By Bill Spinks
The citizens group Midlothian Breathe has received a detailed air-quality study commissioned by the group against proposed changes at the local Holcim plant.
Consultant Dr. Ranajit (Ron) Sahu said in his report that he has reviewed two documents pending issuance of the proposed permit for Holcim’s Midlothian plant by the Texas Commission on Environmental Quality: the application for the permit, and an air quality analysis that was performed in February of this year.
In addition, Sahu said, certain email correspondence between TCEQ staff working on the permit and Midlothian Breathe were also reviewed.
Holcim is one of Midlothian’s largest employers. Its parent company, LafargeHolcim, employs approximately 75,000 employees in around 80 countries, according to its website. Holcim is only one of three huge cement plants in Midlothian, along with TXI and Ash Grove.
In June 2019, Holcim’s Midlothian plant submitted a permit request to the TCEQ. The request asked that Holcim have its cap on carbon monoxide emissions removed so that the production from each of Holcim’s kilns can be doubled. The filing also requested that Holcim be allowed to increase its use of pure petroleum coke from 60 percent of its “flexible” fuel to 100 percent.
As a small group, Midlothian Breathe has been seeking reasonable answers from the TCEQ (and the U.S. Environmental Protection Agency) in relation to air emissions from Holcim’s Midlothian plant activities as well as the impacts of those emissions on the local community.
Petroleum coke, or “petcoke,” is the final solid residue from the refining process, usually from oil sands. While petcoke itself is not considered highly toxic or carcinogenic, the use of it can form a very fine dust — as small as one-thirtieth the width of a human hair — that can lodge in the lungs and cause serious health problems.
In a letter to the Midlothian Mirror in February, Holcim plant manager Michel Moser wrote that petcoke “is only one of the fuel sources used at the Midlothian cement plant. Other fuels used include natural gas, coal and alternative fuels such as waste tires that would otherwise be landfilled.”
Moser added that Holcim has a global commitment to reduce its carbon footprint and run sustainable operations.
“We are committed to producing quality cement that is crucial to the economy of North Texas, and to do so in a manner that meets all applicable federal and state environmental regulations that have long been established to protect human health and the environment,” Moser wrote. “We live here in Midlothian, so we take our responsibility to protect our environment and the health and safety of our 150 employees and our community very seriously.”
In his analysis, Sahu said he focused on the major or more important issues that need to be addressed.
Issues identified by Sahu include:
• lack of support for many critical assertions,
• lack of support for significant technical assumptions,
• lack of explanation of key technical statements,
• misapplication of EPA’s applicable PSD rules especially in connection with implementation of the so-called “capable of accommodating” provisions of the PSD rules,
• lack of enforceability of many of the permit application’s source emissions assumptions.
“In general, the permit application and the Power Engineers modeling analysis contain significant technical and regulatory issues that should be addressed before TCEQ issues the desired PSD permit based on these documents,” Sahu said.