Tire burn plan advances

By: Richard Roth IndeNews March 3 , 2006

RAVENA-The state Department of Environmental Conservation (DEC) has released a 92-page document answering public comments on the Lafarge Building Materials proposal to burn old tires to fire its cement kiln across the Hudson from Northern Columbia and southern Rensselaer counties.

       The entire application , which includes a draft permit and the public comments were sent to the federal Environmental Protection Agency Thursday, February 23, according to DEC spokesman Rick Georgeson. The EPA will give the plan a final review and has 45 days to register any objections.

       "If they [EPA] have any concerns we have to address those before issuing a permit," said Mr. Georgeson. "Barring any unusual circumstances, we plan to issue a permit at the end of 45 days."

       The DEC does not appear to have found any objections that had not been addressed prior to the public comment period. But Susan Falzon, executive director at Friends of Hudson, said her group may mount a legal challenge to approval of the plan depending on the content of the draft permit. Friends of Hudson lawyer Jeff Baker is expected to see the application and the draft permit within the next few days.

       "We're confident that the findings of our experts had merit, and if we need to take further steps we will," said Ms. Falzon.

       Opponents of the proposal who live on the east side of the Hudson fear pollution from the plant will beblown their direction by the prevailing winds.

       The DEC document, called a Responsiveness Summary, addresses 301 oral and written comments, one of which came with 1,189 signatures attached. While the majority of the comments expressed concerns over possible negative impacts on the environment and public health from the use of the old tires in what is called tire derived fuel, there were also safety assurances from neighbors of Lafarge plants in Pennsylvania and Oklahoma already burning tires in their kilns.

       The department received more than 150 comments on possible effects on health and the environment from toxic emissions, including heavy metals such as cadmium, zinc, mercury, lead and arsenic as well as PCBs (polychlorinated biphenyls), benzenes, particulate matter, volatile organic compounds and dioxins. Health impacts cited include the possibility of increased cases of cancer, Parkinson's disease, asthma, reduced IQ, rheumatoid arthritis, and lupus.

       To a commenter who requested that DEC provide the sources and methodologies used to evaluate claims and statements made by Lafarge, the summary states that "the tests utilized were largely based on testing methods developed by EPA to ensure data accuracy and representativeness."

       To address concerns over the use of whole tires rather than shredded tires, the DEC points out that steel, a component in modern tires, is a necessary ingredient in making cement, and that in the absence of tires containing steel, iron or steel would have to be added to the process.

       Moreover, according to DEC, making 24,000 tons per year of tire chips using a portable diesel-powered shredder would take approximately 200,000 gallons per year of fuel oil and generate 66 tons per year of NOx (nitrogen oxide), 13 tons per year of CO (carbon monoxide), 4 tons per year of SO2 (sulfur dioxide), 5 tons per year of VOC (volatile organic compounds), and 4 tons per year of PM10 (larger particulate matter).

       The summary points out that a cement kiln operates with a flame temperature of 3,000 degrees Fahrenheit, considerably higher than that of a commercial incinerator, and that tires will be consumed at a temperature of 1,500 to 1,800 degrees within 30 seconds of being introduced into the kiln.

       The summary includes a number of comments noting that tire derived fuel has been used for over 30 years, and that it is approved for use in 65 kilns at more than 40 cement plants in North America, including two in New York.

       The DEC has required Lafarge to conduct baseline stack tests for small particles of pollution called PM10 as well as PCBs, metals, fluoride, ammonia, sulfur dioxide, carbon monoxide, dioxins, furans and other emissions. Dioxins and furans are highly toxic materials. "Lafarge will be held to their predicted emissions estimates as their permit application will be incorporated by reference into their permit," the Responsiveness Summary states in response to a comment by Mr. Baker.

       If actual operating results are not acceptable, the DEC states, "the percent tire supplement may be reduced and/or additional permit conditions monitoring kiln operating parameters will be written to ensure proper operation and combustion during the firing of tires in the kiln and subsequently, adequate environmental and public health protection."

       The DEC assigns environmental ratings to air contaminants after consideration of four items, according to the Responsiveness Summary. They are

       *Toxic and other properties and emission rate potential of the contaminant
       *Location of the source with respect to residences or other sensitive environmental receptors, including consideration of the area's anticipated growth
       *Emission dispersion characteristics at or near the source, taking into account the physical location of the source relative to surrounding buildings and terrain
       *The projected maximum cumulative impact, taking into account emissions from all sources in the facility under review and the pre-existing ambient concentration of the air contaminant under review.

       The projected emission impacts from the Lafarge proposal are 10 to 100 times less than air guidance concentration levels DEC has established as protective of public health, according to the summary. With the exception of zinc, it states, actual emission levels are expected to be similar to what is currently emitted from the kiln. Moreover, according to DEC, "It is possible that emissions, including mercury, may be reduced with TDF usage."

       The DEC also expects a reduction in nitrogen oxides, which are a precursor to smog. The department acknowledges that zinc oxide emitted as a particulate may present an inhalation hazard. "However," the summary states, "the respiratory effects elicited by particulate matter containing zinc and/or zinc oxide are the same as those elicited by particulate matter which does not contain zinc."

       In addition, it states, the assessment of zinc emissions completed by Lafarge and independently reviewed by DEC "showed that predicted zinc impacts from this project would be way below the public health guidelines established by the Department."

       Several comments expressed concerns with lead, which can have an impact on children's health and IQ. And one commenter noted that EPA is not expected to produce a new lead standard until 2009 and that current criteria are based on a 1979 standard.

       "The department will continue to follow the review of the lead Criteria Document and supporting scientific literature," states the DEC response. However, it continues, the predicted impacts "present negligible risk from this proposed modification to utilize TDF at Lafarge."

       Many comments noted that the Ravena plant has a history of non-compliance with existing air permits, whether caused by equipment malfunctions, poor monitors, inadequate operating procedures, or human error. But the department responds that some of the specific instances cited occurred prior to Lafarge's taking ownership of the facility in mid-2001, and that compliance has improved significantly since then.

       Tires for the Lafarge plant are to come from within a 200-mile radius of the Ravena plant, and Lafarge will not be permitted to burn tires during startup, shutdown or during a kiln malfunction. Tires can amount to no more than 20% of the total fuel used to fire the cement kiln

       Should the permit be issued, Lafarge will conduct additional stack testing after TDF usage has begun, the Responsiveness Summary states, in order to validate the assumptions made in the application. In addition, the permit will require continuous monitoring for carbon monoxide, nitrogen oxides, and opacity to ensure that permit limits are not exceeded.

       Bidding and construction is expected to take approximately 18 months from the date permits are issued, according to Lafarge spokesman David Vahue. Mr. Vahue said the cost of adapting conveyors and kiln shells was originally estimated at $8 million, but that variables in the cost of materials could change that figure. The Ravena plant is one of the largest cement-making operations in North America.

       To contact reporter Richard Roth, e-mail rroth@indenews.com.©The Independent 2006

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