The Issues

Public Health — Air

More than 200 local physicians, hundreds of nurses and other health care providers, the North Carolina Pediatric Society, the North Carolina Asthma Alliance, and the New Hanover-Pender County Medical Society have all stated their concerns about the Titan project and its potential to significantly impact our public health—especially for children and the elderly.

According to the Environmental Protection Agency, cement plants are the third-largest source of industrial air pollution in the U.S.  Air pollution has been identified by the EPA, the World Health Organization, the Center for Disease Control, and countless other organizations as one of the largest environmental threats to public health. Locally, the North Carolina Division of Air Quality (DAQ) has identified particulate matter pollution and ground-level ozone as two of North Carolina’s biggest air pollution problems. Numerous studies support our community’s concerns that Titan’s cement plant and mine would negatively impact our air quality. A few of these studies can be found here.

According to data on criteria and hazardous air pollutants listed in Titan Cement’s current air permit application, Titan would be one of the largest sources of air pollution in our region. We have compiled fact sheets and summary charts to illustrate the potential impacts Titan would have in our region and encourage you to review this information. In New Hanover County,  Titan would be the largest source of benzene and polycyclic organic matter—pollutants associated with causing cancer in humans – and the second-largest source of particulate matter, nitrogen oxides, mercury, carbon monoxide, lead, arsenic, and ammonia.  New Hanover County already has some of the highest mercury emissions in the state. Our area is very susceptible to the conversion of airborne mercury from smokestacks into methlymercury, the highly toxic form of mercury that accumulates in fish and other wildlife. Numerous studies have documented the toxic effects of methylmercury, with developing fetuses considered to be at particular risk.

Titan plans to operate in our region for up to 50 years, which would result in broad, long-term exposure to multiple pollutants emitted from Titan’s smokestack. Because of the potential for significant and long-lasting negative health impacts to our community from air pollutants emitted from the plant, over 200 Wilmington-area physicians have signed the petition against the Titan’s proposed cement factory, especially since more than 8,500 students attend schools within five miles of Titan’s site.  According to the American Lung Association, more than 15,000 New Hanover County residents are already considered at-risk from airborne pollutants because of existing conditions such as asthma, emphysema and cardiovascular disease. Our newest elementary and middle schools, less than two miles away from the proposed site, are of particular concern. We cannot continue to ignore these important public health issues raised by our local medical community.

Public Health — Water

How much water will Titan remove from our aquifer over the life of their project?

It is estimated that the current mineral mining operation by Martin Marietta at the proposed Titan site dewaters the mine by pumping approximately 2.5-5 million gallons per day from our groundwater aquifers. Although exact rates of withdrawal have not been disclosed, Titan has stated in meetings that their proposed operation would withdraw and discharge up to 16 million gallons of water per day from the aquifer. Pumping an average of 12 million gallons of water per day from the aquifer would remove nearly 4.4 billion gallons of potential drinking water from the system each year, at a time when our county and state governments are planning for future scenarios of limited or compromised drinking water supplies. 

Additionally, many of the homes around the Titan property depend on private wells for drinking water, and Titan has admitted that their proposed mine could lower the water table in the area. Saltwater intrusion is an existing risk to private wells in our area and Titan has provided no information on whether their water use would exacerbate the problem. In addition, the Cape Fear Public Utility Authority  was recently forced to shut down some of its wells near Porter’s Neck, as they were concerned  that the wellfield’s withdrawals, averaging just 3.25 millions of gallons per day, were contributing to ponds and wetlands drying up in the area and impacts to residential home foundations.

Will Titan Burn Hazardous Waste/Alternative Fuels?

Titan's current air permit for their Castle Hayne cement plant stipulates that they may only use coal and pet coke as fuel for the kiln, but they could later request a permit revision to allow them to burn tires, hazardous waste, and other heavy-polluting fuels for their operations.

