The Issues

Public Health — Air

More than 200 local physicians, hundreds of nurses and other health care providers and the N.C. Pediatric 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 by countless other organizations as one of the largest environmental threats to public health. Locally, the N.C. Division of Air Quality 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 about how Titan’s cement plant and mine will negatively impact our air quality. A few of these studies can be found here.

According to data on toxic and hazardous air pollutants listed in Titan Cement’s current air permit application. Titan will be one of the largest sources of air pollution in our region. We have compiled summary charts to illustrate the potential impacts Titan would have in our region and encourage you to do review this information. In New Hanover County, we estimate that Titan will 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, carbon monoxide, volatile organic compounds, lead, arsenic, ammonia, beryllium and selenium. Titan will also be the third-largest source of mercury in our area. 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 like Titan into the highly toxic form of methlymercury that accumulates in fish and other wildlife. Numerous studies have documented the toxic effects of mercury. Developing fetuses are at particular risk.

Titan plans to operate in our region for a minimum of 30 years and we do not know the impacts from long-term exposure to multiple pollutants like those 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 Titan Cement project, our health care community is asking for a full, comprehensive study of cumulative and long-term impacts from the Titan project, especially since we estimate that more than 8,500 students attend schools within five miles of Titan’s site. Additionally, according to the American Lung Association, more than 48% of our county is already considered at risk from airborne pollutants because of existing respiratory illnesses like asthma, emphysema and cardiovascular disease. Our newest elementary and middle schools, which are 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 pumps approximately 1-5 million gallons of fresh water per day. Although exact rates of withdrawal have not been disclosed, Titan has stated in meetings that the Titan operation would potentially pump from 8-16 million gallons a day of fresh water from the aquifer. Pumping an average of 12 million gallons per day of fresh water 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 are planning for future scenarios of limited or compromised drinking water supplies. We have no idea what the long-term impacts of this project will be on our region’s water quality and water supply until we see the results of a comprehensive groundwater study, hydrologic modeling effort and a water use permit.
Additionally, most of the homes around the Titan property depend on private wells for drinking water, and Titan has admitted that their proposed mine will lower the water table in the area. Saltwater intrusion is an existing risk to private wells in our area and we have no information on whether Titan’s water use will exacerbate the problem. New Hanover County recently invested millions of dollars in a new well field to serve the northern portion of the county. As recent droughts have demonstrated, we have far too much at stake to allow this project to receive an air permit and begin construction before we know the full lifetime impacts of this massive plant and mine on our critical water supplies.

Concerns about contamination in our drinking water from Titan’s mining activity are not unfounded. Ironically, at the same time Titan officials were in negotiations with New Hanover County Commissioners and other officials about the proposed North Carolina Titan cement plant and mine, Titan’s mines in Florida were being closed down because of concerns over benzene contamination in the Miami-Dade drinking well fields. For more information on the Titan/Florida benzene contamination issue, click here.

Use of Hazardous Waste/Tires/Alternative Fuels

The current air permit application under review by the N.C. Division of Air Quality (dated Feb. 2011) is asking to burn alternative fuels and biomass, in addition to coal.

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 and saw dust. Today, many U.S. cement plants meet between 20 – 70% of their energy requirements by burning alternative fuels. Many US 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 alternative fuels can increase toxic air pollutants—many of which cause cancer—posing an even greater public health threat to our community, especially our children. So the question is: Are we permitting a cement plant or a hazardous waste incinerator? Will Titan burn tires and solvents? If so, how will that impact those forced to breath the air around the stack? Cement plants that burn tires have large piles of tires stored nearby which can introduce many issues such as mosquitoes and the threat that the piles of tires can catch on fire.

Our community has a right to know if Titan plans to ever burn hazardous waste, tires and other forms of alternative fuels—and exactly what would be the health and environmental impacts from burning these types of fuels. For more information on tire burning, click here. For more information on burning hazardous waste, click here.

How Will Titan Impact Current Contamination Problems?

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

At least $3 million dollars have been spent trying to prevent the massive chromium plume at the Elementis Chromium site near Titan from contaminating our water supplies—a spill 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 oil that seeped 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 our state’s 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.

The only way to address these concerns is through a comprehensive, hydro-geological study on Titan’s water use plan before they receive an air permit and begin construction. 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 Titan’s water withdrawals will have on our local water supply.

