Comment Season Opens for Army Corps and Titan: Speak Up!

The public comment period for the U.S. Army Corps of Engineers initial scoping meeting regarding the proposed Titan cement plant in Castle Hayne is now open. So it’s critical that everyone concerned about the proposed Titan plant say it loud and say it proud…but, we’ve been asked to make it relevant. According to Henry Wicker, coordinator for the Environmental Impact Statement being prepared by the Corps, they do not want to hear how bad it’s going to be for us all, or how we really, really, really don’t want Titan here. All they really want to know is what we want them to address in the EIS. Here’s what the Corps typically covers in their own words, which they call “Public Interest Review Factors”:

“Public Interest Review

The Corps public interest review is the main framework for the overall evaluation of projects. The public interest review requires the careful weighing of all public interest factors relevant to each particular permit application. Thus, one specific factor (e.g., fish and wildlife values or economics) cannot by itself force a specific decision, but rather the decision represents the net effect of balancing all public interest factors, many of which are frequently in conflict.

The public interest review is used to evaluate applications under all authorities administered by the Corps. During the review of a permit application, the Corps evaluates the following public interest review factors:

* Conservation
* Economics
* Aesthetics
* General environmental concerns
* Wetlands
* Historic properties
* Fish and wildlife values
* Flood hazards
* Floodplain values
* Land use
* Navigation
* Shore erosion and accretion
* Recreation
* Water supply and conservation
* Water quality
* Energy needs
* Safety
* Food and fiber production
* Mineral needs
* Considerations of property ownership
* The needs and welfare of the people”

Let’s hope this list is not in order of priority. For more than you’d ever want to know about the U.S. Army Corps of Engineers permit process, check out their web page on the subject.

There are a number of ways to comment during the scoping period before it ends at 4:15 pm on July 15, 2008. The easiest is to show up at the Public Scoping Meeting to be held on July 1, at 6 pm, at Wilmington Christian Academy/Grace Baptist Church, 1401 North College Road. There Army Corps officials will give a rundown of the process and then break everyone into groups based on subjects of concern (air, water, aquifer, etc.) Then they’ll go around and ask everyone what concerns them and what they want covered by the EIS. They’ll write it down on a big dry erase board and take it back to HQ and compile all the concerns into categories, which they will eventually ask Titan to address. More public hearings will be held as the process unfolds. We need as many people at the scoping meeting as possible to make sure our concerns are voiced in each breakout group. But if you can’t attend, or you have a detailed list, you can also email your comments to Mr. Henry Wicker at: Henry.M.Wicker.Jr@usace.army.mil or snail mail them to him at P.O. Box 1890, Wilmington, NC 28402.

Here are some of the concerns we’ll be asking them to cover in the EIS. The more people that ask for these, the harder they will be to ignore. So ask away!

Air Quality

1. Please address the cumulative health and environmental effects of air pollution in our area before Titan’s proposal and with Titan’s proposed plant. Including:

–the impact of Titan’s permitted mercury, hydrochloric acid, and particulate matter emissions on the health of our children, particularly those who attend elementary and preschools within ten miles of the proposed plant, and other high risk groups, such as those with asthma, heart disease, emphysema, diabetes, and other impaired lung functions, over the operating life of the proposed Titan plant.

–the impacts of NO2 and SO2 on our airshed and public health, including increases in acid rain and smog, and the impact of increased Nitrogen fallout from the plant on our local rivers, sounds, and estuaries and its potential effect on algal blooms, shellfish and sport fisheries.

–the impacts of CO on human health and the environment, since New Hanover County already ranks first in the state for CO emissions.

–the impacts of CO2 emissions on public health and the environment, specifically since the Supreme Court has now determined that CO2 is a pollutant and should be regulated under the Clean Air Act.

–the feasibility of carbon sequestration from Titan’s proposed plant, as well as whether the plant would be economically viable if a price/cost/or tax is placed on carbon emissions in the near future.

