Sunday, October 4, 2009

What we have a comunicate!

Warning! Boring regulatory discussion below.

Whoa pardner! Where does thou get thy information? First off, a disclaimer: I have no dog in this hunt. What I care about is sound conclusions based on actual – and sound – information. Second, I am a pragmatist – I look at all angles to come to the best course of action. This does not make me pro or con and I hope it does not lead to any bias on my part.
Cement maker TXI withdraws request to burn tires in Midlothian
Two newspaper articles on this. and My interest is on how the public looks at an issue involving risk and exposure. Poorly is my conclusion, but it is not necessarily their fault. We - those of us who understand the situation - do a poor job of describing what is taking place. Another reason is that you can find a scientist to agree or disagree with any consensus (think cigarettes and global warming) – if you can’t trust scientists then who can you trust when it comes to data? And, to top it off, business has done a terrible job of consistently being good stewards of the air, water and land that we require for living. So there are a lot of balls in play here shaping the attitude of the people who, like it or not, make the decision of what takes place in their neck or the woods (NIMBY or “not in my backyard”).

So you take a confused public and you take an information source (news) that pulls from the same ignorant or misinformed or biased populace and what do you get? Rehashing of incorrect information. One reason for this is that newspapers and news shows rely on a limited source for what they report. One guy reports it and everyone picks up on it. The “fact” checking was supposed to be done before it went out on the wire. So the reason we have poorly informed and clueless citizens when it comes to complex issues such as risk and exposure, rests not just on the propaganda “no harm here” purveyors or the NIMBY folks who want a risk free world, but on news organizations that do not make sure their information is correct BEFORE they send it out.

Case in point:
The plants produce 6 million tons of cement a year. According to the most recent EPA statistics, the plants in 2007 emitted about 300 tons of sulfuric acid, nearly 20 tons of benzene, and smaller amounts of mercury, chromium, manganese and other chemicals.
The statistics came from where? The TRI report? That really is the only place one would get this information. So I looked up the TRI report for TXI in Midlothian, Texas. I even went to an EPA site that consolidates the information. (Note 2007 is the most recent data available). [Note: the quote states "plants" so this information may have been combined for all TXI or all cement kilns]

Where did the amount of “20 tons of benzene” come from? And, 522,118 pounds of sulfuric acid equals 261 tons.

Now I don’t fancy myself an expert on TRI Form R reporting, but my read of the information TXI reported is this:

  • The total amount (in pounds) of the sulfuric acid released to air, water, land, and underground injection wells during 2007 Through 5.2 Point source air emissions occur through confined air streams such as stacks, vents, ducts, or pipes was 522118 pounds.
  • The “Annual quantities of the chemical associated with all source reduction and recycling activities” reports 522118 pounds as “Total other on-site disposal or other releases.”
So what this data states is: Of the 522,118 pounds of sulfuric acid emitted, 522,118 pounds of sulfuric acid were “released on-site……. to mediums [which] include fugitive and stack air emissions, discharges to water bodies, underground injection to class II-V wells, land treatment/application farming, RCRA subtitle C surface impoundments, Other surface Impoundments and Other disposals. This total does not include on-site releases or disposal due to catastrophic events.”

Now why the EPA puts this data in a section called “source reduction and recycling activities” is beyond me, especially when TXI reports “0” source reduction and none of the “mediums” described are recycling activities. So the question remains - what is taking place at TXI with this sulfuric acid? Well what we know is this; 522,118 pounds of sulfuric acid is emitted “through confined air streams” and is sent as a waste stream for mechanical separation, scrubbing, and incineration (thermal destruction other than use as a fuel).

Now logic tells me to stop here before I start speculating all over the place. Logic also tells me that the reporter should have asked the question “how much is actually released into the air?” All the TRI does is track what is released, it does not track what is actually available for human health exposure or actual environmental harm. It’s all about the risk paradigm, if there is no exposure there is no risk, regardless of how much is emitted on a TRI report.

Is TXI’s operation contributing to health or environmental problems within the community? I don’t know. What I do know is that the article regarding their operation was flawed which would normally lead some to say “yes.” What we have here is a failure to communicate.

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