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National Citizens Cement Kiln Coalition.
Myths and Facts
About Protecting Human Health and the
Environment: The Real Story About Burning
Hazardous Waste in Cement Kilns
A Commentary
on the Claims about Burning Hazardous
Waste in Cement Kilns in the
Publication, Titled "Protecting Human
Health and the Environment"
published by
the Cement Kiln Recycling Coalition
Return to the National Citizens Cement Kiln
Coalition Home Page
Note - the CKRC
has made no contribution to the material
printed below except to describe the "myths"
in the publication referenced above.
"We have one set of standards for hazardous
waste incinerators. We have another, weaker
set of standards for cement kilns."
Carol Browner , EPA Administrator July 28,
1995
Myth #1
Cement
kilns destroy wastes as effectively as other
commercial treatment facilities.
Fact
There are
twenty-four hazardous waste burning cement
kilns operating in the United States. In
1993 over 1.3 million tons of highly
chlorinated and heavy metal contaminated
waste was prepared by waste blenders and
shipped to kilns for disposal. When
hazardous waste burning cement plants burn
these industrial wastes the impacts on human
health and the environment are dramatic. The
controls on BIFs are currently less
stringent than those on incinerators.
Congressional
Research Service Report for Congress
September 11, 1995
According to the EPA, cement kilns are the
third largest source of dioxin emissions in
the United States. Hazardous waste burning
cement kilns represent 60% of the total
cement kiln dioxin emissions. Dioxin has
been found to cause cancer and adversely
affect the human reproductive and immune
systems.
According to the EPA, cement making
facilities are the second largest source of
mercury emissions to the atmosphere. Mercury
causes damage to the nervous system and
birth defects.
Cement kilns burning hazardous waste emit
significant amounts of hydrochloric acid,
nitrogen oxides, sulfur oxides, and
particulate matter compared to incinerators.
Cement kilns are the third largest source of
dioxin emissions behind medical waste
incinerators and municipal waste
incinerators.
Dioxin
Re-Assessment Report, EPA
April
1994
The data
presented in the attached charts compare air
emissions when highly chlorinated wastes are
burned in a cement kiln versus a commercial
hazardous waste incinerator. See charts 1,
2, and 3. (Information obtained from BIF
Certificate of Compliance data, trial burn
reports, Gossman reports, E.I. Digest, EPA
CETRED Report, or state government files.)
Hazardous waste burning cement kilns
generate cement kiln dust (CKD) laden with
high concentrations of toxic and
carcinogenic heavy metals like lead,
arsenic, cadmium and chromium. In 1993
alone, 1.9 million tons of toxic CKD--a
residue from burning toxic wastes--was
indiscriminately disposed in unlined
quarries where threats to groundwater
contamination are great. By contrast,
incinerator ash is treated to special
federal land disposal restriction standards
and then placed in a high-technology RCRA
permitted landfill. The effect of burning
heavy metals containing waste in cement
kilns is the re-distribution of toxic and
carcinogenic metals like lead, arsenic,
cadmium and chromium back into society
through smokestack emissions, disposal of
cement kiln dust or in the cement itself.
The National Research Council, a part of the
National Science Foundation, in their recent
report on lead exposure to children and
other sensitive populations notes that even
mild lead exposures in children (below 10
micrograms per deciliter - equal to the
weight of a grain of sand dissolved in the
bloodstream) can cause neurological and
behavior changes.
Myth #2
Cement kilns
recovered the equivalent of one million tons
of coal by adding hazardous waste to their
fuel mix.
Fact
Hazardous waste
burning is a subsidy for older,
low-technology wet process cement kilns that
have high fuel demands, and allows hazardous
waste burning cement kilns to put off
upgrading their technology to modern plants.
The real net effect for fuel consumption in
the United States is that we burn 500,000
tons of fossil fuel more per year
than would be the case if the upgrades were
put in place and no hazardous waste
was burned in cement kilns.
Aside from there being no real savings in
the nation's fuel consumption, the notion
that hazardous waste is being used by cement
kilns for energy recovery is simply a sham:
cement kilns accept hazardous waste of all
kinds without regard to energy value.
Genuine recycling--recovery of used
solvents, etc.--has in fact all but
disappeared as the huge appetite for
hazardous waste fed to cement kilns grows,
accounting today for more than 60% of the
commercial hazardous waste combustion
market. See Chart 4.
Myth #3
Cement kilns
burn hotter and have longer gas residence
times than other commercial thermal
treatment facilities.
Fact
However, several
questions remain concerning the safe usage
of solid or liquid hazardous waste in cement
kilns: Gas-phase products [of hazardous
waste] injected at the feed end of
preheater/precalciner systems or mid-kiln
for long kilns are not subjected to the same
elevated temperatures and long residence
times as those wastes injected at the
discharge or hot end. In a worst-case
scenario, volatile compounds may be released
from the container so rapidly that they are
not able to mix with oxygen and ignite
before they cool below a critical
temperature forming hazardous products of
incomplete combustion (PICs).