–Titan has said they are considering burning tires at the Castle Hayne plant. Many other cement kilns also burn hazardous waste. Please determine the type, quantities, impacts, of hazardous emissions that would be emitted from burning such fuels, including dioxins, furans, and any other toxins, including those found in the resulting Cement Kiln Dust.

–the amount and quantity of fugitive emissions from the plant and how Titan plans to remediate or clean up areas affected by such emissions, including Island Creek and the Northeast Cape Fear River. At other plants, they use water to wash down trucks and roads. How will they treat their stormwater and dust-control water run-off to keep potentially harmful substances out of nearby lakes streams and rivers?

–Will Titan’s proposed plant make New Hanover County a federal non-attainment area for air pollution? If not, how close will it bring our county to being a federal non-attainment area?

WATER and WETLANDS

–How will Titan mitigate the impacts its 1,200 acre limestone mine, with it’s mining explosions, noise, and dust, on the aesthetics, fish and wildlife values of Island Creek?

–How will Titan mitigate the utter destruction of nearly 500 acres of wetlands, when wetlands are not widgets, and have instrinsic local values and ecosystems services in place that cannot be replicated elsewhere?

–How much water will Titan take from the Pee Dee and Castle Hayne Aquifers to dewater its mine, and what will they do with that water?. How many homes would that water supply if left in the aquifer? Since Titan and other limestone mining companies are alleged to have contaminated the Biscayne Aquifer in Dade County Florida, what protections will they have in place to keep from contaminating our aquifers here?

–The proposed Titan mine is roughly one mile from a federal Superfund site under the former Oxychem plant, now known as Elementis. As we understand it, the site consists of a deposit of carcinogenic chromium compounds in the Castle Hayne aquifer that are kept in place by injection wells surrounding the contaminated area. It is also our understanding that when the Martin Marietta aggregate mine–which would be consumed by the Titan mine–turns on its dewatering system, the injection wells around the Elementis Superfund site turn on–suggesting some hydraulic connectivity between the two areas. What would Titan do if its much larger dewatering system began to be contaminated by chromium compounds from the Elementis site? Would they be allowed to dump this water into the Cape Fear River? Would they be forced to remove the chromium? What would be the potential health effects if chromium compounds were released into the Northeast Cape Fear River.

–The Cape Fear River is already contaminated with mercury. How will the nearly 8,000 pounds of mercury emitted into our streams, creeks, rivers, and air over the 30 year life of the proposed Titan plant affect public health and the environment, including fish consumption advisories and their economic impact on recreational fisheries.

–Does Titan have enough raw material and/or limestone in it’s current proposed mine site to sustain its cement plant for the next 30 to 50 years, or will it have to open future mines within its stated three mile limit from the plant? Where would those mines be located and how large would they be? What would be the cumulative impact of all of these mines on the aquifers and nearby wetlands, streams, and rivers?

WILDLIFE

–What would be the effect of the proposed plant on any current or future federally listed endangered or threatened species, particularly fish and amphibians that are particularly sensitive to mercury emissions.

–What impacts would the proposed Titan plant have on significant fish and shellfish habitat both in the Cape Fear River System and in coastal waters

Socioeconomic Impacts

–There seems to be some debate among economists on the actual economic benefits of the proposed Titan cement plant. Therefore I request a full socioeconomic impact study to determine the short-term and long-term socioeconomic impacts of the proposed Titan cement plant, including how it will affect health care costs, infrastructure costs, job turnover rates, worker safety, employment, and lost economic development from high-tech or information industries that do not want to locate near a cement plant.

–How does Titan plan to clean up it’s plant site and limestone mine after its economic life is over? How can the citizens of New Hanover County be sure Titan will have enough funds to remediate and clean-up the site in 30 to 50 years? Will they be required to post a remediation bond. How much will that be and will it be enough to meet estimated clean-up costs?

That’s all for now. We’ll surely have more later, or feel free to throw in your own concerns. Remember, the Army Corps EIS process is supposed to be your opportunity to have input into this process. So input away! And show up for the big event on July 1.