GUEST ESSAY—"SPEAK NOW OR FOREVER HOLD YOUR BREATH"
Downwinders Fear: Tire and Slag Burning at Holcim’s Cement Kiln All But Permitted
By Suzanne Colon, Guest Writer, 8-16-06
Suzanne Colon
The Montana Department of Environmental Quality (DEQ) recently released drafts of its long-awaited Environmental Impact Statement and air quality permit to allow Holcim, Inc. to burn 1.13 million scrap tires and more than 16,000 tons of toxic slag waste annually in its cement kiln in Trident, Montana, at the headwaters of the Missouri River.
Just upwind of Bozeman in the increasingly populous Gallatin Valley, the proposed burning has been a highly controversial issue, closely watched by environmental and public health leaders. In 2003, concerned citizens succeeded in persuading the DEQ to more thoroughly investigate the risks to human health and the environment in an Environmental Impact Statement. Now that the DEQ has published its EIS, and is poised to allow Holcim to proceed, the public has until September 28 to submit comments on the local waste-burning proposal.
“We’re excited that after the years of review and the process we’ve been through that the draft EIS and permit are out and available for public comment. The process is not complete yet,” Eric Ervin, plant manager of the Trident facility, told me during a recent conversation, “but we’re looking forward to participating in the remaining steps, answering and addressing the questions and concerns that might arise.”
But questions and concerns are already arising, as area specialists study the EIS. Reviewers with expertise in toxicology, geochemistry and law are finding that numerous omissions of data and calculations, and selective or confusing comparisons make it impossible to accurately assess the human health risk analysis.
"The deficiencies of this EIS are particularly perplexing," says Becky Weed, a local geochemist and organic farmer. "Many specific technical comments we made on the earlier Environmental Assessment of tire burning, and subsequent written inquiries about Holcim's use of smelter slag, raised very explicit questions which need to be addressed to determine health risks. In all the years I was involved in hazardous waste investigations as a geochemist, working in several states with a variety of corporate and regulatory clients, I never saw a document as strangely unresponsive as this one."
Background
For those new to the issue, Holcim is a multinational corporation based in Switzerland operating 11 cement plants in the US. At stake is a reduction in fuel costs-- adding tires and slag to the plant’s mix of other feeds and fuels will reduce operating costs and send more profits back to Switzerland. Holcim acknowledges that no jobs will be created or lost by the granting or denial of this permit. Unlike the jobs-versus-the environment battles of the 1980s, the themes here, arguably, are straight out of Erin Brockovich: human health versus profits for mega-corporations. Holcim is owned primarily by the Schmidheiny family of Switzerland, multi-billionaires who rank near the top of Fortune magazine’s list of the world’s wealthiest people.
The slag in question is from the Asarco lead smelter Superfund site in East Helena. In April of 2005, local residents were alarmed to discover that Holcim had been burning slag for several years despite the fact that Holcim had never received a permit to burn this waste, which is laden with arsenic, lead and other toxic heavy metals. Members of Montanans Against Toxic Burning (MATB), a local watch-dog group concerned about Holcim’s proposal to burn scrap tires, met with Governor Schweitzer to express their concern, and he publicly promised to take action to protect public health.
DEQ officials later went to the Trident facility to test the slag and found that Holcim had been burning not only slag from the Asarco lead smelter but also slag from a Canadian lead smelter and industrial waste from a steel mill in Seattle. After analyzing all three, DEQ allowed Holcim to continue burning a limited amount of the Asarco slag but prohibited the burning of the other two wastes. The director of DEQ, Richard Opper, stated that the public health risks due to the use of toxic slag as a substitute for iron ore in the Trident kiln would be assessed within the EIS being conducted for tire burning.
The DEQ’s Findings
The DEQ is now prepared to grant Holcim an air quality permit to burn tires and Asarco’s slag. According to the DEQ, adding tires and slag to Holcim’s current fuel and feed mix will not substantially increase hazardous air pollutants and will pose no more than a “negligible risk” to human health and the environment.
