January 2004 Update
The Scoping Comment Deadline is Friday, January 23, 2004

Your voice is needed now!
As you may be aware, the Montana Department of Environmental Quality (MDEQ) has determined that an Environmental Impact Statement must be completed before they decide whether to issue a permit for Holcim to burn tires at their Trident plant. We are now in the scoping period of the EIS process. This is when the MDEQ accepts public comment on what issues need to be covered in the EIS. It is important that they hear from as many people as possible. Let the DEQ know that you want a thorough and comprehensive EIS on Holcim's proposal to burn tires in their Trident cement plant.

To comment, we encourage you to attend the public scoping hearing in Manhattan on Tuesday, January 20th (see details below). If you prefer, you can also comment using our online comment form, by email, or by mail.

Significant Issues to Consider in the EIS

Holcim is already burning significant amounts of industrial wastes and therefore its total emissions-not just those resulting from tire burning-should be considered when assessing health and environmental risks due to its pollutants. The DEQ has allowed Holcim to base its risk assessment solely on the incremental increase in hazardous pollutants due to tire burning. Both the increase and Trident's current levels of pollution emissions should be considered in the risk assessment. Considering only the incremental increase in emissions is counter to accepted practices of risk analysis and is contrary to the standard set in the Montana waste incineration statute (75-2-215)..

The air dispersion modeling must be completely redone. The use of data from Great Falls (which was combined with data from a weather station at the Trident facility) to characterize dispersion in the Gallatin Valley is unacceptable. Holcim's local surface data is also suspect; the meteorological station was sited inside the river canyon where air currents tend to follow the flow of the river, whereas the stack protrudes above the canyon rim where winds are primarily from the west. In addition, Holcim chose a model for their analysis that has yet to be officially approved and failed to consider other major sources of pollution in the area.

The EIS should consider the Trident facility's inability to comply with its existing emissions limits. In 2002, the facility experienced a multitude of equipment failures and upsets, which resulted in more than 500 hours of excess emissions (more than 6% of operating time). Montana law (17.8.749) states that a new permit may not be issued unless a facility can demonstrate that it can be expected to operate in compliance with existing air quality standards. This is an extremely important consideration, in that the amount of hazardous pollutants emitted from the plant is a function of the facility's ability to properly operate the kiln.

Impacts of mercury emissions on fish must be considered in the EIS. Although sediments contaminated by toxic metals (especially mercury) were identified in the risk assessment as an exposure medium, "exposure by these pathways and the consequent bioaccumulation in organism tissues were not quantitatively addressed because appropriate data were not located." It is imperative that risks to local fish populations due to mercury ingestion be considered and, in addition, that this pathway of human exposure be considered in the health risk assessment.

Health risks due to ingestion of dioxin in local meat and dairy products were severely underestimated in the previous analysis and must be reassessed. An expert in the fate, transport, and risks of dioxin who has served on EPA review panels found that Holcim's risk assessment underestimated risks due to ingestion of dioxin through beef and milk by a factor of 1,000. In addition, it was found that total exposure to dioxin was significantly underestimated and probably exceeds the "negligible risk standard" that Holcim must meet according to Montana law. A comprehensive and transparent analysis of human exposure to dioxin must be conducted in the EIS.

Impacts of hazardous emissions on local game populations must be considered in the EIS. Although adjacent landowners have confirmed that large resident populations of antelope, mule deer, and white-tailed deer graze on the property surrounding the Trident facility, the risk assessment did not consider impacts to any mammal larger than the red fox, citing the unavailability of data. This omission is unacceptable. In addition, human exposure through the ingestion of game meat should be included in the health risk assessment.

Impacts to endangered species native to the local area must be assessed in the EIS. Although the environmental assessment issued by the DEQ stated that Holcim identified species of concern within an approximately two-mile radius of the facility and that "Holcim analyzed the species in the screening level ecological risk assessment," in fact, Holcim analyzed absolutely none of those species, citing a lack of data and that populations in the area "were not confirmed." This inexcusable omission must be rectified in the EIS.