Within the cement industry, the term “alternative fuel” refers to substituting more traditional fossil fuels like coal, with byproducts from other industries. Examples include tires, plastics, paper, packaging and solvents. Biomass is another form of alternative fuels and can include animal droppings, wood chips, dry sewage sludge and municipal waste. Today, many U.S. cement plants meet over half of their energy requirements by burning these fuels. Many U.S. cement plants also burn “hazardous waste” to offset their fuel costs. Examples of hazardous waste include petroleum sludge, medical waste, paint thinners, and cleaning solvents. Studies show that burning hazardous wastes, tires, and other byproducts as fuel can increase toxic air pollutants—many of which cause cancer—posing an even greater public health threat to our community, especially our children.  Again, Titan does not currently have a permit to burn hazardous waste, but many cement companies first establish themselves by getting their necessary permits for a conventionally-fueled plant, then later go back and apply for a separate permit to save themselves money by burning these wastes.  This is part of the “divide-and-conquer” strategy which we have already seen from Titan, as they have bypassed a comprehensive review of their plant to first obtain their air permit.  Click here to learn more about hazardous waste incineration at cement plants in South Carolina. 

How Will Titan Impact Current Contamination Problems?

We do not know how Titan’s proposed water use would affect ongoing federal and state efforts to isolate previous contamination of the aquifer nearby from other legally permitted industries.

Since 1975, a massive hexavalent chromium plume has contaminated  the groundwater directly beneath what is currently the Elementis Chromium plant – immediately adjacent to Titan’s property.  Since the plume was discovered, the owners of the site have been pumping contaminated water from the surficial and limestone aquifers in order to keep the plume from spreading.  The spill is so hazardous to public health it was designated a federal “Superfund” site.  Before any permits are issued, we need to see the results of an impartial, hydrologic modeling effort and groundwater study to evaluate the potential for Titan’s operation to cause additional spreading of the chromium plume. We also need to understand how lowering the water table would affect the capture of benzene and other potentially hazardous hydrocarbons from the fuel oil that leaked from fuel tanks  into the bedrock at the Ideal Cement plant site in the 1980s. Both spills are classic examples of why local elected officials cannot depend solely on state and federal environmental regulations to protect their citizens, but must take active roles to prevent such threats to public health, our aquifer, and our coastal environment before they occur.

Safe and plentiful drinking water is critical to the health and economic growth of our region. Residents, especially those living closest to Titan’s site, deserve to know the full impacts that Titan’s water withdrawals would have on our local water supply. 

Real Estate, Future Expansion Impacts and Conservation Lands

We do not know how the Titan plant would affect real estate values, businesses and farms located near their plant.

Until we assess long-term impacts from a massive cement plant and mine to the surrounding properties, we cannot know how the Titan plant would affect property values for real estate and other businesses in the area. Future residential development will most likely occur in the northern part of the county over the next few decades, and the close proximity of heavy industry to schools and residential neighborhoods needs further evaluation to ensure that existing property owners are not unfairly and negatively affected by Titan’s project.

New Hanover County Special Use Permit for New Intensive Uses

In October 2011, the New Hanover County Board of Commissioners voted to create a new special use permitting (SUP) process for intensive industry – a requirement that had already been in place for such businesses as veterinaries, recreation facilities, and retirement homes, yet was not required for heavy intensive manufacturing industries.  After nearly five years of research by planning board staff, board hearings, and public input, the county’s planning board and county commissioner  both voted overwhelmingly to change the outdated zoning ordinance.  In essence, the SUP for new industrial firms creates an opportunity for public review, allowing our local government an ultimate say over whether a new industry is an appropriate fit for the community.  Area residents present at the hearings spoke overwhelmingly in support of the updated code, tired of the one-size-fits-all state and federal regulations that had allowed the county to become a pollution haven, with some of the state’s worst air quality and the highest levels of toxic releases

Throughout the exhaustive process of researching, presenting findings, drafting permit conditions, and planning board and county commissioner hearings, Titan has repeatedly threatened to sue the county if they are denied a special use permit from the county.  A similar issue played out in Virginia, when a Titan facility located in Chesapeake, Virginia, did not like a proposed waterfront development that was close to their property.  The waterfront development project was supported by a majority of area residents and by many local officials, but Titan did not want any restrictions on their future business plans, so they had their lobbyists fight the development project for years at the local level. Ultimately, the high-density development was built, but only after a prolonged fight with Titan and other industrial interests.  For more information about this, click here . 

We do not know how far Titan will expand their mining operation in relation to our elementary and middle schools and to adjacent neighborhoods and businesses.