Given the high concentrations of arsenic, cadmium, chromium, and lead in the Asarco slag, some scientists outside the DEQ find this hard to believe. Tom Willingham, a toxicologist with 30 years’ experience at EPA’s Denver office was astonished at the DEQ’s conclusion. “It’s difficult for me, as a scientist, to believe that burning whole tires and slag will not result in significant contamination of soil and air quality surrounding the Trident facility,” said Willingham.
Willingham and others familiar with the Trident plant know that vast differences in kiln operation and technology mean that what may not increase hazardous emissions at one kiln can increase them at another more outdated plant. Newer, dry-process kilns are much more efficient, can better control the cement-making process, and have fewer “upsets.” Therefore, they emit smaller amounts of hazardous air pollutants. The Trident facility, however, is an antiquated wet-process kiln with a track record of frequent malfunctions and equipment breakdowns that result in hundreds of hours of uncontrolled emissions annually.
Another point of contention is that Holcim will burn whole scrap tires. Most cement kilns that are permitted to use tires as alternative fuel burn “tire-derived fuel,” which consists of shredded or crumbed tires with the internal structural wires removed. “Those wires contain heavy metals,” warns Willingham, “which will significantly alter the emissions profile of the plant.” Yet the EIS’s projections show key emissions going down as tires and slag are added to the fuel mix, without any new pollution controls, and nowhere are there any numbers to show how the DEQ is getting to this counter-intuitive result.
Missing Data?
Those who would like to see the data and calculations from which the DEQ’s conclusions were drawn are having a difficult time finding them, as all copies of the EIS are lacking the 22 attachments to Appendix A (the Human Health and Ecological Risk Assessment) where the data is cited. Although they consist of complex numerical calculations and are probably indecipherable to the layman, they are necessary for review by the toxicologists and air quality experts who are being asked to evaluate the EIS and inform the public dialogue.
Greg Hallsten, EIS coordinator at the DEQ, says that the department is not trying to make it hard to evaluate the EIS, but that the calculations were considered “unintelligible” to the public and totaling some 400 pages, they were not printed as a matter of course. “The attachments are available to anyone who wants them,” he offers. “Call the DEQ and we’ll send you a copy. We’re not trying to hide anything.”
Willingham says that, “Without looking very closely at that data, it’s impossible to verify any of the DEQ’s assumptions, and the extent to which they simply used data provided them by Holcim.” However, according to Willingham and others it appears that newer, dry-process kilns burning shredded tires with better emissions control systems have been used for comparisons, rather than kilns comparable to the Trident’s.
MATB’s Jennifer Swearingen observes that “Holcim initially provided data from 11 plants, none of which match the Trident kiln profile, that is, wet kiln burning whole tires. The DEQ has now made ‘adjustments’ (actually reductions) in the original emissions projections by ‘comparing’ the data with test burn data from the Trident kiln and other kilns. The problem is that those test burns and the calculations are missing from the EIS document. The appendices refer repeatedly to a “compilation” submitted by Holcim in January 2004, which is not available to the reader.”
In the US, there are nine wet-process cement kilns burning whole tires, seven of which routinely violate the air quality standards of their regulatory agencies. Three of these are classified by EPA as “high-priority violators,” including a Holcim plant in Ada, Oklahoma. The Ada kiln has been out of compliance for several years running. In September 2005, the EPA took its second enforcement action against the Ada facility and fined Holcim $321,000. Signifcantly, this is Holcim’s only wet-process, whole tire burning kiln. Accordingly, it is the only relevant data that would allow for an apples-to-apples comparison with Holcim’s Trident plant. Yet the DEQ’s analysis is not informed by any emissions data from the Ada facility.
What about the Alternatives?
The controversy over tire-burning boils down to concerns about Holcim’s frequent malfunctions and outdated pollution controls. The Trident kiln could be updated and converted to a dry-process kiln; more effective pollution control technology could be installed; and/or the tires could be shredded and the metals within them removed prior to burning. Any one of these alternatives to Holcim’s proposal might reduce the risks to the environment and human health. But the DEQ declined to consider any alternatives to Holcim’s proposal.
