1. Hazards of tires.
It is highly inaccurate to state that tire derived fuel, (TDF) ... "does not contain hazardous materials;" A. Tires are mfg from petrochemical feedstocks such as styrene and butadiene, which are both being classified as human carcinogens. Styrene is a benzene derivative and burning tires releases styrene and several benzene compounds. Butadiene is a highly carcinogenic four-carbon compound that may also be released from the styrene-butadiene (SBR rubber its called) polymer form during combustion. Chemical composition tests on waste rubber show that it contains numerous toxic and hazardous air pollutants and once burned, these can become airborne. I have lab results somewhere on tests that I helped to perform as a state official, and we were surprised that waste rubber from SBR was not classified as a hazardous waste. M, P and O-Xylenes may also be found in TDF which are benzene derivatives and carcinogenic. Tires --older tires--used to be made from chloroprene, a chlorine-containing petrochemical used less and less today in tire mfg. Polybutadiene is another polymer used to make synthetic rubber for tires. Aromatic extender oils comprise about 25% of most tires today and are known to cause cancer in lab animals as well as being suspected human carcinogens. These are highly aromatic--multiple benzene-containing chemicals--petroleum waste materials with complex ring structures that are even more difficult to burn that benzene, which has a highly stabile ring structure that makes good combustion far more difficult that burning natural gas or straight chain carbon compounds. Anything with benzene will require higher combustion temperatures, higher residence times and higher oxygen to break apart the six-carbon ring with electron clouds above nd below that protect the ring from easy chemical breakdown.. The thick black oil and black smoke that one sees when tires are burning outdoors is due solely to the aromatic extender oils; they too require higher combustion temperatures, higher residence times and higher oxygen to break down fully to CO2 and water. Do cement kilns really provide higher combustion temperatures, higher residence times and higher oxygen? These are complex process questions that can be debated by different technical experts to give very different sets of answers, and because there are generally two different kinds of cement kilns such as 1) old, energy inefficient wet process kilns and 2) newer, more energy efficient dry process cement kilns. Generally cement kilns run at higher combustion temperatures than incinerators, but I think it is highly questionable that anyone can make an absolute blanket statement supported by solid scientific proof that cement kilns provide longer residence times and adequate oxygen (i.e. as excess air) to give complete combustion. Why? a) Cement kilns when stack tested show products of incomplete combustion (PICs) just like incinerators and other combustors demonstrating that perfect combustion is not being achieved. So something is not right with combustion. b) Turbulence for good combustion may not be as perfect as some experts claim in cement kilns due to the extraordinarily large volumes of solid materials in the kiln being used to make clinker and then cement product, in part since a cement kiln is a giant oven used to bake rock and turn it into clinker. c) cement kilns typically run on the lower limits of excess air for good combustion due to the huge quantities of air required to be heated from ambient temps to 3,000 degrees F, and to heat this much air to such high temps requires tremednous energy costs. So every single pound of air heated in a cement kiln exacts a certain operating costs in fuel use and thus cement kilns try to keep the excess air (and oxygen) at the borderline of safe combustion. But during stack tests of TDF cement kilns will do several things to make emissions and combustion look good-to-decent for such facilities: a) run at higher excess air to improve combustion efficiency, b) control kiln parameters more precisely, c) prevent kiln solid ring formation and buildup that creates havoc for good combustion of any fuels, d) burn lower TDF levels during stack tests than they may be seeking to burn operationally, e) operate and maintain their ESPs or baghouses in top condition to keep particulate emissions to a reduced level; and f) miscellaneous tricks. B. Older tires may contain much higher amounts of lead when leaded gasoline was being used, according to Dr. Jerome Nriagu of the Uinversity of Michigan's School of Public Health. Burning these older tires means that some of the lead will go back into the environment as airborne contamination. C. Metals. TDF does contain metals and these amount vary somewhat. They m,ay be cleaner that real dirty coal or they may be worse than some cleaner types of coal. One also has to be skeptical about self-reported metal levels in coal, such as mercury, because coal users want to show less mercury emissions than is the case. D. COMBUSTION UPSETS. This is a serious public health issue near cement kilns. Cement kilns certainly do have combustion upsets and smoke may be emitted during such events. Cement kilns are not designed or required to have major fail-safe combustion devices such as large afterburners that all state-of-the-art incinerators must have by federal law today (all medical, municipal, & hazardous waste incinerators can not operate without their afterburner or secondary combustion chambers in normal operation). The afterburner is required because of the potential for flame outs and total combustion failure in the primary burn chamber, which is all that cement kilns possess. Cement kilns have no fail safe combustion