CARMAN’S FINAL EDITION (via e-mail received 3-12-99)
Dr. Neil Carman’s Speech Oct. 25, 1998, to Citizens for Healthy Growth
paraphrased by EHC, edited by NC, received 3-9-99 by email, then reformatted
by EHC, then edited again by
Neil Carman--and now used with his permission (March 11, 1999).
Emphasis added by EHC.
“From 1980-1992 I worked with the Texas Air Control Board, a predecessor
agency to the TNRCC. Since
1992 I have worked for Sierra Club in Austin as an advocate for citizens
statewide who have problems with air pollution mainly from industrial sources.
When I worked for Air Quality Control Board in a region l
office, many of the permits issued from Austin were badly flawed, but
we didn’t know that until later.
“Sometimes we got citizen calls saying that there is a compliance problem at a permitted plant. But we were told by the state's permit engineers in Austin (who issued the air permits in the first place) that once a permit is issued it is impossible to revoke it (it takes an Act of God!). The permit engineers would tell us once the permits were issued and compliance problems occurred due to a badly flawed permit from Austin -- Now it's a compliance problem!
“The city officials didn’t care, even if people were dying of cancer, etc, the agency NEVER (except once or twice on a fluke) revoked any permit (it's a permitting agency foremost). There have been several thousand compliance cases on air pollution just since 1980, and some are repeat offenders. The local district court judges would not shut the non-compliant places down, not even temporarily, because they are all elected officials.
“There was one egregious plant that never operated within the permit
for even one day in eight years. Hydrochloric acid was emitted so
badly that it corroded car and truck engines as well as fences, buildings,
equipment and chemical storage tanks, but the plant's air pollution permit
was never revoked by agency
officials in Austin despite hundreds of violations. Instead, Austin
kept reissuing the permit, making it more and more complex but the company
continued to fail to comply month after month and year after year. The
air permit expanded from 1 to 15 pages, but still the plant never operated
legally for even one day unless it was completely shut down.
I have seen very few good permits, and we issued thousands of them.
Yet they DON’T EVER revoke them.”
“I have seen the UCI permit from TNRCC. It is a very flimsy permit.”
“The TNRCC doesn’t really scrutinize the permits. They would have to do
a lot of work to do so, to check the air pollution models especially. That
they never do. In fact the permits are full of errors. They issue thousands
of permits and can’t spend the money to check them. To ask UCI to do what
is needed would cost UCI a lot of money.”
“When UCI says “it’s not feasible to build a plant that emits no lead” what it really means is that it costs too much. “This is all about money.” UCI COULD operate perfectly lead-free. But it would cost them a lot. Why didn’t the City understand all this? The city probably doesn’t have any chemical engineers.
“Only an experienced chemical engineer is an expert on this subject of air pollution control technology, or how to cut the lead to zero.” “The US EPA's National Ambient Air Quality Standard (NAAQS) for lead is 1.5 mcg. (micrograms) per cubic meter averaged over 3 months. UCI must comply with that quarterly NAAQS standard.” “UCI (United Copper Industries) states that it will release 260 lbs. Per year (that’s 65 lbs every 3 months), which is equal to nearly 118 trillion micrograms* per year (as a mass emissions rate). In ten years that is approximately a Volkswagen full of lead. And UCI can amend their permit after they get it and ask to emit even more lead a few years from now.” “The stacks would have to dissipate all that lead into Denton’s so that it would be below national standards.” “However, ask any M.D. and he or she will tell you that, despite these national standards, NO amount of lead is safe—Not a single molecule is safe. Because the first exposure of lead has effects that are largely irreversible.” “After that first exposure often nothing can be done.”
“Lead is like a tiny invisible bullet. For UCI to say, first see if anyone is harmed by it, and then complain, is like having a policeman say, first wait for someone to shoot you and then we will protect you. Remember DES (hormone diethylstilbestrol for preventing miscarriage)? The daughters of the mothers who took DES started dying of cancer, and other ailments. All it takes to damage a fetus or a small child is as little as ONE microgram. Lead affects IQ in a developing fetus or child.”
“Suppose we shifted the IQ of our population just 5 points. Half the geniuses would be lost and the number of retarded people would be doubled. (Note: UCI will be emitting other pollutatants as well, but since lead is the most harmful of these, we are focusing only on lead tonight. If you want information on the others I can send).
What we want from UCI: UCI should be located many miles from any humans. In-stack monitoring for lead, property-line monitoring, and in the community monitoring. The “computer modeling” has a lot of problems. “They tweak the numbers” until they get seemingly “safe” numbers. But they use the BACT idea: best available controllable technology” but the computer model is just a black box: junk-in-junk-out. Problems with UCI's copper smelter and air permit application include at least the following:
(A) the background lead level number is too small
in my opinion;
(B) background air and soil testing is needed;
(C) windspeed problem: the air model did not address
the issue of a zero
windspeed. But sometimes there is zero windspeed
or very minimal wind
(stagnant conditions), and then the wind will not
blow the stuff away as per
the model.
“We have to ORGANIZE and keep after them.
“Recently the TNRCC issued a draft permit to build a brand new toxic waste dump near Sierra Blanca, Texas and the site was called the Sierra Blanca Low Level Nuclear Waste Dump in Hudspeth County just east of El Paso, Texas. The Sierra Blance Low Level Nuclear Waste Dump was sited directly over an active seismic fault line.
“It was stopped only because the people demanded a public hearing and
the two state administrative law judges concluded that building such a
nuclear waste dump over a geologically active fault is not good science
(even though the TNRCC's executive director and staff had initially recommended
approval of that permit). After the two law judges recommended denial of
the draft permit, the TNRCC decided to reverse itself and voted down the
permit for the nulcear waste dump last October.
=================
*Conversion of lead in pounds to micrograms:
UCI to emit 260 pounds lead/year x 453.6 grams/pound = 117,936 grams
/year of lead 117,936 grams lead x 1,000,000 micrograms/gram = 117,936,000,000
micrograms of lead/year. UCI will emit nearly 118 trillion micrograms
per year and close to 30 trillion micrograms per quarter.
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