REPORT: FLAWED TCEQ PLAN WILL ALLOW EXIDE NOT TO MEET LEGAL STANDARDS FOR SAFE AIR QUALITY – CONCERNED? GET YOUR COMMENTS TO TCEQ BY THIS MONDAY, AUG. 8!
Professional Engineer and co-founder of Houston-based Spirit Environmental Jess McAngus has reviewed the proposed TCEQ State Implementation Plan – SIP – proposal for Exide’s lead smelter, and he has prepared detailed comments addressing the proposal’s many shortcomings that will prevent the Frisco lead smelter from meeting legal requirements for safe air quality standards. He also presented his comments at the TCEQ public hearing here on July 28.
Below is a summary of his findings, and his biography. You can find the detailed, full copy of his comments here. Please share this post and the full report with your concerned family, friends, neighbors, co-workers, facebook friends and twitter followers, etc.
CONCERNED? SEND YOUR COMMENTS TO TCEQ BY THIS MONDAY, AUGUST 8 DEADLINE!
If you are concerned about the shortcomings and flaws in the TCEQ’s proposed Agreed Order/SIP that will allow the Exide lead smelter to continue to illegally emit high levels of lead and other toxins into the air, soil and water in the heart of our community, then please make sure to send your comments RIGHT NOW! to the TCEQ, as THIS MONDAY, AUGUST 8, is the deadline for TCEQ staff to coordinate all public comments.
When you contact the TCEQ, please request that Exideâ€™s toxic lead emissions be reduced to the maximum level achievable â€“ and nothing less!
No community should have to carry the burden of a lead smelterâ€™s known toxic emissions â€“especially when proven technology is readily available to minimize lead and other toxic emissions to very low emission levels.Â
Send your comments NOW! to TCEQ via:
Public comments will be accepted online by clicking here.
You can can fax your comments to 512-239-5687.
You also can mail your comments to:
Holly Brightwell, MC 206, Air Quality Division, Chief Engineer’s Office, Texas Commission on Environmental Quality, P.O. Box 13087, Austin, Texas 78711-3087.
All comments pertaining to the state implementation plan should reference Project No. 2011-001-SIP-NR. Comments on the agreed order should reference Project No. 2011-024-MIS-NR.
EXCERPT’S FROM JESS McANGUS’ REPORT ON FLAWED TCEQ/EXIDE SIP
“Even though the TCEQ has expended a tremendous amount of work on this proposed SIP, unfortunately, the proposed SIP contains numerous errors and the proposed SIP will not result in attainment of the new Lead NAAQS (National Ambient Air Quality Standards). The errors we have identified will be discussed and our recommendations for the attainment of the Lead NAAQS are provided…”
A SUMMARY OF TCEQ ERRORS IDENTIFIED TO-DATE INCLUDES:
Â·Â Â Â Â Â Â Â Â Background concentration of lead not included in modeling;
Â·Â Â Â Â Â Â Â Â Base Case Modeling does not include all sources;
Â·Â Â Â Â Â Â Â Â Mysterious Source 999 was previously not known and now is assumed to be controlled 100%;
Â·Â Â Â Â Â Â Â Â Future Case Modeling does not use the proposed Allowable Emission
Rate, (presently, the TCEQ does not know what the proposed Allowable
Emissions will be);
Â·Â Â Â Â Â Â Â Â 100% control of fugitive sources is unrealistic, especially when
considering the existing “culture” Exide has demonstrated regarding control fugitive emissions:
Â·Â Â Â Â Â Â Â Â Modeling of Allowable Emissions also demonstrates nonattainment of SO2 and PM2.5NAAQS;
Â·Â Â Â Â Â Â Â Â RACT/RACM analysis does not include all viable technologies; and
Â·Â Â Â Â Â Â Â Â Wet Electrostatic Precipitator control is RACT.
OUR RECOMMENDATIONS FOR IMPROVING THE PROPOSED LEAD SIP INCLUDE:
Â·Â Â Â Â Â Â Â Â Use a 90% control efficiency for capture and control of fugitive
Â·Â Â Â Â Â Â Â Â Prepare proposed Allowable Emission Rates that coincide with the
proposed SIP and proposed Agreed Order;
Â·Â Â Â Â Â Â Â Â Re-do Future Case Modeling with corrected Allowable Emissions
Rates (90% control of fugitive emissions) and include background lead
concentrations of between 0.03 – 0.10 Âµg/m3;
Â·Â Â Â Â Â Â Â Â Model all site-wide emissions of all pollutants and toxics to
demonstrate compliance with all NAAQS and State Health Effects Guidelines;
Â·Â Â Â Â Â Â Â Â Re-consider WESP Technology as RACT.”
Â Jess McAngus’ Biography
Jess co-founded Spirit Environmental in 2005 after 25 years with Pilko & Associates. Jess started his career at DuPont with assignments in process and project engineering in nylon, polyester, and acrylic intermediates. Since his work with DuPont, Jess has consulted for over 30 years in environmental areas, particularly with litigation support, environmental auditing, and permitting new large industrial facilities. He has established a reputation for his expertise in preparing and negotiating over 400 New Source Review (NSR) air construction permits, including state construction, PSD and nonattainment permits, and air toxics reviews. He is also an expert in air dispersion modeling, having completed over 100 air quality impact reviews. Jess has been involved in over 60 litigation matters and has been deposed frequently and testified over 25 times.
He has completed several studies on the effects of major environmental legislation on industry, including a study for Congress analyzing the national economic impacts of alternative NSR policies for nonattainment areas. Jess also worked with several state agencies in the development of air toxics reviews. He has testified on behalf of the Houston Business Coalition for Clean Air Appeals group regarding the Houston SIP.
Jess has a B.S. degree in chemical engineering from the University of Texas and has completed his studies for a M.B.A. from Pepperdine University.