DEQ to Allow Holcim Cement to Burn Tires and Slag

In July 2006 the Montana Department of Environmental Quality gave preliminary approval to Holcim Cement to burn more than a million tires and use 15,000 tons of toxic slag each year in its cement kiln at Trident near the headwaters of the Missouri River. The decision came despite promises by Governor Brian Schweitzer that “a new day had dawned” at DEQ and that a thorough environmental analysis would be completed.

There are too many flaws in DEQ’s environmental impact statement to detail individually here. But three flaws are so fundamental that they must be mentioned. First, DEQ has no idea what toxic air pollutants Holcim is currently releasing into the air. Second, DEQ has failed to analyze how burning lead smelter slag will impact air pollution. And third, DEQ has grossly underestimated the risk posed by the dioxin pollution that will be released when the tires are burned. This article will cover each of these issues in turn.

First, an environmental impact statement is supposed to identify cumulative impacts—in this case, of burning tires and using slag at Holcim. To do that DEQ must know what toxic air pollutants the Holcim plant is currently emitting, and what additional emissions will occur when slag is used and tires are burned. Holcim is currently allowed to burn coal, petroleum refinery waste, and used glass, and is already releasing many toxic pollutants including dioxin, mercury, lead, chromium, and arsenic. But Holcim has not provided any quantitative data on its current toxic emissions, and DEQ is not requiring it to do so.

Instead, DEQ is allowing Holcim to play a complicated shell game designed to avoid answering the simple question of what is coming out of its “smokestack” right now. Holcim estimated its current air pollution using data from 11 other kilns in other states that burn a different mix of fuels and wastes. Holcim claims that it took the data from these other kilns and verified it with an emissions test at Trident. Unfortunately, DEQ and the public are not allowed to see the data from Holcim’s emissions test because DEQ refuses to require Holcim to submit it.

Therefore, DEQ is basing its decision on data that it has never reviewed and cannot verify. It has no idea if the data are accurate or representative. DEQ is blindly trusting Holcim, and asking the public to do the same. The problem is that without knowing how much pollution Holcim is currently releasing, it is impossible to know whether the increased pollution resulting from burning tires and using lead smelter slag will harm public health and the environment.

Second, DEQ never studied whether using lead smelter slag would increase air pollution. The slag comes from the now-closed ASARCO smelter in East Helena, which is a federal Superfund site. Last year a Gallatin County resident learned that Holcim was using the toxic slag without having an air pollution permit to do so. A month later a roomful of concerned citizens, and MEIC, met with Gov. Brian Schweitzer to voice their concerns. The governor assured everyone that DEQ would be on this “like stink on a skunk.”

People left the meeting feeling hopeful that DEQ might finally investigate and alter this illegal practice. Five months later DEQ cut a deal with Holcim that allowed it to continue using the slag without a permit. But DEQ assured the public that the environmental analysis and risk assessment being prepared for Holcim’s tire-burning proposal would include an analysis of the risks posed by using slag. Unfortunately, the documents released this Summer completely fail to do so.

Holcim says that it uses lead smelter slag as a replacement for iron ore that is needed to make cement. But a comparison of iron ore to lead smelter slag shows that toxic air pollution emissions could increase when the slag is substituted for the ore. Compared to the iron ore the plant was using, ASARCO slag contains 4,344% more manganese, 545% more arsenic, 457% more chromium, 180% more cadmium, and 34% more lead. The slag also has a higher pH level, and contains more cobalt, antimony, nickel, phosphorous, selenium, and zinc.

So, with a complete lack of information about how lead smelter slag impacts Holcim’s air pollution, and despite the governor’s promise and DEQ’s assurances of a thorough environmental analysis, DEQ now says that burning slag is safe. It appears that once again DEQ is taking a “faith-based” approach to environmental analysis.

Third, DEQ grossly underestimated the public health and environmental risk posed by the dioxin emissions that will result from burning tires. Tires contain chlorine. When chlorine is burned, it can form dioxin. DEQ admits that the dioxin emissions pose the greatest risk to health and the environment from tire burning. But instead of actually quantifying the risk posed by increased dioxin emissions, DEQ once again relied on faith rather than analysis.

Federal law places a limit on dioxin emissions from cement kilns. DEQ arbitrarily said that Holcim would never exceed that limit. So when it was supposed to be evaluating the existing dioxin emissions at Holcim, and estimating the increased risk due to tire burning, DEQ instead simply substituted the federal emission limit. Assuming that emission limit, DEQ concluded that tire burning would not increase dioxin emissions and that burning tires would not threaten public health.

In fact there is no way to know if Holcim is complying with the federal emission limit for dioxin. The law only requires Holcim to directly test for dioxin once every 2.5 years.

In conclusion, the governor and DEQ promised that the environmental analysis would answer all the questions and concerns that have been raised about the risks of burning more than a million tires and using 15,000 tons of lead smelter slag each year in the Gallatin Valley. In the end, those promises have been shown to be merely hollow words, and once again a State agency has failed in its Constitutional duty to protect public health and the natural environment.

• The DEIS can be found at: www.deq.state.mt.us/eis/Final%20Holcim%20EIS/HolcimFinal.pdf

• See MEIC's Comments to DEQ on the Draft EIS
• See MEIC Power Point presentation on tire burning at Holcim

FOR MORE INFORMATION:

• Fact Sheet on Issues Associated with Burning Waste Tires in Holcim’s Trident Cement Kiln
• Review of the Human Health Risk Assessment for the Kiln-Related Emissions at the Holcim Trident Cement Plant at Trident, Montana by Wendy Heiger-Bernays, PhD
  Associate Professor of Environmental Health, Boston University School of Public Health, September 28, 2006 (104 KB pdf)
• O2 Engineering Review of Draft Environmental Impact Statement for the Holcim (US) Inc., Tire Burning Proposal, September 2006 (996 KB pdf)
  
• History of Holcim Cement Wanting to Burn Tires
• Also visit Montanans Against Toxic Burning

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