“We considered the workability of those ideas and that sort of thing,” said Hallsten, “and arrived at the conclusion that they wouldn’t really give us any environmental advantage.” The language used in the EIS cites another reason for dismissing the alternatives: that these alternatives (presumably affordable for a $1.2 billion corporation) were “considered and eliminated” because they would incur or increase costs, which is counter to the purpose of the permit application.
Risks to Public Health
Physicians are worried about the effects of slag and tire burning on human health. Dr. Colette Kirchhoff, who has been watching Holcim’s operations for 10 years- since they applied for a permit to burn hazardous waste- is frustrated with the DEQ for not adequately assessing the content of the slag and the formation of dioxins in their Human Health Risk Assessment. “The slag is rife with heavy metals, including lead, chromium, cadmium and arsenic. We can also expect large increases in Dioxin formation with tire burning. These are all highly toxic carcinogens and harmful to the developing human brain,” she warns. “Significant studies have shown that these substances are contributing to the increases in Autism, ADD and mental retardation that we are seeing in this country.”
Area physicians have said that they will look closely at the details on dioxin emissions. Shockingly, MATB reports that the EIS’s health risk assessment has deliberately excluded increases in dioxin emissions. “Holcim’s own data show very large increases in dioxin emissions.” writes Swearingen. “Yet the DEQ has allowed Holcim to factor in only the federal legal limit for cement kiln dioxin emissions, which is far lower than what Holcim’s own data indicate. The DEQ is electing to ignore a clear public health hazard—toxic emissions of dioxin—in order to conclude that Holcim’s tire-burning proposal will pose no more than a negligible health risk, as required by Montana law.”
Is this Recycling?
Holcim has downplayed the health risks and sought public support by extolling the benefits of “recycling” tires in its cement kiln. “Holcim is a strong believer in sustainable environmental performance and corporate social responsibility,” says Ervin, plant manager. “We see this proposal for using tires as fuel as an ideal fit for those goals. Using tires as an alternative fuel, a proven practice at other kilns, eliminates that waste from tire piles and landfills and helps us conserve natural resources.”
Opponents are quick to point out that Montana has neither a tire disposal problem nor a landfill space issue; and tire burning as fuel is not technically recycling-- the EPA no longer considers combustion’s “energy recovery” to be recycling. Montana does have a tire recycler that converts tires into useful products: Vern Reum of Polson, MT. Reum’s operation shreds tires and produces products with several different uses. He is in the process of qualifying for a low-cost economic development loan to buy a tire crumber so that he can expand his business.
If Holcim proceeds, tires from neighboring states would have to be trucked in to meet their goals, as the number they would like to burn, 3,117 tires per day, significantly exceeds the number of tires available in Montana. Reum already has contracts with all the major tire wholesalers not only in Montana but also in eastern Washington, most of Idaho, and northwestern Wyoming. He pays more per tire than Holcim is willing to pay, which raises the question of where Holcim will get such a volume of tires if permitted to burn them.
Meanwhile, the issue of “recycling” slag is much trickier and still flying below the general public’s radar. Kiln temperatures of 2500 degrees or more vaporize the heavy metals in the slag, making it a potentially significant contributor to hazardous air emissions. As it now reads, the EIS contains virtually no analysis of the environmental impacts and health risks associated with slag burning. “Without knowing the exact composition of the Asarco slag and how it will behave when heated in the kiln, it is impossible to assess whether the subsequent emissions are acceptable from a human health standpoint,” warns MATB.
Hallsten insists that the slag has been adequately tested. When challenged on the issue, he said “We tried to use the word as often as we could, but the point is that the slag content was figured into the risk assessment. The modeling and the analysis does include slag in the mix.” Nevertheless, those poring over the document to find the slag analysis find it severely lacking.
Future Recourse
Perhaps the most ominous point in the entire debate is this one made by MATB: “In its entire history, the Montana DEQ has never revoked an air quality permit--even when there have been egregious violations at major industrial sources.” Instead, the DEQ pledges to work with Holcim in the event that they violate the permit. "The permit has conditions on it,” says Hallsten, “and if they violate these, we’ll have to do something about it.” What’s generally done about it is to fine the company, which may penalize them but does nothing to undo the damage downwind.