We cannot allow Titan’s mining operation—with blasting, explosives, heavy earth moving machinery—to operate without any regard for nearby residents and schools. Titan’s Medley, Florida, mine is part of the Lake Belt mining district that covers more than 40 square miles—one-fifth the size of New Hanover County. The current air permit application neither requires nor contains these details about the future scope of the Titan project, which would most likely expand significantly beyond the scope of their currently-announced plans. As such, the regulatory community, our elected officials, and the public’s understanding of the full and long-term effects of this plant are still extremely limited.  Additionally, area residents could reasonably expect significant noise from blasting and traffic that would result from the mining operation, along with the hundreds of large diesel dump trucks traveling  the same roads used by school buses and residents of Castle Hayne.

We have not assessed how Titan’s operation would impact existing public game lands, natural areas, and conservation lands identified for acquisition and protection.

We all recognize the unique value of the Northeast Cape Fear River to this region. Over $111,000,000 in state, federal and private funds have been invested over the last 15 years to preserve public game lands, park lands, riparian corridors and critical ecosystem components of the Northeast Cape Fear River Corridor. This investment includes over $41,000,000 in grant funds from the NC Clean Water Management Trust Fund. We need to know how Titan would impact this significant investment of public money.

Economy

Because the economies of New Hanover County and the surrounding Cape Fear region are so dependent on natural resources, tourist perceptions, and quality of life, Titan’s proposed plant carries enormous risks to the future economic health of our community.

The only economic study used to justify the initial incentives offer to Titan by the county’s board of commissioners used input data for a ready-mix plant, not for a cement plant and mine.  In addition, the analysis, paid for by Titan Cement, used a best-case scenario, did not account for any of the negative impacts to existing and potential business firms, and likely significantly overestimated the “multiplier effects” of their overall impact.  The only type of analysis employed for their study was an “IMPLAN analysis,” a method preferred by industry because they are the easiest to perform and produce the largest  values most favorable to industry.

Two professors at the UNCW Cameron School of Business conducted a full economic analysis, released in 2012, and that study stated the project would likely have a negative economic impact on our region. The report also states that Titan’s claim of 160 jobs is inflated and that the project would result in fewer than 50 permanent jobs for New Hanover County,  which is far less than Titan’s public projections. Click here to read the summary of the report.  With many of our area’s prominent business leaders stating their concerns about the Titan project, including over 100 Businesses Against Titan, we need to know how this 50+ year plan would impact our region’s economic future and how this one industry would affect our community’s stated goal of attracting less-polluting, high-tech industries.

Despite the exhaustive nature of this comprehensive economic impact study, however, the models used were unable to account for both the unique natural resources that drive the Cape Fear region’s economy, and the full extent of damage that Titan’s cement plant could potentially wreak on industries dependent on those resources.  The principal models used for determining “dispersion” effects, or the number of jobs we can expect to lose as a result of having such a massive industrial presence added to our community, were based on statewide averages for heavy industry.  With considerably above-average reliance on tourism, natural resources, and recreation in the Cape Fear region’s economy, one of the authors of the study has stated that Titan’s negative economic impact could be far more extensive.  In 2011, the region reached an all-time high for visitor spending and the resulting economic impact, which was nearly one billion dollars.  Furthermore, this growing industry currently supports over 10,000 jobs in the area, which are ultimately dependent on the perceived attractiveness of the Cape Fear region to visitors.

Impacts to Marine and Other Wildlife Ecosystems

We have yet to assess how the additional mercury and other toxic emissions would affect our local commercial and recreational fishing industry.

Several state agencies, including the NC Division of Water Quality, the NC Wildlife Resources Commission, and the NC Division of Marine Fisheries have written letters of concern about the impacts from Titan’s emissions on our local fisheries. Local commercial fish distributors oppose Titan because of concerns about negative impacts to the fishing industry. The Division of Water Quality has stated that no more mercury can be deposited into the mercury-impaired Northeast Cape Fear River. Titan’s kiln would emit mercury that would deposit into the river, according to Titan’s own toxicology study, impacting the fish and other aquatic species. If Titan plans to operate for 50+ years, we need to know the long-term impacts of emissions to our commercial and recreational fishing industries, especially given recent studies stating that the state’s commercial fishing industry generated over $119 million and supported over five thousand jobs along the coast in 2011, in addition to a coastal recreational fishing industry worth nearly $2 billion.

