Supporting Information for the Editorial Submitted to the Bozeman Chronicle
By Becky Weed, for Montanans Against Toxic Burning

13 August 2005

Dear Gallatin Valley residents:

The State Department of Environmental Quality (DEQ) is gradually and partially emerging from its public ambiguity about whether the Holcim Trident Plant is required to seek a permit for using Asarco Lead Smelter slag in its cement plant. The Chronicle reported that Director Opper said they had been "discussing it obsessively", then, that DEQ will essentially roll the slag burning issue into the tire burning permit "in exchange" for discontinuing the use of its more recently revealed use of TeckCominco slag from a Canadian smelter. However, in the interim, the DEQ is allowing Holcim to burn 50% more than it burned in 2004. Opper formalized this 'offer' in a letter to Holcim's plant manager on August 5th. Strange bargaining indeed.

Holcim has evolved as well; after weeks of asserting that Holcim is not required to seek a permit for using smelter slag in its cement kiln (and after years of using such slag without a permit or even notification of the DEQ), its public relations manager attempts to comfort us by writing, "Materials that are regulated in our permits are set at minute levels that are far within the standards to protect health and the environment. Those levels are set so low to ensure the public's safety. The writers know this, but continue to ignore it" (letter to Bozeman Daily chronicle, July 25). To the contrary. here's a partial list of what we can ill-afford to ignore:

• Holcim has not released, nor has DEQ demanded, direct empirical measurements of the trace metal concentrations emerging from its stack during the burning of slag in the kiln. We also do not know the concentrations of metals in the cement dust which does not go up the stack (and which may go home on workers' clothes).
• The Asarco lead smelter in East Helena is known to have processed diverse ore deposits from around the world, so it is reasonable to expect that trace metal contents are extremely variable. Published data from an Asarco smelter in Utah show lead, cadmium and arsenic concentrations varying over 3 and 4 orders of magnitude, up to tens of thousands of parts per million for lead. The small number of slag analyses which were performed (after public demands by MATB) indicate extremely low variability of the slag content, raising concerns that unrepresentative samples were analyzed. In fact, the analyses conducted by the DEQ looked at samples from only one small area of the vast Asarco slag pile.
• The Asarco lead smelter in East Helena became a Superfund site precisely because of airborne deposition of heavy metals from the smelter stack during the ore processing which created the slag residue in question. Asarco, our state and federal governments, and numerous private contractors have spent countless hours and dollars studying and remediating the effects of those metals in local soils, vegetable gardens, small grain crops and streams.
• We do not know enough about the chemical content or mineralogical status of the slag to predict exactly how it will behave in the kiln. Nor does Holcim or DEQ. We do know that inserting slag into an extremely hot kiln is not the same as leaving it in an ugly but relatively harmless heap, where aqueous low temperature leaching is minimal (and has been measured). The likely oxidation in the kiln will release fine, metal-bearing particulates to the air which will be far more soluble than the unaltered slag. Alternatively, the residual slag in the cement mix will become part of the ground-up final product, also more soluble than the undisturbed slag. We do know that the small number of available Asarco slag analyses indicate the presence of lead, cadmium, arsenic and chromium at concentrations up to a few hundreds parts per million. Contrary to Prokop's claim that we are alarmed at the "mere presence" of hazardous material, we are instead concerned at the active alteration and introduction of soluble (and thus biologically available) toxic metals into our environment. These concentrations would have been high enough to raise eyebrows (and regulatory oversight and action) at every hazardous waste site I have worked at in Montana, Colorado and Utah.
• We live in a society that has spent many years and millions of dollars to find alternatives to lead additives in gasoline and to regulate lead removal. Similarly, we have made huge efforts and big strides toward reducing childhood exposure to lead paint and mine wastes. These public health expenditures have been credited with lowering blood lead levels in children nationwide, and have been justified by abundant epidemiologic data showing that lead is toxic at extremely low concentrations, even lower than what had formerly been considered "acceptable" under the EPA regulation of 10 micrograms per liter. Why then, do we want to consider unnecessarily redistributing any contaminants, especially lead, into our local atmosphere and cement? This is not knee-jerk obstructionism of any industrial operations, as Prokop suggests; it is a call for smart industrial operations.
• We live in a valley that has had the extraordinary luxury of not having to routinely measure blood lead levels in children, because our environment is anomalously clean compared to urban America. We have both the right and the responsibility to husband that special status.

Regardless of the alleged regulatory ambiguity referred to at the beginning of this letter, I think that the questions before us are fairly clear. As parents, teachers, farmers, cement workers, health officials, journalists, etc., we can ask:

1. Does Montana Statute 75-2-215 apply to the burning of slag? MATB asserts that it does, just as it applied to Holcim's request to include glass in its kiln ingredients in 1999. Slag, which is melted, processed and rapidly cooled rock, is essentially a dirty form of glass.
2. If so, should not the DEQ demand that Holcim discontinue the slag use unless and until it can prove that such slag use is safe?
3. While the lawyers discuss what is required, does it not make sense for Holcim as a corporate citizen to discontinue the slag use unless and until it can prove that such slag use is safe? Had W.R. Grace followed such a policy with regard to known hazards of trace asbestos in vermiculite, the citizens of Libby, Montana would be operating in a different universe today. Regulatory regimes and enforcement have commonly lagged behind technical knowledge; does that absolve us of all responsibility for common sense? I am not suggesting that the Trident plant poses hazards that are comparable to the burdens on Libby citizens. I am suggesting that we can learn from their experience.
4. Where can we seek investigative support? Our local reporter cites the long-term use of Asarco slag at the Ash Grove cement plant in Montana City as evidence that all is okay---what data can he point to, other than the fact that people are not dropping like flies in the street? Our local reporter, after the initial press conference on the slag, reported that the metals of concern occurred in concentrations of less than 1%, implying that our concerns are overblown. Is he unaware that these are trace metals, i.e., by definition they occur and can be toxic at low concentrations? That is why they are generally reported in concentrations of parts per million, not parts per hundred.
5. Does the track record of stonewalling by Holcim on the slag issue serve as an indicator of corporate trustworthiness on other matters, in particular, on all the monitoring, reporting, and technical planning surrounding the tire-burning permit process? MATB's vast accumulation of data on the Holcim plant, including a prolific non-compliance history, is a tremendous resource to all concerned citizens and journalists. What does it tell us about DEQ?
6. Considering all of the above, can DEQ adequately address the slag issue by rolling it into the existing EIS for the tire-burning? The details matter. Is it appropriate for a state agency charged with protecting public health and the environment to be bargaining on Holcim's use of lead smelter slag while the facility is in the middle of a permitting action for burning scrap tires, another public heatlh concern?

There's a lot of work to do yet. Even though a bunch of volunteers in the Gallatin Valley (MATB) have made an impressive start at it, a local newspaper has a special role to play in sifting through, analyzing, explaining and expanding upon that start. It's a helluva detective story. Its about jobs and economy and technology and multi-national business culture and State agency culture and the air we breathe. We need investigative reporting in our community.

To learn more, click on these links:

• Our Summary Fact Sheet.
• Health Considerations.
• Other Uses of Scrap Tires.
• More information about cement kilns from http://www.cementkiln.com. They have an interesting article about the cement industry called The Sultans of Cement.