By Kris Thomas from Montanans Against Toxic Burning
Editors Note: The Headwaters Group of the Sierra Club is opposing Holcim’s plans to burn tires.
The Coke Appeal Has Been Settled with Good News for Montanans! Last winter, Holcim applied to change its fuel composition to a very high percentage (50%) of petroleum coke, a waste product of the petroleum refineries and a notoriously dirty fuel. Holcim's proposal could have increased the emission levels of sulfur dioxide, nitrogen oxides, and particulate matter. Unfortunately, the State of Montana granted Holcim a permit without requiring the facility to perform previously agreed-to testing.
Montanans Against Toxic Burning, the Montana Environmental Information Center, and the Headwaters Chapter of the Sierra Club appealed this permit on the commonsense notion that people deserve to know what is coming out of Holcim's smokestack. Shortly before Thanksgiving, this appeal was settled before the hearing date with some good news for all Montanans. Through negotiation, a reasonable, responsible decision was reached:
- Holcim will install continuous emissions monitoring equipment within nine months to monitor sulfur dioxide and nitrogen oxide emissions.
- Emissions monitoring reports will be submitted quarterly to the Department of Environmental Quality for the first year and semi-annually thereafter, and emissions information is to be made available to the public.
- Within 90 days of increasing its use of coke fuel, Holcim must conduct a source test to determine the chemical composition of its stack emissions.
Emissions monitoring will allow the public to know whether Holcim is in compliance with the limits established by the DEQ. It is not a perfect settlement. There are still serious concerns about emissions of metals and polyaromatic hydrocarbons associated with burning high amounts of petroleum coke. However, monitoring of sulfur dioxide and nitrogen oxides is a good start toward protecting the clean air and agricultural economy of the Gallatin Valley.
A Legacy of Pursuing Dangerous Fuels
As many residents in the Gallatin Valley remember, Holcim, a multinational corporation based in Switzerland, applied for a permit ten years ago to burn 8.2 million gallons of hazardous waste per year in its Trident cement kiln. Holcim brought in its hired "expert," Kathryn Kelly, to testify that "in terms of potential impact to the public health or environment, there is no difference in the stack, in the cement kiln dust, or the concrete product as a result of using hazardous fuel" (Bozeman Daily Chronicle, 7/31/91). After years of vigorous opposition from citizens groups, the application was withdrawn in 1994.
Time has proven that Holcim's "expert" was wrong and that citizens' health concerns were well founded. In 2001, the U.S. Environmental Protection Agency ranked hazardous-waste-burning cement kilns as the second highest source of dioxin in the country. The number one source of dioxin in the United States is municipal (solid) waste incinerators.
Solid Waste Incineration
In July 2000, Holcim submitted an application for a permit to incinerate solid wastes. Holcim has asked that the permit address "a wide variety of potential material": "It is unknown at this time what waste streams will be brought into the Holcim-Trident Plant. We are anticipating that we will receive slag-like materials, catalysts from the metal industry, wood wastes, and other traditional industry wastes."
In October 2001, Holcim submitted an application for an air quality permit to burn tires in its kiln. The company hopes to reduce its fuel costs by supplementing its traditional fuel with scrap tires at a rate of 75 tires per hour, 1,800 tires per day, or 657,000 tires per year.
What's the problem with burning tires?
Tires are composed of styrene and butadiene, which are both being classified as human carcinogens; extender oils, which contain carcinogenic benzene derivatives; up to seventeen different metals, many of which are toxic; and carbon black, a fine particulate matter produced by the incomplete combustion of fossil fuels. Tires are not considered a hazardous substance—until they are burned. When tires are burned,
- their hazardous constituents are released, and new, more toxic compounds, such as dioxins furans, PCBs, and polyaromatic hydrocarbons, are created.
- metals are not destroyed but are concentrated in the cement product and in the kiln waste product. They are also distributed throughout the environment through the stack emissions.
Cement kilns are prone to malfunctions that trip pollution-control equipment and result in large amounts of uncontrolled emissions. During these incidents, called "upsets," unburned and partially burned chemicals are released directly into the environment. The Holcim Trident plant reported more than 600 upsets during the year 2000. With tires added to the fuel mix, upset emissions are expected to increase, posing a greater threat to public health.
Tire Permitting Process Proceeds—Your Comments Are Needed!
The Department of Environmental Quality is currently conducting a completeness review of Holcim's application to burn tires. They are welcoming written questions and comments. Please send a letter to David Klemp, Air and Waste Management Bureau, P.O. Box 200901, Helena, Montana, 59620-0901, or send a FAX to 406-444-1499, or e-mail to email@example.com.
There are several points you may want to consider addressing:
- Because of the potential health impacts of incinerating tires, an Environmental Impact Statement should be prepared.
- Test burn data from other cement plants are presented in the application. Test burns represent carefully controlled conditions, not normal operating conditions. The DEQ should consider the high rate of upset emissions at the Trident plant and attempt to quantify those emissions.
- A full spectrum of test burn results should be included in the permit application, not just data showing favorable results. In addition, there should be sufficient data points to make a valid risk assessment.
- The permit application should consider the worst-case scenario, not an averaging of potential emissions.
- The calculation of potential toxic emissions (dioxins, metals) from tire burning should be based on actual measurements of pollutants, not estimations.
- Holcim must specify the wastes it is proposing to burn in its kiln.
When the permit is found to be complete, the Department of Environmental Quality will make its determination on whether the permit should be issued (Preliminary Determination). If it decides to issue the permit to Holcim, a draft permit will be presented to the public for comment. We will let you know when the comment period begins. Meanwhile, there are other ways that you can help safeguard the health of the Gallatin Valley:
- Write a letter to the editor of your local newspaper and send us a copy.
- Contact your city and county commissioners and let them know your concerns.
- Help educate your friends and neighbors. Let them know about our Web site http://www.notoxicburning.org.
- Contact the Gallatin County Board of Health and let them know your concerns.
- Volunteer! We are opposing one of the biggest cement companies in the world and can use all the help we can get. For more information, call Katie at (406) 582-8365 ext 3002.
This article was reprinted courtesy of Kris Thomas and Montanans Against Toxic Burning.