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September 2006 Update
The Montana Department of Environmental Quality has released the draft EIS and a draft permit that would allow the Holcim Trident kiln to burn 1.13 million whole scrap tires annually, along with 16,535 tons of lead smelter slag (which contains a slew of toxic heavy metals, including lead, arsenic, chromium, and cadmium) from the Asarco Superfund site in East Helena. The deadline for comments is September 28. A public hearing will be held 6-9 PM on September 20 in the Three Forks High School Gym. Montanans Against Toxic Burning has contracted with experts to review the technical aspects of the analysis. However, our own survey of the documents reveals major concerns.
- First, DEQ has based its permitting decision on health risks resulting from only the increase in emissions due to the burning of tires. According to Montana statute 75-2-215, Holcim must prove negligible risk to human health and the environment based on its total emissions, not simply the increase due to the addition of wastes.
- Second, the EIS predicts pollution without examining any data from cement kilns like the Trident kiln, that is, wet-process kilns burning whole tires. Not one of the ten kilns in the data set are wet-process kilns burning whole tires. In the United States, only nine wet-process kilns burn whole tires, and seven of those are out of compliance with their permitted emissions limits. Three are classified as “high-priority violators” by the U.S. Environmental Protection Agency, including a Holcim cement plant in Oklahoma, which was fined $321,000 in 2005 for violating its pollution limits more than 1,000 times in one year. The fact that Holcim excluded data from wet-process kilns burning whole tires is especially critical given that EPA has found that these kilns have much higher emissions of dioxin. Given Holcim’s egregious record of malfunctions and equipment failures, the plant is well positioned to become the next addition to EPA’s list of high-priority violators.
- Third, the Montana DEQ has deliberately excluded predicted increases in dioxin emissions from analysis in the health risk assessment. Although the data chosen by Holcim tends to underestimate projected emissions for wet-process kilns, they nonetheless show very large increases in dioxin emissions. Yet DEQ has allowed Holcim to factor in only the federal legal limit for cement kiln dioxin emissions, which is far lower than what Holcim’s own data indicate is actually emitted. DEQ is electing to ignore a clear public health hazard—toxic emissions of dioxin—in order to conclude that Holcim’s tire-burning proposal will pose no more than a negligible health risk, as required by Montana law.
- Fourth, the DEQ simply accepted Holcim’s proposal without seriously considering any alternatives that would address pollution concerns. Modernizing the plant to make it more efficient, installing more effective pollution control technology to capture hazardous emissions, and using crumbed tires instead of whole tires in order to reduce hazardous pollutants were all dismissed as “unfeasible,” without conducting any cost/benefit analysis.
- Fifth, the DEQ has failed once again to provide any design specifications that would make it possible to accurately assess the potential for the formation of dioxin and other hazardous pollutants when inserting whole tires into the middle of the kiln.
- Sixth, the EIS fails to account for existing public health risks from Holcim’s use of lead slag from the ASARCO lead smelter in East Helena. Two years ago, the DEQ discovered that Holcim was purchasing lead slag from the East Helena Superfund site as a cheap source of iron for its cement mix. However, the slag has a hidden cost, which is high lead and heavy metals content. Because kiln temperatures of 2500 degrees or more will vaporize heavy metals in the slag, adding slag to Holcim’s kiln raises serious concerns about the release of hazardous air pollutants from Holcim’s stack. DEQ assured the public that it would assess the impacts of burning lead slag in combination with tire-burning during this EIS process, yet the analysis in the draft EIS considered only the incremental increase in emissions resulting from tires in its permitting decision.
- Finally, the analysis in the draft EIS lacks transparency. Because the supporting evidence and calculations are absent from the document, it is impossible to determine how DEQ arrived at its conclusions. The law requires that Holcim prove negligible risk to human health and the environment before it is permitted to burn wastes. This document does not provide the evidence to support that conclusion.
Comments on the draft EIS and draft permit should be sent to:
Montana Department of Environmental Quality
Director’s Office, Attn: Greg Hallsten
P.O. Box 200901
Helena, MT 59620-0901
Check back soon for more details as we get more information from our experts. Once we have completed our analysis, we will be sending out alerts and talking points.
Recent Press
The best new article that reflects the latest developments is from New West.
July 25, 2006 Update
The Holcim draft EIS and draft permit will be released very soon!
The draft Environmental Impact Statement (EIS) and draft permit for Holcim’s plan to burn more than 1 million scrap tires annually along with slag from the Asarco lead smelter Superfund site in East Helena are expected to be released in the final week of July. Check this Web site frequently for summaries of these important documents and for announcements on the comment period and public hearing.
In July 2005, the Montana Department of Environmental Quality announced that Holcim could continue its use of Asarco slag while state officials incorporated the risks of burning slag, which has significant amounts of lead, arsenic, chromium, and cadmium, into the risk assessment being conducted for tire burning. By law, Holcim must prove negligible risk to human health and the environment before being permitted to burn these wastes. Click Here for more information.
Click here for our most recent informational fact sheet.
August 14, 2005 Update
Following is link to a letter to the editor of the Bozeman Daily Chronicle on the issues related to burning Asarco slag in the Holcim cement kiln.
Letter to the Editor Submitted to the Chronicle
Below the letter is a longer version that contains supporting information.
June 14, 2005 Update
Following is a link to a guest editorial submitted to the Daily Chronicle by Montanans Against Toxic Burning in response to Holcim’s two-month advertising campaign. Below the editorial, we list links to sources that document the information in our editorial.
Editorial Submitted to the Chronicle on June 9, 2005
Supporting Links for more information
April 3, 2005 Press Release
Click here for a recent press release regarding Holcim's use of slag waste from the Helena Superfund site.
Archives of Older Updates
Click Here for the archives.
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