Environmental Justice

The Environmental Protection Agency (EPA) defines environmental justice as “fair treatment and meaningful involvement of all people--regardless of race, color, national origin or income-- with respect to development, implementation, and enforcement of environmental laws, regulations, and policies.”  Fair treatment means that no group of people should bear a disproportionate share of the negative environmental consequences resulting from industrial, governmental, or commercial operations, or the execution of federal, state, local, and tribal programs and policies. Meaningful involvement means that potentially affected community residents have an appropriate opportunity to participate in decision-making about a proposed activity that would affect their environment and/or health. The area in which the Titan cement plant would be built has high concentrations of both people living below the poverty line and people of color. Census data indicates that areas of highest poverty – between 20% and 40% – and highest proportion of minority residents – between 30 and 50% – are immediately adjacent to the proposed site. In addition, subjecting our most vulnerable citizens to increases in air and water pollution raises the question of environmental justice, an issue not addressed in Titan’s air permit.

Wetlands

We have not assessed the immediate or long-term effects the destruction of wetlands will have on the critical functions that are provided by these wetlands.

The creation of Titan’s mining operation would require the destruction of hundreds and possibly thousands acres of wetlands. These wetlands are critical components of the Cape Fear River ecosystem, providing protection from floods, filtration of storm water runoff and nursery grounds for many important fishery species. Without knowing the full scope of Titan’s mining operation, we have no way to assess effects to our wetlands from this project. We also do not know the full effects to tidally-influenced wetlands that provide important spawning areas for such important species as striped bass (Morone saxatilis), blueback herring (Alosa aestivalis), alewife (Alosa pseudoharengus), and the federally-endangered shortnosed (Ancipenser brevirostrum) and Atlantic sturgeons (Ancipenser oxyrinchus).

Titan’s project has the potential to impact areas designated as Primary Nursery Areas (PNA’s).  The NC Department of Environment and Natural Resources defines PNA’s as natural areas “where larvae first move into and begin to grow. These areas are usually shallow with soft muddy bottoms and are surrounded by marshes and other wetland vegetation that provide protection from predators. Low salinity and the abundance of suitable food in these areas are ideal for young fish and shellfish to grow and survive.” As such, a plan for avoiding, minimizing, or compensating for direct and indirect degradation in habitat quality as well as quantitative losses that result from the project must be addressed before a site is chosen. Wetlands within and adjacent to the project site have a high significance in relation to the ability for the perpetuation of important fish species. This level of importance is clearly shown through the state designations of the NE Cape Fear River and Island Creek within the vicinity of the project as an Anadromous Fish Spawning Area (ASA) and a PNA. Impacts that are currently proposed are of such significance and would result in such adverse impacts, that the North Carolina Wildlife Resources Commission feels that there is no mitigation that could adequately address the proposed loss of these valuable wetlands.  Their 2008 letter to the Army Corps of Engineers reads, in part:

"Impacts that are currently proposed are of such significance and would result in such adverse impacts, that the NCWRC feels that there is no mitigation that could adequately address the proposed loss of these valuable wetlands. Mitigation through compensation, even within the same subbasin would not be able to protect these species and continue to provide appropriate habitat for spawning areas.”

Because the Cape Fear River Basin, and especially the Northeast Cape Fear River, is such a critical ecosystem and biodiversity hotspot for our region, a broad group of environmental organizations and state agencies operating as the Cape Fear River Partnership have developed a draft action plan for migratory fish in the Cape Fear River basin:

“…the river's migratory fish suffer from numerous threats that impact their numbers… Land clearing for development, industry, forestry, and agriculture can reduce riparian buffers (trees and vegetation along riverbanks) that serve to filter out excess nutrients and other pollutants from entering the river. Engineered water withdrawals, reservoirs, and inter-basin water transfers (where water is moved from one river basin to another for human use) alter the amount of water in the river—an essential aspect of migratory fish habitat health.”

Despite being considered a regional hotspot for biodiversity, a lack of adequate protection over decades of heavy development has left the Northeast Cape Fear River “highly stressed,” and Titan’s proposed mine and kiln, through the destruction of critical wetland habitat, loss of fish nursery areas, potential degradation of ground and surface water, and deposition of pollutants associated with their substantial air emissions, carries enormous risks to the regional ecosystem.  This, in turn, would put the regional health of our natural resource-dependent economy at considerable risk.


* These facts are from the permit application. Click here to view the full DAQ draft permit application.


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