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IN DEPTH: The Lafarge tire-burning proposal, in detail SIGN THE PETITION: Click here...LaFarge North America Inc. has filed a TDF (tire-derived fuel) application to New York State's Department of Environmental Conservation (DEC) for a permit to burn 4.8 million whole tires annually in two old (1960's technology) kilns at its plant in Ravena New York in southeastern Albany County. Currently the plant uses coal as fuel at this plant. Tires would be delivered in trailers (25-40 trips per day) with up to 100,000 tires stored in trailers on-site. LaFarge proposes to modify the kilns by installing a opening midway down the kiln chute that would open to receive 6 tires from a conveyor at every rotation of the kiln. The DEC has reviewed the application and determined it to be complete. This does not mean that the application is complete, but rather than it is ready for Public Comment. The Comment Period closes on September 2, 2005; groups and towns have called for an extension. A Legislative Hearing to take public comments is scheduled for Thursday August 25th at 7 pm at the A.W. Becker Elementary School on Route 9W in Bethlehem (see below). NYS scrap tire management policy uses the commonly accepted hierarchy for disposal of solid waste. In this hierarchy the highest value is placed on reducing waste at the source. The next two high valued strategies are reuse and recycling. Just above disposal in landfills (obviously the least desirable option) is waste-to-energy recovery. TDF in cement kilns fits into this category of waste management--second to the bottom in order of desirability. Scrap tires are normally considered to be solid waste and as such are subject to state regulations governing solid wastes. The familiar and hazardous tire stockpiles fall under these regulations. On the other hand, when tires are used for fuel they are reclassified by the DEC as a "beneficial use," and then are not subject to the solid waste regulations. The storage and handling of the TDF would be covered under a Part 360 Solid Waste Management Facility Permit and the use of the tires as fuel would be covered under a Part 360 Solid Waste Beneficial Use Determination (BUD). In addition, LaFarge needs a modification to its existing Title V Air Permit to use tires in place of coal. What's potentially wrong with this proposal? Cement kilns are not designed or constructed to be incinerators. Cement kilns are single chambered combustion devices. Tires contain 10-25% extender oils that, because of a higher molecular weight than rubber, require more oxygen, higher temperatures, longer residence time and more turbulence than rubber. They are best burned in dual chamber combustion devices such as waste incinerators that can achieve those optimum conditions. Cement kilns are not meant to be operated as incinerators. Due to the difficulty of maintaining constant temperature and airflow cement kilns are prone to upsets and incomplete combustion. According to engineer Alex Sagady, small particles as well as other unburned waste may be emitted during such events. Higher rates of toxic emissions will be more probable during a combustion upset and malfunction. Adding whole tires increases the probability of such upsets. LaFarge's wet process kilns are less efficient and reliable than newer kilns. The LaFarge proposal contains no provision to upgrade the old technology at the Ravena plant, nor to add new pollution control mechanisms. Cement kilns are not regulated as incinerators. There are different rules, regulations and regulatory policies with respect to BACT (best available control technology) review, air modeling, and public health evaluation. All medical, municipal, and hazardous waste incinerators cannot operate without their afterburner or secondary combustion chamber in normal operation. Cement plants usually have inadequate pollution control equipment for tire disposal. Tires are not benign substances to burn. Tires contain styrene, butadiene, benzene based extender oils and other petrochemicals, chlorine and up to seventeen heavy metals including lead, zinc, arsenic, chromium and copper. In addition to the emission of criteria pollutants (carbon monoxide, nitrogen dioxide, sulfur dioxide and particulate matter) that affect atmospheric pollution and aggravate respiratory problems, the incomplete combustion of chlorinated materials produces dioxins, furans, PCBs, PAHs. These non-criteria pollutants are all recognized as carcinogens and reproductive and developmental toxins. that cause cancer, birth defects, impaired child development. According to the US EPA, "Exposure to dioxin, even at minute levels, poses cancer risks and health concerns wider than previously suspected, including possible damage to the immune and reproductive systems." There are no safe levels of exposure to dioxins. TDF will not necessarily result in decreased emissions. An EPA Report on emission tests from 22 tire-burning facilitie included the following results from the three power plants that had baseline data and that were previously using only coals. Particulates went down in two and in the third, up twice and down twice Sulfur Dioxide went down in one, up in the other two Nitrous Oxide went down in two, up in one. While these emissions generally went down, it is a mixed bag. None of them tested for metals, dioxins, or most of the other non-criteria pollutants. In an independent report for the California Integrated Waste Management Board.