Bison Engineering's Responses to the Holcim Draft Permit

The Department of Environmental Quality received approximately 1,500 letters commenting on Holcim's draft permit to burn tires in their cement kiln at Trident. Only two of those letters were from proponents of the project. One of those letters was from Bison Engineering, Holcim's consultants for the tire-burning project. Apparently, Holcim believes that they did not receive enough concessions from the DEQ in the draft permit. They are asking for much more. The following highlights some of the changes requested by Bison Engineering.

• allow 30-minute (instead of 15-minute) upset before being required to stop tire feed into kiln (an upset is a malfunction during which the pollution control equipment is turned off, allowing uncontrolled emissions)
• eliminate the limit on the number of tires to be incinerated
• eliminate the recordkeeping of the number of tires incinerated
• change the designation of "passenger and/or light truck tires" to "waste tires" (that is, no restrictions on size, weight, class, etc.)
• change "whole waste tires" to "waste tires" (potentially allowing the incineration of cut-up industrial tires, which contain huge metal belts)
• eliminate testing for volatile organic compounds (VOCs)
• eliminate the limit on VOCs
• eliminate the limits on lead, arsenic, and beryllium-all of which are classified as hazardous air pollutants (HAPs)
• require the remaining limits on HAPs to apply only to that portion of emissions resulting from the incineration of tires (making the limits potentially unenforceable)
• conduct only one baseline test instead of two
• test for dioxin only every two and a half years instead of annually