Backspin: Orcem Goes to School

A response to Orcem's presentation to

the Vallejo School District


What does Orcem produce?
Orcem does not actually manufacture Ground Granulated Blast Furnace Slag (GGBFS) as stated; slag is a byproduct of the steel industry.  Orcem proposes to import granulated blast furnace slag to the former General Mills site in south Vallejo from Asia in big cargo ships, and grind it into fine powder at the site.  It still must be mixed with other materials to make a cementitious product.  GGBFS is not green cement, it is powdered slag.  It is an ingredient in cement products that can be called green relative to ordinary portland cement.
What is green cement?
Substituting GGBFS for ordinary limestone clinker reduces the overall carbon footprint by eliminating the need for quarrying and baking limestone in high temperature kilns.  How much of that savings is nullified by loading GBFS produced in Asia onto polluting heavy cargo vessels and hauling it across the ocean?  Cement manufacture causes environmental impacts at all stages of the process.  The fact that the GBFS hasn’t been quarried and baked before it comes to Vallejo is beside the point.  The salient question is whether this site is an appropriate place for heavy polluting industry in 2016 Vallejo.  The focus on whether or not you can justifiably call the final product green cement is a distraction.
Is green cement different than ordinary cement?
The quality of the concrete made with green cement is superior to ordinary concrete as described.  The other claims about the "harmless material" and air pollution made here are directly contradicted by the company’s own safety data sheet and the draft Environmental Impact Report.  To call the claims regarding NOx emissions disingenuous would do them kindness.  Keep in mind the cement plant project would be part of a larger deepwater port terminal project, and both contribute significantly to the environmental impacts.  

The draft Environmental Impact Report reveals that the volume of NOx emissions would pose a serious health risk to residents of south Vallejo.  According to the draft Report and shown in Table 3.2-13, the project would pump out more than 63 tons of NOx (nitrous oxide and nitrogen dioxide) per year.  These gases form ground level ozone that destroys lung tissue.  That is six times the threshold level of significance set by the Bay Area Air Quality Management District in 2010.  The other claims regarding air pollutant emissions are equally misleading and contradicted by their own analysis of the project.
Is Orcem proposing to build a “cement plant” in Vallejo?
The draft EIR includes quotes like the following from page 3.2-14: “The  proposed Orcem  facility  would  include  construction of a
production plant intended for production of GGBFS..."  Who cares what you call it?  To most people a “plant” is just a manufacturing facility.  Calling it a finishing mill does not change the many negative unavoidable impacts identified in the draft Environmental Impact Report.  Calling the product “green” does not help the children in south Vallejo who would be breathing the ozone, dust and soot from operating the “finishing mill" and who already suffer some of the highest rates of respiratory illness in the state.  We should focus on real life impacts on human health and quality of life instead of splitting hairs over labels.
How is Orcem’s green cement supplement better for the environment?
The zero carbon footprint claim is nonsense.  The draft EIR lists the carbon monoxide emissions alone from project operations at 24.57 tons per year.  (See Table 3.2-13)  Does that sound like a zero carbon footprint?  The ships hauling GGBFS across the ocean to Orcem and then idling in port for a week to provide power to offload the cargo, along with the fossil fuels burned in the drying process would pump out large quantities of CO2.  The effort to minimize the perception of impacts by segregating and examining processes piecemeal is not credible.  Again, none of the green arguments bear on the question of whether the General Mills site is an appropriate place to locate such a facility.
What are some examples of structures built using green cement?
Gee whiz, that's all impressive but nothing here mitigates the environmental impacts of manufacturing the product near schools and homes.
What is Orcem's green cement supplement used for?
It’s a useful product, no question, but that’s no justification for putting a polluting heavy industry manufacturing facility upwind of south Vallejo’s children.
How will the raw materials arrive at the facility?
In addition to the ship engines idling in port it would mean a huge increase in heavy truck traffic, and reactivating a rail line that requires trains to block traffic at 19 intersections across town and traverse another twenty or so places where pedestrians are likely to cross.  This rail line was laid out in 1869 and at one time went around the city.  Now that the city has grown many times that size, it cuts right through the heart of Vallejo.  It would be better to convert the rail route to a pedestrian/bike trail to further interconnect Vallejo residents.
How will the Orcem project benefit the City of Vallejo?
If we’re talking about a household budget, then $2.6 million over five years sounds like a lot.  In terms of the City budget and compensation for the host of negative unavoidable impacts laid out in the draft Environmental Impact Report, then that amount is truly a pittance.  The jobs numbers represent an exercise in creative accounting which attempts to project all the spillover effects rather than use direct employment numbers.  Their own economic analysis characterizes the 189 jobs number as including “direct, indirect and induced jobs” by 2021.  Vallejo needs businesses that produce sales tax, not just utility taxes, and create more jobs that require less specialized training.  We need businesses that contribute more than they cost in negative unavoidable impacts.  