Real Estate, Future Expansion Impacts and Conservation Lands

We do not know how the Titan plant will 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 can not know how the Titan project will affect property values 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 incompatible mixed use of heavy industry, schools, and neighborhoods needs further evaluation to ensure that existing property owners are not unfairly and negatively affected by Titan’s project. As you may have read recently, Titan threatened to sue our planning department if they went forward with amendments to local planning regulations that would require heavy industrial projects to go through a special use permit process. This process would allow a more careful review of impacts at the local level. Special use permits are widely used throughout North Carolina and the United States. Titan’s threat to sue our county underscores some of the many concerns we have with this project and with this company. Click here to read about Titan’s threats to sue.

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 community members and by many local officials, but Titan did not want any restrictions on their future business plans so they sued. 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. The complete scope of the plant and mine needs to be available and if needed, restrictions made, to limit significant impacts on property owners closest to the Titan plant and mine. 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 does not require nor contain details about the future scope of the Titan project, which will most certainly expand significantly beyond the scope of their current requires. As such, the regulatory community, our elected officials, and the public’s understanding of the full and long-term effects of this plant will be severely limited until the federal EIS is completed.

Will Titan be allowed to blast in their quarry 24 hours a day? How much noise from blasting and traffic will result from the mining operation, especially the hundreds of large diesel dump trucks running back and forth along the same roads used by school buses and residents of the Castle Hayne community? If Titan’s quarry and cement plant are found to have a negative impact on our local community what can our community do to address the issues after the fact? Without knowing the full scope of their mining plans before Titan receives any permits, our community will be unable to place reasonable restrictions on Titan’s mining activity as other communities around the nation have done. We must know all impacts before any permits are issued.

We have not assessed how Titan’s operation will 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, parklands, riparian corridors and critical ecosystem components of the NE 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 will impact this significant investment of public money.

Economy

We do not know the impacts, short or long-term, on our local economy or the true economic benefits or costs of Titan’s project.

The only economic study ever made public used input data for a ready-mix plant, not for a cement plant and mine. Professors at the UNCW Cameron School of Business, who have studied the economic impacts of heavy polluting industries, have stated the project will likely have a negative economic impact on our region. They also state that Titan’s claim of 160 jobs is inflated and that the project will only result in fewer than 50 permanent jobs, a fact which has not been refuted by Titan’s representatives. With many of our area’s prominent business leaders stating their concern about the Titan project, we need to know how this 50 + year plan will impact our region’s economic future and how this one industry will affect our area’s stated goal of attracting less-polluting, high-tech industries.

Pending SO2 Nonattainment Designation for Our Area

New Hanover County is currently under consideration by EPA for non-attainment status from our current SO2 emissions. Titan’s General Manager, Bob Odom, is on record as saying this is not Titan’s issue—but if Titan’s air permit is approved, it will be the 4th largest source of SO2 in our county and one of our area’s most heavily polluting industries. How will this affect existing and future industries that may want to come to our county? Cement plants are the 3rd largest source of industrial pollution in the nation. We need to know how the Titan project will affect the non-attainment issue for SO2 and if it will push us toward non-attainment status for other toxic emissions, such as carbon monoxide, nitrous oxide, or ground level ozone.

Impacts to Marine and Other Wildlife Ecosystems

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

Several state agencies 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 will emit mercury that will deposit into the river, impacting the fish and other aquatic species. If Titan plans to operate for 50 + years, we need to know the long-term impacts on emissions to our commercial and recreational fishing industries, especially given recent studies that state the commercial fishing industry brought $82.3 million and the recreational fishing industry generating $ 2.1 billion and more than 24,000 jobs statewide.

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 will affect their environment and/or health. The area in which the Titan cement plant would be built has high concentrations of poor people and people of color. Census data indicates that areas of highest poverty – between 20% and 40% -- and highest 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. In fact, Titan’s previous draft air permit was released before the public was allowed to review or comment on the permit. Titan intentionally manipulated the permit process to deny the citizens the right to full disclosure and public comment, and that strategy continues today.

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 will require the immediate destruction of hundreds and possibly thousands acres of wetlands. These wetlands are critical components of the Cape Fear system, 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 impacts to our wetlands from this project. We also do not know the full impacts to tidally influenced wetlands that provide important spawning areas for such important species as the federally endangered shortnosed sturgeon (Ancipenser brevirostrum), Atlantic sturgeon (Ancipenser oxyrinchus), blueback herring (Alosa aestivalis), alewife (Alosa pseudoharengus), and stripped bass (Morone saxatilis).

Titan’s project has the potential to impact areas designated as primary nursery areas (PNA). 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 Primary Nursery Area (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. 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.

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


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