The sharp-eyed Mom, furious that these children would be located this close to such a large pollution source, actually called in to the Curtis Wright show one morning when Wright had a representative from the School Board on air to discuss the redistricting. The School Board official said he knew nothing about the new school’s proximity to the proposed cement plant. Just one more example of poor planning on our county’s part, because the Titan proposal was never brought before the county’s planning department.

As we’ve noted elsewhere on this site, a ground-breaking study conducted last spring by researchers at the Texas Health Science Center showed for the first time a link between autism rates in Texas public schools and the distance to industrial sources of mercury. “We suspect low-dose exposures to various environmental toxicants, including mercury, that occur during critical windows of neural development among genetically susceptible children may increase the risk for developmental disorders such as autism,” the authors wrote. According to the article on the study in Science Daily, “The new study findings are consistent with a host of other studies that confirm higher amounts of mercury in plants, animals, and humans, the closer they are to the pollution source. The price on children may be the highest.”

KS

Sorry, but I can’t resist the comment the Titan spokesman made about locally produced cement being more “environmentally friendly.” Let’s ignore for the moment their comparison of pollutants produced from importing cement via rail from (the horror!) South Carolina or Virginia, or via ship from anywhere else along the Eastern Seaboard versus a massive coal-burning cement kiln running 24/7 for 50 years. As a multinational cement conglomerate that exports its product around the globe, their sudden interest in producing locally is really touching, and probably has nothing to do with rising fuel prices. And by the way, as the Star-News noted in their big cement story on June 29, our region used roughly 878,000 metric tons of cement from 2003 to 2007. One sharp reader pointed out that amounts to 220,000 tons a year (or 175,000 tons if the years are inclusive). The plant they propose will pump out 2.3 million tons a year. So what are they going to do with their annual surplus production of 2.08 million tons? In the Port City? Anyone….anyone?

(hint: can you spell E-X-P-O-R-T?)

JB

This is the critical first public meeting in the permit process. If Titan doesn’t get its permits, it can’t build the plant, so come out and tell the Army Corps everything you are concerned about.

Here’s how EIS scoping meetings typically work:

Army Corps officials will give a rundown of the process and then break everyone into groups based on subjects of concern (Public Health, Air, Water, Aquifer, etc.) Then they’ll go around and ask everyone what concerns them about the proposed plant and what they want included in the EIS. (Haven’t a clue as to what to ask them to include? Cut and paste from the list below or click on the links to the left below the “Scoping issues” that concern you the most. Then ask whatever else you deem appropriate.)

They’ll write all our concerns and questions 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. Since this is such a massive project that will have major impacts on public health, the environment and our economy for the next half century, we feel the Corps needs to commission several independent studies to let us know exactly how this plant will affect our children and community.

Titan may run from public forums sponsored by the Star-News, but they can’t hide from the Corps of Engineers, so we need as many people at the scoping meeting as possible to make sure our concerns are voiced in each breakout group. If you can’t attend, or you have a detailed list, you have until 4:15 pm on July 15, 2008 to 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.

PUBLIC HEALTH

We respectfully request a full Health Risk Assessment conducted by an independent non-biased organization such as the University of North Carolina School of Public Health or the Duke University School of Public Health to address the cumulative health impacts of the proposed cement plant on communities and high-risk populations in Brunswick, New Hanover and Pender Counties. Including:

–-The impact of Titan’s proposed 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 cement plant.

–The impacts of Titan’s proposed mercury emissions, now and any increases in the future, on local recreational fisheries, consumption advisories for those fish, and the potential impacts on prenatal health, including any possible increases in birth defects, neurological disorders, behavioral disorders, and autism.

–-The impacts of NO2 and SO2 on public health, including increases in acid rain and smog,

–-The impacts of CO on human health, 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.

–-Titan has said they are considering burning tires at the Castle Hayne plant. Many other cement kilns also burn hazardous waste. What are the health impacts, including increased potential mortality and increases in cancer rates from the 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, and the potential for the fugitive dust to reach communities or schools in the counties.

–We request an independent study of prevailing winds and the smokestack plume to determine the type and amounts of the contaminants coming from the plant’s stack emissions, vehicle emissions, and fugitive dust will fall within one, five, ten, 15, and 20 miles of its stack.

–Since Titan and other limestone mining companies are suspected of contaminating the aquifer beneath their Florida mines with benzene, what would be the health impacts of the contamination of the Pee Dee and Castle Hayne Aquifers with benzene and other pollutants from Titan’s proposed 1200-acre limestone mine, and how would Titan safeguard the counties’ primary water source?

WATER, WETLANDS, AND THE ENVIRONMENT

Due to the extremely large size and scope of the proposed cement plant and limestone mine and the major potential impacts on a critically important water sources, we respectfully request a complete hydrological impact study of the proposed plant on local surface waters, groundwater, and aquifers, to be conducted by the U.S. Geological Survey, which has done similar studies in Brunswick and Onslow Counties. This study should address, among other things, the impacts of the mine and plant on the availability of clean ground water and surface waters in adequate amounts for present and future needs.