It’s noteworthy that the benefit to the “local economy” is given as ten times that of the benefit to Vallejo.  That may explain the interest of county level officials who have been pushing this project.  We should never consider sacrificing the health of our children to benefit regional big money interests.
Why is the Orcem project important to California and its clean energy goals?
The short answer is that it’s not important at all.  There is already a slag cement plant project further along in the approval process at the Port of Stockton.  That site is in a heavily industrialized area where such a facility would be a much better fit.  The current lack of heavy industrial activity on the east shore of our waterfront is seen by the General Plan Working Group as an opportunity to reclaim this asset for the City and connect south Vallejo to the downtown.  The VMT/Orcem project would block all public access along the waterfront and further isolate south Vallejo with truck and train traffic.
Truth Number One
There are environmental impacts associated with every stage of cement manufacture.  Skipping first steps does nothing to minimize the subsequent impacts.  It is true that cement plants are usually located near limestone quarries.  That’s to avoid the costs associated with transporting the material.  To be truly ‘green’ the Orcem plant would locate next to an iron ore blast furnace so that the GBFS would not need to be transported, loaded, and shipped overseas.  All that material transport requires burning fossil fuels, which means the green is definitely fading on that green cement.
Truth Number Two
It's not all that complicated.  The truth is that once in operation the finishing mill would produce whatever mix of products will provide the greatest profit in the current market.  The draft EIR on page 3.2-14 includes the following: “Orcem would primarily operate as a GGBFS production facility, although the facility could also be used for production of portland cement."  Since this would be a sixty five year lease, predictions of what might be produced in decades to come are speculative.  The operation would be anything but clean, whether grinding imported clinker or imported slag.
Truth Number Three
Material Safety Data Sheets for GGBFS from around the world contradict the claim that none of the slag material is toxic.  The potential suppliers that would provide Orcem raw materials are not identified in the project proposal, or any provision for testing batches of slag before import.  Over the life of the project, market conditions will likely dictate the slag supply sources.  There is no assurance at all that future imports will be identical to the single sample they provided for analysis. 
Truth Number Four
The claim that slag from the production of iron is somehow different from steel slag production in terms of toxicity is contradicted by Safety Data Sheets from various other sources.  Here are some quotes from the Ash Grove Corporation Safety Data for slag from iron production, for example.  Apparently nobody told them it is scientifically and physically impossible. 

“Material Name:  Ground Granulated Blast Furnace Slag (GGBS/GGBFS, or Slag Powder)
Trade Name: DURA SLAG™
Description:  A ground powder made with an appropriate mill from a glassy granular material formed when
molten iron blast furnace slag is rapidly chilled as by immersion in water.”

“Slag is a nonmetallic byproduct of the production from the
production of iron.  Trace amounts of chemicals may be detected during chemical analysis.  For example, slag may contain trace amounts of titanium oxide, chromium compounds, sulfur compounds, and other trace NTP.”

“However, slag may contain trace amounts of substances (such as
hexavalent chromium) that are classified by IARC and NTP as carcinogens.compounds.  

“Avoid actions that cause dust to become airborne.”