devices which is unthinkable today in all incinerators. E. Other kinds of upsets. Cement kilns are subject to a variety of problems, including a type of meltdown of the kiln when the ID fans lose power or fail to operate; without adequate air flow to control kiln temperatures at or below 3,000 degrees F, the kiln temperature may skyrocket quickly to 4,000 degrees F and the kiln is so hot that the steel shell sags toward the ground effectively destroying the kiln. Kiln meltdowns are not rare events and have happened here in Texas at several plants in the last ten years. Cement companies do not like to talk about this problem. These are just a few of the technical issues surrounding combustion problems observed in cement kilns. The bottom line is that they are not designed, not built and not operated as state-of-the-art incineration devices, but are basically old model-T versions (especially old wet process kilns) of first generation incinerators of the 1950's-mid 60's which had no afterburners. Sincerely yours,
NEIL J. CARMAN, PH.D. Clean Air Program Director and former Texas Air Control Board official Lone Star Chapter of the Sierra Club P.O. Box 1931 Austin, TX 78767-1931 512-472-1767 Phone 512-477-8526 Fax Email: Neil_Carman@greenbuilder.com ============ Sunday,
October 19, 1997 12:57:34 PM From: yojo@batnet.com,Internet (greenbuilder)
Subject: #3
PROPOSED EPA NATIONAL AIR QUALITY STANDARDS = FACT SHEET May 1997
Page 2 New Standards Save Money A recent EPA study found that for every
dollar we spent on air pollution controls since 1970, we have gained $45
in health and environmental benefits. EPA estimates that its new air standards
will yield $120 billion in public health benefits, including fewer work
days lost, hospitalizations, doctor visits and premature deaths. *******
New Medical Studies Support Stronger Air Quality Standards EPA's newly
proposed air standards are based on hundreds of scientific studies on humans
and animals. These international health studies have demonstrated that
levels of smog and soot below current federal air quality standards exacerbate
serious respiratory disease and contribute to early death. L.A. Children
Are Considerably At Risk Children in Los Angeles are exposed to the highest
levels of air pollution in the country. In fact, Los Angeles ranks second
only to Mexico City as having the worst air pollution on the American continent.
In Southern California alone, there are more than 2.5 million young children
breathing highly polluted air every day. As a result, Southern California
children who are exposed to polluted air over time are much more likely
to develop long-term respiratory illnesses including asthma, chronic bronchitis,
pneumonia, and emphysema, and reduced lung function. EPA Must Set Federal
Air Standards Based Solely on the Science **** Air quality standards must
protect all people, including sensitive individuals such as the elderly,
children, and people with heart and lung disease or asthma, with an adequate
margin of safety. Every independent expert panel which has reviewed the
scientific literature, including the World Health Organization and the
Clean Air Science Advisory Committee (including public health and industry
experts) has agreed with EPA that the science indicates better standards
are needed. ===========
Sunday, October 19, 1997 12:57:40 PM Message From: yojo@batnet.com,Internet
(greenbuilder) Subject: #4 List of scientific references for particulates
and ozone To: Neil Carman List of scientific reference for particulates
and ozone. This list needs to be cleaned up of comments before using it.
Joyce -----------
Key references from the peer review medical literature (e.g. not
junk science) Jefferson H. Dickey, MD Greater Boston Physicians for Social
Responsiblity, Cambridge Abbey, D. E., B. L. Hwang, et al. (1995). "Estimated
long-term ambient concentrations of PM10 and development of respiratory
symptoms in a nonsmoking population." Archives of Environmental Health
50(2): 139-52. => one of three prospective cohorts to find an association
with lung cancer; confirms development of de-novo disease in association
with particulate Abbey, D. E., P. K. Mills, et al. (1991). "Long-term ambient
concentrations of total suspended particulates and oxidants as related
to incidence of chronic disease in California Seventh-Day Adventists."
Environmental Health Perspectives 94: 43-50. American Thoracic Society,
C. o. t. E. a. O. H. A. (1996). "Health effects of outdoor air pollution.
Part 1. Committee of the Environmental and Occupational Health Assembly
of the American Thoracic Society." American Journal of Respiratory &
Critical Care Medicine 153(1): 3-50. => THE ATS review; a little outdated
already when published, but very comprehensive; IF YOU ARE GOING TO READ
ONE THING, THIS IS IT American Thoracic Society, C. o. t. E. a. O. H. A.
(1996). "Health effects of outdoor air pollution. Part 2. Committee of
the Environmental and Occupational Health Assembly of the American Thoracic
Society." American Journal of Respiratory & Critical Care Medicine
153(2): 477-98. Bates, D. V. (1995). "The effects of air pollution on chqildren."
Environmental Health Perspectives 103(Suppl 6): 49-53. Bates, D. V. (1996).
"Particulate air pollution." Thorax 51(Suppl 2): S3-8. Bromberg, P. A.
and H. S. Koren (1995). "Ozone-induced human respiratory dysfunction and
disease." Toxicology Letters 82-83: 307-16. Brunekreef, B., D. W. Dockery,
et al. (1995). "Epidemiologic studies on short-term effects of low levels
of major ambient air pollution components." Environmental Health Perspectives
103(Suppl 2): 3-13. => fabulous review of short term effects; 2nd MOST
IMPORTANT ARTICLE ON LIST Dockery, D. W., A. C. d. Pope, et al. (1993).