Before a comprehensive risk assessment can be made, Holcim must submit specifications on their proposed modification. Without this information, the potential for dioxin formation cannot be assessed. The Administrative Rules of Montana (17.8.748) require detailed descriptions, drawings, and diagrams of any new or modified equipment. The present application contains three sentences of text describing a system to insert tires into the kiln along with one grainy photograph. According to an industrial engineer who reviewed Holcim's application, it is impossible to adequately assess the potential for dioxin formation in the kiln without these design specifications. In addition, if Holcim is permitted to incinerate tires without submitting modifications, it will set a significant precedent for future air quality permit applications.

An accurate and comprehensive BACT analysis must be conducted. Because the incineration of tires causes a significant increase in hazardous air pollutants and carbon monoxide, Holcim had to undergo a Prevention of Significant Deterioration review, as required by the federal Clean Air Act. Part of this review requires that Holcim install the best available pollution control technology. Holcim's BACT analysis deemed that all available control technologies (such as regenerative thermal oxidizers and catalytic oxidizers) were "economically infeasible." However, a review of Holcim's calculations found gross errors in costs of equipment and operating costs. An accurate analysis of potential pollution control technology is imperative, especially given the hazardous nature of the pollutants associated with tire burning.

A more thorough review of the impacts of potential upset emissions must be conducted. The draft permit would have allowed Holcim to continue burning tires even when the kiln is experiencing upset conditions and the pollution control device is turned off, allowing uncontrolled emissions to escape into the atmosphere. Insertion of tires into the kiln would stop only when the duration of an upset exceeded 15 minutes. (Note that Holcim, in its comments to DEQ, has asked that this period be extended to 30 minutes.) This is particularly troublesome in that Holcim's outdated wet-process kiln experiences frequent upsets, many of which are less than 15 minutes long. These add up to large amounts of uncontrolled pollution and should be taken into account in assessing health risks.

The importation and incineration of other states' wastes in an area of intense agriculture and livestock and dairy production is an issue of environmental justice that must be addressed in the EIS. During the late 1990s, state government studied the issue of waste tires in Montana and found that "Montana does not have a problem with waste tire management." In fact, Holcim would have to import from other states or Canada more than half the tires it would burn, making the Gallatin Valley a regional waste incineration site.

The estimates of hazardous air pollutants in Holcim's application are highly questionable and must be reevaluated. Emissions from tire burning at the Trident plant were predicted through the use of data Holcim gathered from other cement plants of varying sizes and different processes, using a variety of fuel types. Data was not available for many pollutants of concern. Even the toxicologist hired by the DEQ to review Holcim's risk assessment stated in a memo to the department that "there is substantial uncertainty regarding the accuracy of the estimate emissions" and that Holcim's approach "may be subject to controversy." The EIS should collect new data that is valid for Holcim's case, that is, data from wet-process kilns burning whole tires in conjunction with petroleum coke and coal.

The economic impacts to area property values and to agriculture and livestock and dairy production must be considered. Additionally, impacts to businesses that have located in the Gallatin Valley for high quality of life should be considered. Among the record number of comments submitted to the DEQ on Holcim's draft permit were many concerned with economic issues. Allowing waste incineration to take place upwind of the Gallatin Valley will have significant impacts on economic decision-making, property values, potential economic and real estate development, and the perceived safety of agricultural products. These impacts must be considered in the EIS.

Come to the hearing and show your support!
Manhattan Elementary School
Room Change - Multi-Purpose Room
Tuesday, January 20, 7:00 to 9:00 PM

Click Here to Comment Now!

Watch our Short Online Video

See our video (Real Video (488K), Quicktime (1153K), Windows (222K))
The one-minute video gives a great overview of our campaign while taking you along for a tour of the plant.

Other ways to help
Click here to read more about how you can help the campaign.

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.

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