(prepared by UC Davis professor, Seymour Schwartz) that looked at test results from four California cement kilns burning tires as 20% of their fuel Dioxins and furans increased between 53% and 100% in all four cases; Polycyclic aromatic hydrocarbons increased in three cases (between 296% and 2230%) and decreased in one; Lead emissions increased in three cases by 59%, 388%, and 475%, and decreased in one; Hexavalent chromium increased in one case by 727%, and decreased in two others. A test burn of 10% tires at a Kaiser cement kiln in California found increases in 11 of the 20 pollutants tested: a 603% increase in lead emissions 30% increase in dioxins 837% increase in hexavalent chromium increases in nitrous oxides and particulate matter LaFarge's application predicts that criteria pollutant emissions are not expected to increase However carbon monoxide emissions will increase as will cadmium, lead, mercury, selenium and zinc. These assertions--the amount of increase as well as the projection of emissions that won't increase-- all need to be subjected to independent review and verification. What is Friends of Hudson doing about this proposal? Friends of Hudson is an interested party in the DEC review process. The organization is committed to leaving no stone unturned to ensure that this permit, if granted will meet the highest standards of protection of the public heaklth and safety. Jeff Baker of the Albany law firm Young, Sommer is our lead attorney, working with Beth Morss and others in the firm. Camp Dresser McKee (CDM) are our consulting engineers. This is the team that provided the legal and technical consultation and support that enabled us to prevail against SLC's Greenport proposal. Friends of Hudson will participate actively in the public comment period. Our findings will be submitted into the record of the DEC's review process. We will work aggressively to ensure that the DEC process is conducted to be maximally protective of the public's interest. Friends of Hudson will provide information and support to the public in this matter. Friends of Hudson is conducting several information meetings throughout the most heavily affected area (northwestern Columbia, southwestern Rensselaer, southeastern Albany and northeastern Green counties, as well as towns in the Berkshires). We are providing information on the proposal as well as information and support for public participation in the review process. Friends of Hudson is working with local elected officials to ensure that they have the information that they need to represent their constituencies in the review process. The Towns of Chatham, Kinderhook and Stuyvesant, and the Village of Kinderhook in Columbia County are interested parties in the DEC's review process, as is the Rensselaer County Legislature. We are expecting to get more municipalities involved. Friends of Hudson is engaging the participation of other interested groups. Already Citizens Environmental Coalition, Clearwater, Environmental Advocates, The League of Conservation Voters and Sierra Club among others are expected to join us in voicing concerns and requesting extensions to the comment period What can you do? Get involved and get others involved. First become informed about the proposal and the issues it presents. Prepare yourself to effectively participate in the process. Submit comments in writing to the DEC, telling them why you are concerned about or opposed to the project. Attend the Legislative Hearing on Aug. 25 to make a statement or lend your support. Spread the word to your friends and family to participate in this process. Write letters to local papers. Support Friends of Hudson's efforts by volunteering or making a donation to help fund the legal and technical work on this project. Where can you get more information about this proposal? Contact the DEC for a copy of the proposal or visit an area library: William J. Clarke NYSDEC Region 4 Headquarters 1150 North Westcott Road Schenectady, NY 12306 (518) 357-2069 r4dep@gw.dec.state.ny.us Ravena Coeymans Selkirk Community Library, 15 Mountain Road, Ravena Castleton Public Library, 85 South Main Street, Castleton Contact Friends of Hudson: Friends of Hudson Office: 362 1/2 Warren Street Mailbox: P.O. Box 362 Hudson NY 12534 (518) 822-0334 tel (518) 822-9435 fax or e-mail Susan Falzon at falzon@mhcable.com ADDITIONAL INFO ON THE REVIEW PROCESS: The New York State Department of Environmental Conservation has begun a public comment period on the Lafarge proposal. A public hearing is scheduled for Thursday, August 25th at 7 pm at the A.W. Becker Elementary School in Bethlehem (southern Albany county), 1146 Route 9W. This is your best opportunity to make your concerns directly to the DEC staff. You do not need to be a resident of Ravena, or an expert in tire-burning, to attend... For directions, call (518) 822-0334 or click HERE. WHERE TO SEND WRITTEN COMMENTS: If you cannot attend the hearing, please send written comments to: William Clarke Read our news releases on this topic: Press release (8/22/05) CHECK BACK REGULARLY FOR MORE INFORMATION, OR CALL (518) 822-0334 |