"An association between air pollution and mortality in six U.S. cities
[see comments]." New England Journal of Medicine 329(24): 1753-9. => the
Harvard prospective cohort; establishes size of particle as critical Dockery,
D. W. and C. A. r. Pope (1994). "Acute respiratory effects of particulate
air pollution." Annual Review of Public Health 15: 107-32. => one of two
or three best reviews on particulate; contains the most extensive meta-analysis
on paticulate Gilmour, M. I., P. Park, et al. (1993). "Ozone-enhanced pulmonary
infection with Streptococcus zooepidemicus in mice. The role of alveolar
macrophage function and capsular virulence factors." American Review of
Respiratory Disease 147(3): 753-60. Gong, H., Jr. (1992). "Health effects
of air pollution. A review of clinical studies." Clinics in Chest Medicine
13(2): 201-14. Jorres, R., D. Nowak, et al. (1996). "The effect of ozone
exposure on allergen responsiveness in subjects with asthma or rhinitis."
American Journal of Respiratory & Critical Care Medicine 153(1): 56-64.
=> ozone makes asthmatics more sensitive to allergens!!!! Koenig, J. Q.
(1995). "Effect of ozone on respiratory responses in subjects with asthma."
Environmental Health Perspectives 103(Suppl 2): 103-5. Lippmann, M. (1992).
Environmental toxicants: Human exposures and their health effects, Van
Nostrand Reinhold, New York. => this and the next reference are (by far)
the best reviews on ozone; Lippmann is (by far) one of the most knowledgeable
individuals in the air pollution field Lippmann, M. (1993). "Health effects
of tropospheric ozone: review of recent research findings and their implications
to ambient air quality standards." Journal of Exposure Analysis & Environmental
Epidemiology 3(1): 103-29. NRDC (1996). Breathtaking. => using reasonable
methodology estimated that 64,000 deaths a year in the USA are attributable
to particulate air pollution; peer reviewed by quality people (Bates, Pope
etc); contact Natural Resources Defence Council, Wasthington, DC Pope,
C. A. r., D. V. Bates, et al. (1995). "Health effects of particulate air
pollution: time for reassessment?" Environmental Health Perspectives 103(5):
472-80. Pope, C. A. r., M. J. Thun, et al. (1995). "Particulate air pollution
as a predictor of mortality in a prospective study of U.S. adults." American
Journal of Respiratory & Critical Care Medicine 151(3 Pt 1): 669-74.
=> one of the big prospective cohorts; continues to establish particulate
size as important; all three found associations with lung cancer; Schwartz,
J. (1994). "Air pollution and daily mortality: a review and meta analysis."
Environmental Research 64(1): 36-52. => the guy lives to develop statistical
models; all three meta-analyses found the samething! a 100 mcg/m3 increase
in particulate air pollution is associated with a 10% increase in daily
mortality Schwartz, J. (1994). "What are people dying of on high air pollution
days?" Environmental Research 64(1): 26-35. => case control study of the
Philadelphia story; elucidates cause of death
***************************************************************** Sunday, October 19, 1997 12:57:15 PM Message From: yojo@batnet.com,Internet (greenbuilder) Subject: some of your writing -- #1Toxics and cement kilns To: Neil Carman Hi Neil: Thanks so much for writing an opposition letter to CIWMB against Resolution 97-425. Please send a fax (so I can make 20 copies as they require) and email of your letter to me so we can read it at the hearing. Also fax it to the CIWMB. My fax # is 408 973 1087. Jane Williams will be speaking also. Seymour Schwartz has given us a two page letter to read. Bonnie Holmes-Gen, Sierra Club California, will speak. Planning and Conservation League might speak. Communities for a Better Environment is having a retreat on Oct 22 but is writing a statement and will have an intern read it. Cal PIRG will send a letter and maybe speak. Silicon Valley Toxics Coalition might speak. The Santa Clara Valley American Lung Association will not even meet with us or send or letter. They said that since no permit has been applied for that they won't do anything. I talked to Tom Bussing -- he was great and will write a letter. Anyway, with all these writers and potential speakers, you are still the only real expert on cement kilns and their hazards and toxics. THanks, thanks, thanks, Joyce ---------------------- 6/97
I also tell people that breathing a toxic soup of pollutants is like a molecular shotgun blast to our cells, in part because of synergistic and additive interactions among the various pollutants rather than evaluating chemicals one bullet at a time. Modern toxicology is plagued by the problem of having very minimal to no information on synergistic and additivity effects of chemical pollutant mixtures. The real world is not breathing one chemical bullet at a time, but usually involves breathing several to many. Lab tests do not look at synergy and additivity. Cement kilns: The cement plant I used to inspect was a very dusty site so much that I would come out covered with cement kiln dust and clinker/product dust from head to toe. The concern is that cement kilns are allowed very large particulate emissions because the cement mfg process is inherently a highly dust producing one. But incinerators today have to meet 5% opacity (indirect PM measurement) while old cement kilns can brun at 30% and many are at 20% opacity. When taken together with the fact that cement kilns also have higher stack mass emission rates (i.e., higher stack gas flow rates of 6-8 times an incinerator's) than the average incinerator, it calculates into the fact that cement kilns are permitted for much high emission levels than most incinerators. Result: more air pollution. --