– What will be the impact of increased nitrogen pollution from the plant on our local rivers, sounds, and estuaries and its potential effect on algal blooms, shellfish and sport fisheries? How does Titan plan to safeguard our watershed from nitrogen pollution?

–-What is 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?

–Please determine the exact amount and type 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?

–What is the precise amount (not estimates) of mercury emissions that will be released from plant at current projected clinker rates, given the exact analysis of the mercury content in the local limestone, in the type of fly ash planned to be used and the type of coal that will be used. Other cement plants in the United States that currently produce similar amounts of clinker emit nearly twice the estimated amount of mercury emissions from the Titan plant.

–-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? How much money will the county lose in federal funds if we become a non-attainment area.

–-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 provide local values and ecosystem services in one place that cannot be replicated elsewhere?

–-Exactly how much water will Titan take from the Pee Dee and Castle Hayne Aquifers to dewater its mine and in its cement manufacturing operations, and what will they do with that water? How many future homes would that water supply if left in the aquifer?

-–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. We therefore request a thorough independent study on the impacts Titan’s dewatering system would have on the chromium deposit under Elementis. This should include what Titan would 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 or into the Castle Hayne Aquifer?

–-Does Titan have enough raw materials 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? 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 or state-listed endangered or threatened species or species of concern, particularly fish and amphibians that are particularly sensitive to mercury emissions? We formerly request an independent survey of threatened, endangered, or rare species of plants and animals on the proposed mine site and surrounding areas and streams.

–-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? Will their emissions contaminate local oyster and clam beds?

–Island Creek serves as prime habitat for numerous ducks and other migratory species, as well as several neotropical songbirds. How will emissions from the proposed plant and the destruction of nearly 500 acres of wetlands affect these species?

–-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?

SOCIAL AND ECONOMIC IMPACTS

–-There is great debate among economists on the actual economic impacts of the proposed Titan cement plant. Because of the tremendous size and scope of this project, and its potential to have serious impacts on the economy of our region, we request a full, independent social impact assessment, from a university or qualified firm, such as Impact Assessment, Inc., which has done such studies on the North Carolina coast in the past. Such a study should include both short-term and long-term socioeconomic impacts of the proposed Titan cement plant, including how it will affect health care costs, infrastructure costs, wages, job turnover rates, worker safety, employment, real estate values, and lost economic development from high-tech or information industries that do not want to locate near a cement plant. It should also include the impacts of increasing mercury levels in local freshwater, brackish, and saltwater fish species on the local economy, which receives millions in revenue each year from recreational fishermen and is a primary incentive for attracting new residents.

–Island Creek is a known area of Native American activity. We therefore request an archaeological survey of the proposed mine site by independent archeologists to determine the archaeological significance of the sites in this area.

–-How does Titan plan to clean up its proposed plant site and limestone mine after its economic life is over? How can local citizens be sure Titan will have enough funds to remediate and clean up the site in 30 to 50 years, particularly since the cement industry has historically been a boom and bust industry. 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 after inflation?

–We request an independent study on the exact savings projected in cement and/or concrete costs to local builders and construction firms working on local development and infrastructure projects to purchase cement/concrete from current suppliers versus purchasing such products from the proposed Titan plant based on independent projections of cement demand over the next 50 years.

–How much of its cement production does Titan plan to export?

–Many industries and federal agencies expect the next Congress and Administration to place a cost and/or tax on carbon emissions. How will a carbon tax affect the economic impact of the proposed plant on our counties? Since it will emit millions of tons of CO2, will it limit future industries from coming into our region if a carbon tax is regulated in the future?

–Since CO2 is a powerful greenhouse gas, and our coastal region is among the most susceptible to sea-level rise from global climate change with millions of dollars in coastal real estate at risk, we request an independent study to look at the potential for sequestering CO2 emissions from the proposed plant, and how such emissions, if not sequestered will contribute to the state’s total CO2 emissions and be affected by efforts to reduce them.

TRAFFIC AND INFRASTRUCTURE

Given the size of the proposed mine and plant, and the potential for 30,000 to 40,000 large truck trips each year on our local roads and bridges, we request an independent traffic and infrastructure impact study to look at public safety, accident rates, fatality rates, and infrastructure and congestion costs associated with the proposed facility.

–Such a study should also include the impacts of thermal (heat) pollution on the surrounding area, including its impacts on the generation of fog on major and minor nearby bridges over the Northeast Cape Fear River and Island Creek.

–The study should also include the impact on air traffic of the proposed facility, since it sits in the flight path for Wilmington International Airport.