Many of Holcim’s kilns around the country operate in frequent violation of their permits. The EPA fined the Holly Hill plant in South Carolina $838,850 for failing to comply with air emissions standards. The Texas Air Control Board fined the Midlothian plant $135,000 when it discovered emissions were almost 50% higher than allowable. The Clarksville, Missouri plant paid a $100,874 fine for violations ranging from failing to analyze waste to keeping waste in open containers. Five years later this same plant was failing to report excess emissions entirely. Given the Trident plant’s history of upsets and malfunctions, it is not hard to imagine worst-case scenarios.
What next?
The Draft EIS and permit were made available on July 28th, beginning a 60-day comment period. The public has until September 28th to voice concerns and raise questions. “Sixty days is not a lot of time, given the complexity of this issue,” says Swearingen. “And the glaring deficiencies in the analysis and the lack of documentation to support DEQ’s conclusions compound the problem.”
The DEQ must hold a public hearing on the issue, the time and place of which will soon be announced. By attending the hearing or submitting written comments to the DEQ, the public may be able to generate enough resistance to convince the DEQ to undertake more testing, look at data from more comparable plants (like Ada’s) and ultimately change the Proposed Action and deny the permit. Governor Schweitzer, who once pledged to watch the issue closely, will surely feel some pressure to weigh in on it. Only one thing is certain: if the public is silent on this issue, Holcim will receive a permit to begin burning tires at the headwaters of the Missouri.
According to the activists involved with monitoring Holcim's plan and state review, the time has arrived to speak now or forever hold your breath.
EDITOR'S NOTE: Suzanne Colon is a writer and mother who lives in Bozeman.
To find out more visit these sites:
http://www.holcim.com
http://www.NoToxicBurning.org
http://www.deq.state.mt.us
http://www.downwindersatrisk.org
Questions or comments may be sent to:
Greg Hallsten, EIS Coordinator
Montana Department of Environmental Quality
PO Box 200901
Helena, MT 59620-0901
To contact the Governor:
http://governor.mt.gov/contact/comment.asp
phone: 406-444-3111
fax: 406-444-5529
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Comments
>>>>>>>
There are several advantages to using tires as fuel:
Tires produce the same amount of energy as oil and 25% more energy than coal
The ash residues from TDF may contain a lower heavy metals content than some coals.
Results in lower NOx emissions when compared to many U.S. coals, particularly the high-sulfur coals.
EPA supports the highest and best practical use of scrap tires in accordance with the waste management hierarchy, in order of preference: reduce, reuse, recycle, waste-to-energy, and disposal in an appropriate facility. Disposal of scrap tires in tire piles is not an acceptable management practice because of the risks posed by tire fires, and because tire piles can provide habitats for disease vectors, such as mosquitoes.
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Also, slag is not "burned". It is a mineral addition to the cement-making material that actually lowers the energy required to make cement. Less energy = less fuel burned = less pollution. The company may be all about making money, but if it also works to lower pollution, then maybe everyone's bottom line is improved.
We can do more to protect our environment by engaging in productive dialog with industy. Stop villifying these people and work with them to find a better way.
"Based on over 15 years of experience with more than 80 individual facilities, EPA recognizes that the use of tire-derived fuels is a viable alternative to the use of fossil fuels. EPA testing shows that TDF has a higher BTU value than coal. The Agency supports the responsible use of tires in portland cement kilns and other industrial facilities, so long as the candidate facilities: (1) have a tire storage and handling plan; (2) have secured a permit for all applicable state and federal environmental programs; and (3) are in compliance with all the requirements of that permit."
Perhaps the win-win is in the permit requirements, monitoring, and enforcement. That seems fair to me.
Montana law requires Holcim to prove negligible risk to human health and the environment before the facility can be permitted to burn tires. From the evidence in the draft EIS, it is quite clear that this is not the case.