No Toxic Burning! Holcim Cement Kiln's Plan to Burn Tires from Montanans Against Toxic Burning

September 2007 Update

The Montana Department of Environmental Quality announced that it expected to release the Final Environmental Impact Statement (EIS) in June 2007 but it has still not been released. Once it is released, a record of decision on Holcim’s air quality permit will be published approximately 15 days later. We do not anticipate that there will be another opportunity for public comment. If the outcome is not satisfactory, the next step will be to appeal the decision to the Board of Environmental Review. We will only have 15 days after the record of decision to appeal so stay tuned...

Particulate Monitoring in the Gallatin Valley is Inadequate

We have started a campaign to advocate for better monitoring of particulates in our valley. For more information, read our letter to the members of the Gallatin City-County Board of Health here.

February 2007 Update

EPA Do-Nothing Rule on Cement Kiln Mercury Pollution
Ignores Court Order, Public Outcry

Montanans Against Toxic Burning joins coalition of groups to
challenge EPA's latest refusal to control toxic mercury emissions.
Press Release

November 2006 Update

The public comment period on the long-awaited Draft Environmental Impact Statement (DEIS) and Draft Permit ended on September 28, 2006, and we now await the DEQ’s response to comments on those drafts and the departmental determination on the air quality permit.

Overwhelming evidence was presented at two public hearings (one in Three Forks and one in Bozeman) and in written comments, demonstrating that the human health risk assessment failed to show, as required by law, that burning tires and slag in Holcim’s outdated cement kiln would pose no more than a negligible risk to human health and the environment. Sixty local physicians signed a petition stating opposition to the burning of tires in the Trident kiln, and several doctors presented very compelling testimony at the hearings on the serious health impacts of lead, mercury, and dioxin emissions, all of which are expected to increase if the permit is granted. Experts in the fields of risk assessment, toxicology, chemical engineering, and air dispersion modeling submitted comments on the serious inadequacies in the state’s analysis, and several hundred local citizens stated their concerns and objections to the proposed action.

Montanans Against Toxic Burning worked closely with the Montana Environmental Information Center, the Montana Chapter of the Sierra Club, EarthJustice, and an informal coalition of local physicians on this campaign. These groups shared the various tasks of analyzing the technical aspects of the analysis and informing local citizens on the issues.

These efforts paid off. Roughly 150 people attended the Three Forks hearing, and close to 350 people attended the Bozeman hearing, filling the Bozeman High School cafeteria to capacity. A great majority of the people who testified stated their opposition to burning tires and lead smelter slag in Holcim’s outdated wet-process cement kiln. Only a small group of Holcim managers and industry representatives expressed their trust in the DEQ’s decision, asserting that Holcim has been a good neighbor and that they were not worried about health risks.

During the hearings, citizens gave voice to a long list of problems in the state’s analysis. The Draft Environmental Impact Statement failed to prove negligible risk to human health, as required by law, used very suspicious assumptions in its analysis, and totally ignored several important issues. Furthermore, the documents released to the public were missing important appendices, and DEQ failed to show how it arrived at its counter-intuitive conclusions. In addition, the DEIS failed to analyze several alternatives that might have mitigated negative impacts of the proposal, such as burning processed tires instead of whole tires or converting to a more efficient dry-process kiln.

One of the most troubling flaws in the analysis is that DEQ established an artificially low hourly limit on dioxin emissions in order to reach its conclusion that the proposal would result in no more than a negligible risk to human health and the environment, without requiring any meaningful monitoring to assure compliance with that limit. In fact, DEQ is not requiring Holcim to test dioxin emissions any more frequently than the federal requirement for cement kilns, which is every two and half years. See below for a complete discussion of the flaws in the analysis.

Another serious problem is that the risk assessment is based on the same invalid data used in the initial 2003 risk assessment. These data were extrapolated from test burns conducted at ten cement kilns burning various types of tire-derived fuel, but none of the facilities match the profile of this proposal, which is a wet-process kiln burning whole tires. This distinction is critically important because research conducted by EPA indicates that wet-process kilns have much higher dioxin emissions when burning whole tires as fuel. This finding is confirmed by the compliance history of the few wet kilns burning whole tires in the United States: Six of the seven wet-process kilns burning whole tires are out of compliance with their permitted pollution limits. Three of those are classified as "high-priority violators" by EPA, including a Holcim cement plant in Ada, Oklahoma, which was fined $321,000 in 2005 for violating its pollution limits more than 1,000 times in a single year. Despite repeated requests, Holcim has declined to share emissions data from its Oklahoma cement plant, leading one to believe that this information would be detrimental to Holcim’s Trident proposal.

