LONE STAR CHAPTER SIERRA CLUB ON BEHALF OF THE WEST VALLEY CITIZENÕS AIR WATCH COMMENTS ON RESOLUTION 97-425 TO AUTHORIZE TIRE-DERIVED FUEL USE IN CEMENT KILNS AND UTILITY BOILERS FOR ENERGY RECOVERY Submitted October 22, 1997 to the California Integrated Waste Management Board Sacramento, California Public comments are being submitted on behalf of the West Valley CitizenÕs Air Watch to the California Integrated Waste Management Board on a proposed plan to authorize scrap tire disposal in cement kilns and utility boilers for energy recovery. These comments were prepared by Neil J. Carman, Ph.D., Clean Air Program Director for the Lone Star Chapter of the Sierra Club.
We believe that cement plants have inadequate pollution control equipment for tire disposal. (15) Cement kilns are designed to bake rock until it makes cement "clinker," not to burn wastes. Many of these kilns use old and outdated cement making technology.(16) All rely on only one air pollution control device to filter stack emissions - the same device they use whether they are making cement or burning waste. This device, designed to remove particles, does not remove heavy metal vapors like mercury or other toxic gases released from burning tires. Nor does it remove all dioxins, PCB's, or furans which tend to be created when tires are burned in cement kilns and for which many scientists say there is no safe level of exposure. (17) Health problems from heavy metals, hydrocarbons, products of incomplete combustion, and newly created substances like dioxin emitted when burning tires are magnified when combined with dust emissions that are part of cement production process.(17) No matter what kind of waste or fuel is being burned in them, cement kilns are large air polluters. (18) They are a major source of Particulate Matter (soot and dust) which has been found to be toxic to human health in its own right, even at the smallest measurable levels of exposure.(19) When waste is burned in cement kilns, this Particulate Matter acts a magnet for unburned toxic metals such as lead, arsenic, cadmium and chromium and Products of Incomplete Combustion emitted from their stacks.(20) This "toxic enrichment" of the tons of Particulate Matter these cement kilns release into the atmosphere when waste is burned creates a major public health hazard which we believe should not be imposed upon us or our children.(21) Cement kilns are the second largest source of dioxin emissions in the U. S.(22) The most toxic dioxins have been found only in cement plant emissions where synthetic substances are burned. (23) If they are allowed to burn wastes that could result in the creation of dioxin, we believe that cement kilns should be required to install continuous dioxin monitoring and control equipment. Incineration plus chlorine makes dioxin.(24) Dioxin is a potent toxin capable of a variety of adverse health effects, including hormonal disruption, decreased sperm count, decreased testis size, altered male sexual behavior, cancer, endometriosis, ovarian dysfunction, reduced fertility, immune system suppression, spontaneous abortion, birth defects, impaired child development, thyroid changes and diabetes.(25) The average person currently carries a body burden of 15-20 parts per trillion of dioxin.(26) Even a single, minute exposure to dioxin can cause irreparable harm to unborn children.(27) Evidence that body burdens are increasing or decreasing conflict and are inconclusive. There are significant reservoirs of dioxin already in the environment.(28) We don't want any more created. We believe cement kilns should not be allowed to use wastes that contain chlorine (or other halogens like bromine) without continuous dioxin emission monitoring and control equipment. Many people who live downwind of cement plants already carry unhealthy body burdens of toxic heavy metals and/or synthetic chemicals many of which mimic hormones and have other toxic effects. (29) The slightest additional exposure will cause these people harm.