As a reminder, the time/place of the Army Corp’s Environmental Impact Statement scoping meeting is listed below:

Wilmington Christian Academy
1401 North College Road
Wilmington, NC
July 1 at 6:00 PM

Please check back with the StopTitan.org website where we will have a new post up by Monday, June 30th, to better assist people with their scoping questions. The information will have specific, printable headers for each main category (air, water, wetlands, aquifer, etc.) with examples of questions and areas of concern. You will be able to either print this information out and take it to the July 1st scoping meeting or use it to submit your questions directly online. The comment period extends until July 15th.
Full story on starnewsonline.com

1. The largest cement producer in the US (Texas Industries, Inc.) is also the # 1 polluter in the county where it operates (Ellis County, Texas)
2. The second and third largest US cement producers (CEMEX, USA and LaFarge North America) are also the single largest polluters in their respective counties of San Bernardino, CA and Alpena, Michigan
3. LaFarge Cement (the third largest producer) has a clinker production rate of just over 2.2 million tons per year (from a Portland Cement Association 2006 report) and emits up to 580 lbs of mercury per year. According to Titan’s draft air permit under review with NC Department of Environment and Natural Resources (NCDENR), Titan plans to produce 2.19 million tons of clinker per year. Oddly, Titan estimates their mercury emissions will be 263 lbs. per year even though the production rate is almost the same as LaFarge’s. Remember, mercury emissions are reported as estimates and are highly sensitive to the mercury content not only of limestone but also the type of coal and fly ash used (fly ash is a by-product of coal combustion). LaFarge used to report their mercury around 40 lbs. per year until it was discovered they were vastly underreporting their emissions, primarily because of the high mercury content of the fly ash they were using. Titan says they will burn coal and use fly ash from Progress Energy. The type of coal that comes from the Appalachian and Gulf Coast regions of the US is known to have a high mercury content as does the fly ash from burning this type of coal. We should demand a more thorough investigation of the testing methods and exact mercury emissions from Titan’s Castle Hayne plant. Otherwise we can assume, like at the LaFarge plant, that Titan’s mercury estimates might not be completely accurate
4. New Hanover county already ranks 6th highest in the state for mercury emissions. Titan’s proposed plant will move us up to 4th in the state. It will be the # 1 mercury emitter in New Hanover county. This number could be even higher if Titan’s mercury estimates are not accurate
5. An even more sobering fact is that when the local regulatory authorities in Michigan discovered the Lafarge plant was emitting close to 600 lbs. of mercury a year–ten times more than previous estimates–they sued to try and force the cement plant to reduce their mercury to comply with the state of Michigan’s mercury limits. Guess what? They lost. The courts said the Michigan regulatory authorities charged with keeping industries like cement plants in compliance with state and federal regulations had no authority to demand LaFarge to lower their emissions because there was no state law on record specific to cement plants. North Carolina, with no operating cement plants, will likely be just as vulnerable and just as incapable to regulate a heavy polluter like Titan Cement
6. If this is not maddening enough, EPA scientists estimate that 1 in 6 American women of childbearing age has enough mercury in her body to put her child at risk, should she become pregnant.

North Carolina, specifically, New Hanover county, does not need any more mercury sources and most certainly does not need to offer incentives to bring a heavy polluting industry into our community. Besides, there is no shortage of cement plants in our area. Every state that borders NC has at least one operating cement plant. There are 7 plants within 400 miles (including one plant in SC within 250 miles). No matter what savings Titan and other’s say will be gained by having a cement plant in our area, the increased pollution and degradation of our natural resources is not worth it. –Kelly Stryker

The ad weakly addressed only one economic argument but ignored the significant negative impact Titan’s pollution would have on real estate and tourism, our ability to attract non-polluting industries or health-care for the people the pollution sickens.  Surprisingly, Brod chose to argue (ineffectively) with several scientific studies of southern cities showing low-tech industries typically reduce long-term net economic activity and jobs due to increasing input costs, congestion of local infrastructure, and the perception that an area is favoring dirty heavy industries.  If we had no other advantages to offer businesses, the Cape Fear region would be desperate for the jobs Titan says might be coming.  But, our area has so much to offer that we would have a much easier time enticing clean businesses to the area without polluters like Titan. 

Moreover, the ad clarifies that Titan has two sets of numbers where job creation are concerned – one they give to the public and another they use internally.  In paragraph two, the ad asserts there will be an economic impact of between 1730 and 2133 jobs, but not a shred of evidence is presented to support this unbelievable assertion.  In paragraph nine, Brod clarifies that his “upper-bound estimate of 424 additional workers is small potatoes when compared to the county’s labor force of 100,000 people”.  They don’t even believe their own public estimate of job growth, not that a few jobs would compensate for all the other costs to the community.

Just for good measure, the ad ends with a stunning act of intellectual wizardry, claiming “the most reasonable conclusion is that significant economic benefits will accrue” without presenting any reasoned argument in favor of that conclusion.   Yes, that may be the most reasonable conclusion if one lacks completely the ability to reason.

As a small business owner who moved my company here in 2001, I can tell you the one strike against Wilmington in our survey of possible locations was water quality, due to the widely-publicized fish kills in North Carolina.  I am embarrassed to say that I was unaware before moving just how bad the air and water quality here really are.   A visit to ScoreCard.org, an independent pollution reporting site, makes it plain that we just cannot afford to continue to court heavy industry.  We are among the worst 10-20% of counties in the country for all six of the major pollution categories. 

Let’s change course, New Hanover!