed with TCEQ.


How were the locations chosen for Holcim's air modeling? Why were Corsicana, TX (> 40 miles) and Shreveport, LA (> 200 miles), both counter to prevailing winds, according to TCEQ (https://www.tceq.texas.gov/airquality/monops/windroses.html ) used as sites for collecting upper air data for modeling purposes? Wouldn’t locations closer to Holcim provide more accurate, predictive data? Is meteorological data from 2011-2015 the most recent data available?

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In section 10.3.2 of the permit, Holcim claims that "properly controlled combustion in the kilns" is part of their Best Available Control Technology (BACT) to minimize emissions. How can "properly controlled combustion" be monitored or enforced? It can't. Therefore, it is a meaningless form of BACT and certainly not the "best available." Our community deserves better and we will not be misled to think otherwise.

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If TCEQ is going to allow Holcim to continue production with "operational difficulties," "capable of accommodating adjustments," and non-enforceable forms of best available control technology, TCEQ should require that Holcim limit production to limit actual emissions.

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Where is the prior petroleum coke testing data that Holcim references in the permit (page 6-1 and 6-2)? This data should be shared with the public and evaluated by TCEQ.

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What testing has Holcim done to validate their plan in section 6.2.1 to “refine the PM 2.5 emission rates for the dust collectors"? This refinement needs to be tested to make sure the numbers they have calculated on paper accurately reflect what is actually happening in the production process. Holcim’s original calculations in February 2020 showed that the projected total PM 2.5 concentration will be extremely close to max allowable levels, per NAAQ standards. Revised numbers filed in May brought those critical numbers down. Shouldn't Holcim be expected to provide supporting evidence for all of their claims, especially when submitting ammended numbers on a dangerous pollutant like PM 2.5?

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Holcim has used "capable of accommodating" adjustments to explain why SO2, NOX, and GHG will not meet de minimis netting threshold for PSD determination. This is not a correct use of the "capable of accommodating" adjustment, which was designed to account for transient surges in production demands. Holcim instead uses it to inflate their continuous baseline emissions (prior to permit approval), using emission numbers based on operating at 100% capacity 24/7, which is not realistic or appropriate. They do this to minimize the apparent increase in their predicted emission increases (after permit approval). For instance, Holcim expects NOx emissions to increase by 256 tons per year (TPY) from their current actual emissions and normally an increase of 40 TPY would trigger PSD. The "capable of accomodating" adjustment allows them to use projected NOx emissions occurring with max production 24/7 as their baseline rather than their true (actual) baseline emissions, so as to minimize the apparent increase. Using the "capable of accommodating" adjustment to explain away the need for PSD review of an NOx increase of over 6 times the normal threshold for PSD review is very concerning.

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What is Holcim’s proof that “in the cement manufacturing process, fuel-bound sulfur becomes incorporated into the clinker, essentially restricting the amount of fuel-bound sulfur emissions that will reach the main stack?" In section 6.1.2, Holcim states this claim is supported by prior permitting reviews, technical papers, and petroleum coke testing trials. Where are the details of the prior petroleum coke testing trials and technical papers to support this claim? They are no where to be found in the permit request.

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It's imperative that we have stack tests done PRIOR to approval of the permit, with a focus on extremely accurate monitoring of PM 2.5. Conducting test burns after permit approval doesn't make common sense, especially based on Holcim's poor record in living up to emissions claims.

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Why haven't CO (carbon monoxide) emissions trended down over time as they have for THC (total hydrocarbons) and HAPS (hazardous air pollutants)? This is not reasonably explained in the application. If the RTO pollution control device is working appropriately, CO emissions should trend down when THC and o-HAPS trend down. CO emissions are primarily a product of combustion, so even if the composition of organic materials in the kiln feed has changed significantly over time, this should not affect CO emissions. In a prior permit request, Holcim predicted a 50% reduction in CO that has now proved to be false. If their predictions were this far off previously, why should we believe their predictions now?

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Holcim extends a second explanation as to why their cap on carbon monoxide emissions should be lifted, saying "in recent years, the composition and concentration of the organic materials in the kiln feed have increased significantly compared to the baseline actual emissions" (page 1-1 of executive summary). This does not make sense. Why would the limestone be any different now than it was five years ago or 1,000 years ago? Holcim should have better evaluated the quality of the limestone before they built their plant or installed extra pollution control equipment to compensate for the bad limestone. Instead, they are asking for permission to worsen air quality.

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Why doesn't Holcim correct the operational difficulties and waste build-up that they acknowledge exists, according to their permit application to TCEQ (see Executive Summary page 1-1), rather than ask for permission to raise carbon monoxide emissions?

PARTICIPATION IN THE OFFICIAL PUBLIC MEETING HELD AUGUST 27, 2020

Miss the "meeting"? Transcribed segments have been posted on Facebook@MidlothianBreathe.

The TCEQ public meeting was held virtually Thursday, August 27, 2020. It was a poor substitute for meeting in person on an issue so impactful to our community. After all, it's the only chance citizens get to address Holcim and TCEQ directly.

Midlothian Breathe tried to work collaboratively with both. Holcim refused to meet with representatives from our group of local moms. TCEQ responded to several of our emails, but said they have limited ability to engage with citizens outside of legally mandated and very confining paths.

Don't let heavy industry increase pollution in our community without pressing for safeguards. Take a look at our 5 Actions and help us hold Holcim accountable for the claims they are making.