Hexavalent chromium is the cancer causing substance that Erin Brokovitch was fighting in Hinckley, and which contaminated a school  yard in Davenport, California from a slag finishing mill.  The slag material would be stored in the open in forty foot high piles and will emit dust every times it’s scooped up and moved.  The mill itself may release a modest amount of dust, but storing and moving the stuff around will certainly not be the “dust-free” operation the applicants want to portray.  Listen to the residents of Camden, NJ who are living with one of these plants in their neighborhood: 
Truth Number Five
This is greenwashing at its finest.  In the first place the production of the ‘green’ cement is only one aspect of a much larger project.  The cement manufacturing facility will only be approved as part of the larger Vallejo Marine Terminal project and the impacts of the entire project must be considered. 
Second, focusing on just the slag milling piece of the Orcem process without considering the environmental impacts of other aspects of the operation like material transport hides the true picture. 
Third, the ‘green’ aspects of the project are all over before the material ever gets to Vallejo, and have no bearing on the question of whether the General Mills site is an appropriate location today for heavy industry.
Truth Number Six
1)  The actual material transfer and milling process is anything but green, in fact it’s dirty.  The VMT/Orcem project is incompatible with the current effort to update the General Plan.  The City of Vallejo just spent two years and three million dollars in a planning effort for the waterfront that envisions a completely different use for the site, one that does not include heavy industrial zoning at all.

2)  Vallejo’s location can be considered an asset for any number of reasons, it certainly doesn’t obligate us to put heavy industry on our waterfront.  We can find much better uses that don’t threaten the health of our children.
Truth Number Seven
Well, yes, if they had to truck in all the slag material as well it would no doubt be exponentially worse.  How is that relevant?  The number of vehicle trip estimates keeps changing but the conservative estimate given here is plenty bad enough.  Since these heavy trucks have to go in and back out again, that translates to 238 trucks passing each day starting at three in the morning.  People live in these neighborhoods and if it was your neighborhood I’m reasonably sure you would feel like you were being inundated too.
Truth Number Eight
Diesel trucks produce soot classified as a Toxic Air Contaminant even with the best available technology.  A lot of diesel trucks produce a lot of soot.  According to the draft Environmental Impact Report the project would release nearly sixteen tons of soot and other particulate matter per year.  That is not a small number, and when you add it to the other emissions and the atmospheric load already present it presents a clear health hazard to local residents.
Truth Number Nine
Fair share?  How about all of it and then some?  The city has no incentive to share any of the cost.  Not only would Lemon Street require major improvements but all the streets traveled subsequent to Lemon will deteriorate much more quickly under steady heavy cement truck traffic.  The projected utility tax pittance would not even cover those expenses much less any cost sharing with the private beneficiaries of these improvements.
Truth Number Ten
We might want to consider the noise of trains rumbling through neighborhoods and sounding 110 decibel warning horns all the way across town.  There’s no guarantee that this wouldn’t occur in the middle of the night.  Property values would be negatively impacted and emergency service vehicles will find intersections blocked by passing trains.
Truth Number Eleven
The intensive use zoning for the General Mills site is an outdated legacy from the mid-nineteenth century.  A city has grown up around the site in recent decades that includes neighborhoods with children.  We are not prisoners of the past, and a citizen-driven planning effort has just agreed on a River and Bay City planning vision for the waterfront.  That roadmap for the future would relegate heavy industry on the east Strait waterfront to the history books where it belongs, as many other Bay Area cities have done.
Truth Number Twelve
A school a mile and a half away is certainly not too far away to be impacted.  Elevated ozone levels can be detected in rural areas hundreds of miles downwind of NOx sources.   Grace Patterson Elementary School is much closer, less than 1500 feet.
Truth Number Thirteen
Our children are too important to just rely on the word of people who stand to profit from this project.  The best way to protect our children is not with monitoring stations at their schools.  The one sure way to prevent the identified unavoidable health risks is to locate such projects away from our neighborhoods and schools.
Truth Number Fourteen
Trying to make the pittance that the City would get in return for all these impacts  sound significant by multiplying it over five years seems a peculiar argument to make to an educational body.  Presumably educators will know how to divide.  The small projected annual increases only make it a slightly larger pittance.  The projected indirect and induced job projections are just speculative guesswork.  The actual number that would be employed by the cement plant itself is much smaller.
Truth Number Fifteen
Lemon Street is far from the only roadway that will suffer damage from the heavy cement truck traffic.  That is just the beginning of the routes that would be traveled by these vehicles.
Truth Number Sixteen
If the port project goes forward at the site, then Homeland Security regulations will prevent any and all public access.  That will force the Bay Trail away from the Bay where it belongs and keep it on Sonoma Blvd., an inappropriate detour.  The addition of a continuous walking and bike trail that would connect the California State campus with the downtown is a main feature of the vision just produced by the General Plan Working Group.  The VMT/Orcem project would prevent the implementation of that planning vision developed by City Commissions and citizens in an expensive two year effort as well as block the regional Bay Trail project.