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June 9, 2005 It's About Pollution Holcim has spent a lot of money trying to convince people that burning more than one million scrap tires annually in its Trident cement kiln is a good idea, but these advertisements are misleading. This past winter the Holcim facility had many serious malfunctions that led to long periods of uncontrolled emissions. Several of these events coincided with weather inversions that tend to trap pollution in the Gallatin Valley. If Holcim is permitted to burn scrap tires, those uncontrolled emissions will pose a serious health threat. First, and most important, burning tires in cement kilns increases emissions of hazardous air pollutants. Holcim wrongly claims that burning tires as fuel will provide a reduction in the plant's "total" emissions. While some test burns indicate a slight decrease in emissions of nitrogen oxides, studies clearly show a significant increase in hazardous air pollutants such as dioxin, mercury, lead, arsenic, chromium, and other toxic substances. Moreover, the information submitted by Holcim in its permit application plainly predicts large increases in these pollutants, as well as carbon monoxide, with the burning of tires. These pollutants collect and persist in our fields and streams, entering the food chain and causing serious health problems, including cancer, reproductive disorders, and developmental disabilities. A small reduction in emissions of nontoxic nitrogen oxides hardly offsets a major increase in toxic air pollutants. Second, Holcim cites a study by the U.S. Environmental Protection Agency in support of its claimed emissions reductions, but that very same study cautions against burning whole tires in old, frequently malfunctioning kilns like Holcim's "wet-process" plant. In the entire United States, there are only nine wet-process kilns that burn whole tires, and seven of those nine are now operating in violation of air quality standards. According to EPA., three are high-priority violators, including Holcim's plant in Ada, Oklahoma. As it stands now, the Trident plant has regular upsets. If it is permitted to burn tires, it is likely to become yet another one of Holcim's high-priority violators. Third, Holcim wrongly suggests that Montana will be littered with tires if the Trident plant is not allowed to burn them. Burning tires is a "solution" to a problem that does not exist. Our state legislature's Environmental Quality Council has determined that Montana does not have a scrap tire management problem. In any case, Montana doesn't generate anywhere near the 1.13 million tires Holcim's draft permit allows it to burn. Holcim would be importing waste tires from other states. The draft permit does not require Holcim to take tires from Montana, and Holcim has never pledged to accept any tires from Montana. A recent letter to the editor from Holcim's alternative fuels manager stated only that it is "possible" to reach their targeted use without using out-of-state tires. In fact, Holcim is likely to import tires from states that provide financial incentives to dispose of them. For example, the State of Utah would pay Holcim $70 per ton to burn their scrap tires in the Gallatin Valley. Thus, while Holcim's ad campaign promises to clean up Montana, Holcim's tire-burning proposal would really make the Gallatin Valley a regional waste-incineration site. No amount of advertising can conceal the fact that incinerating whole waste tires in an aging kiln upwind of the Gallatin Valley is a very bad idea. The choice is clear: Holcim could increase its profits-and its hazardous air emissions-by burning dirty waste fuels in its old, outdated kiln, or Holcim could reduce its fuel costs-and its air emissions-by modernizing its facility and utilizing readily available technology. It's not about "appreciation," as Holcim's ads would have us believe; it's about pollution. Montanans Against Toxic Burning is an all-volunteer group including health professionals, small business owners, farmers, ranchers, builders, and other concerned citizens. Our goals include public education of environmental and health risks of toxic waste incineration. For more information and links to the references cited above, go to www.notoxicburning.org. Supporting Links
Status of and Alternatives
for the
Management of Waste Tires
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