DEQ also failed to adequately assess the health risks associated with burning slag from the ASARCO East Helena lead smelter. DEQ simply states in the DEIS that slag was included in its analysis but provides no evidence for how that was done. Moreover, the state failed to even disclose to the public the compositional analysis of the slag, which contains significant amounts of toxic heavy metals, including lead, arsenic, chromium, and manganese. DEQ’s stated assumption that 95% of these toxic metals end up in the final product (the remaining 5% is expected to be trapped by Holcim’s pollution control device) is not justified anywhere in the analysis. More troubling is DEQ’s failure to formally permit Holcim’s use of slag under Montana’s waste incineration statute (MCA 75-2-215). This decision sets a very disturbing precedent for Holcim’s future use of "alternative" feeds and fuels.

The state has indicated that it will take several months to respond to comments submitted by citizens and to issue the final EIS and its final determination on the permit. In the meantime, we expect that Holcim will again lobby the state legislature for a tax credit for burning tires (Holcim lobbyists pressed hard for this in the last session but their efforts were thwarted by the counterlobbying of several environmental and public health groups). We also expect that DEQ will seek to weaken the existing waste incineration statute (MCA 75-2-215), making it easier to permit industrial facilities as waste incinerators. MATB will be actively involved in these legislative issues in the coming months. In addition, MATB will be working with the Tire Depot, a tire-recycling center in Polson, supporting its plan to upgrade and expand its operation, thus enhancing its ability to truly recycle all of the waste tires generated in Montana.

Flaws in the Draft Environmental Impact Statement (DEIS) and Draft Permit

WHY YOU SHOULD BE CONCERNED: Burning waste causes much of the worst hazardous air pollution in the U.S. That’s why Montana has outlawed any waste-burning that poses more than a "negligible risk" to human health. Unfortunately, the Holcim EIS provides no assurance that tire-burning at Holcim will not pose significant risks to human health. People living and working in the Gallatin Valley need to be aware:

Burning whole scrap tires exposes people to hazardous dioxins. This is the biggest reason why doctors and other concerned citizens in our community are concerned about tire-burning at Holcim’s cement kiln:

Dioxin is among the most toxic substances ever identified, according to the National Academy of Sciences. Exposure to dioxin is linked with tumor development, birth defects, reproductive disorders, immune system disorders, and skin disorders among many other adverse health effects.

Studies by the U.S. Environmental Protection Agency (EPA) reveal that burning whole tires significantly increases emissions of cancer-causing dioxin. At Holcim’s Trident kiln, the DEQ anticipates that burning whole tires will increase dioxin emissions by 60 percent, well over federal limits that are intended to protect public health. Yet the DEQ decided to ignore this alarming jump in dioxin emissions when it prepared the health risk assessment required under Montana’s waste-burning laws.

Actual increases in dioxin emissions are likely to be even greater than anticipated by the DEQ. The DEQ is projecting emissions based solely on information from other plants, but it failed to gather any data from kilns with operations similar to what Holcim is proposing to do, that is, burn whole tires in a wet-process kiln. EPA studies show far greater increases in dioxin emissions when old "wet-process" kilns such as the Trident kiln burn whole tires.

The DEQ is ignoring threats from toxic heavy metals. Lead smelter slag containing lead, arsenic, cadmium, chromium, and other toxic metals is already going into Holcim’s kiln. Last year, the DEQ agreed that pollution from slag is a major issue that must be addressed. Yet the DEQ has never attempted to find out what is coming out of Holcim’s stack. Based on this EIS, the public has no idea whether current pollution levels are safe, or what the impacts will be if Holcim adds tires to its mix.

Unaccountably, the DEQ is predicting that emissions from heavy metals and other hazardous air pollutants are going to decrease if Holcim receives its permit to burn 1.13 million whole scrap tires and 16,535 tons of lead smelter slag annually. Yet tires contain far more heavy metals than the coal they will be replacing in Holcim’s kiln, and EPA studies confirm that heavy metal emissions go up when cement kilns use tires as fuel. Similarly, lead smelter slag contains more heavy metals than the iron ore it is replacing in the cement mix.

The DEQ is relying on pollution controls to prevent heavy metals from escaping out Holcim’s stack, but the controls don’t work during the plant’s frequent "upsets." The Trident kiln regularly malfunctions, and burning tires is likely to make the current problems worse. Of the nine wet-process kilns burning whole tires in the U.S., seven are violating their pollution emissions limits. Three are classified as "high-priority violators" by EPA, including a Holcim cement plant in Ada, Oklahoma, which was fined $321,000 in 2005 for violating its pollution limits more than 1,000 times in one year. This record inspires little confidence that the Trident facility will effectively control emissions of hazardous air pollutants if it is allowed to burn tires.

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