Scientific
Advisory Board of the Cement Kiln Recycling
Coalition
Cement
kilns have hot and cold ends. Waste
introduced at the cold end or mid-kiln may
never get to the hot end. Gas residence time
may be as little as 0.3 seconds, in an
oxygen-starved atmosphere (good for making
cement, bad for combustion of hazardous
waste). In a hazardous waste incinerator,
all waste gases pass through an afterburner
which assures high temperature destruction
in an oxygen-rich atmosphere. Cement kilns
don't have afterburners or hydrochloric acid
gas air pollution control equipment. Dioxin
and acid gas emissions are significantly
greater for hazardous waste burning cement
kilns.
Myth #4
Cement kilns
meet specific health-based standards,
regulations that are equal to or more
protective than the regulations governing
other commercial thermal treatment
facilities.
Fact
Allowable stack
emissions for toxic metals like lead,
cadmium and arsenic are based on inhalation
concentrations and air dispersion modeling.
They do not account for total mass emissions
into the environment and the risk from
exposure in the food chain and other
pathways. No standards are set for dioxin.
EPA Administrator Browner has called these
standards, Anot tough, not protective.
Myth #5
The quality of
cement is indistinguishable from cement
manufactured in kilns burning conventional
fuels.
Fact
Recent studies
conducted by Rutgers University show that
heavy metals build up in the clinker (which,
when ground up with gypsum, makes the cement
product) when wastes with heavy metal
content are burned in the cement kiln. There
are apparently no studies available to show
whether the increased levels of heavy metals
in the cement affect the quality and
durability of cement. Corrosion attack on
steel reinforced cement has not been
studied, either.
A survey of the occupational health hazards
of cement workers from exposure to heavy
metals in cement shows increased rates of
cancer, asthma and lung disease, and skin
disease. In particular, a study of Swedish
cement factories found a 60% increase in the
risk of colorectal cancer in workers with
fifteen
The database on
the fractional release of the metal
compounds from kilns should be expanded . .
. Additional data collected under both
normal and compliance test conditions are
needed . . . There is only fragmentary and
sometimes conflicting information on the
effects of: 1) chlorine content, 2) location
of waste injection, and 3) the operation of
the by-pass duct on the cycling of metal
compounds in kilns.
Scientific
Advisory Board of the Cement Kiln Recycling
Coalition
or more
years of employment. Also a study of German
workers showed an increased risk of
laryngeal cancer for workers exposed to
cement for 10 or more years. As
concentrations of dioxin and heavy metals
accumulate in cement kiln dust and the
cement itself, the health risks to cement
workers will rise.
Myth #6
Extensive
studies have found no significant
differences between the air emissions and
kiln dust from conventional cement kilns and
kilns burning waste-derived fuels.
Fact
Numerous
submissions of data to the EPA by the cement
companies themselves show dramatic increases
of heavy metals in cement kiln dust due to
inputs of waste with heavy metals at
permitted feed rates. The levels are far
above any reported by the EPA in its Report
to Congress on Cement Kiln Dust, and should
leave little doubt about the hazards posed
by freely dumping CKD from hazardous waste
burning on the ground and in quarries. See
Table 1.
The EPA was apparently unaware of this data
at the time the Report was being prepared,
and it appears equally clear that cement
companies did nothing to call attention to
this important data, though the Report was
open to public comment for almost a year
before the EPA finalized its decision on
management of CKD.
Myth #7
The limestone
burned to make cement provides a natural
"dry scrubber" inside the kiln to capture
chlorine. The CKRC quotes Barry Dellinger:
The limestone used to make cement
neutralizes hydrochloric acid emissions, an
essentially fail-safe acid scrubber . . .
Dellinger recently wrote,
. . . results
contradict the existing belief that the
alkaline environment of cement kilns
scavenges all available chlorine, thereby
making it unavailable for chlorination
reactions.
Fact
Dellinger recently wrote, . . . results
contradict the existing belief that the
alkaline environment of cement kilns
scavenges all available chlorine, thereby
making it unavailable for chlorination
reactions.
The EPA reports
that cement kilns are the third largest
source of dioxin emissions in the United
States. Dioxin is a product of chlorine
reactions. See charts 5, 6.
Myth #8
Kiln
temperatures cannot change quickly, ensuring
that waste destruction is always complete.
If the raw materials contain high levels of
hydrocarbons, main stack emissions of
hydrocarbons may be dominated by
volatilization/ pyrolysis before the raw
material enters the high temperature regions
of the kiln. The chlorination of these
hydrocarbons are a potential source of
chlorinated hydrocarbon (CHC) emissions.
Scientific
Advisory Board of the Cement Kiln Recycling
Coalition
Fact
For mid-kiln and
cold end waste feeds, there is no assurance
that temperatures are high enough to assure
good combustion of hazardous waste. Add a
low-oxygen atmosphere, and high carbon
monoxide and total hydrocarbon emissions
from raw materials, and it is virtually
impossible to monitor combustion efficiency.
Although destruction and removal efficiency
(DRE) may appear satisfactory, the formation
of chlorinated hydrocarbons after gases
leave the kiln is a well-documented fact
supported by numerous publications. Dioxin
formation in the preheat zone of cement
kilns is a real problem, and explains why
cement kilns that burn hazardous waste are
the third largest emitters of dioxin in the
United States. As the CKRC itself states,
the Ainterim status cement kilns currently
enjoy, to burn hazardous waste, Adoes not
require DRE demonstration.
Myth #9
Cement kiln
emissions controls are highly efficient at
removing metals--indicating that their air
emissions controls are on a par with those
of commercial hazardous waste incinerators.
Fact
If this is so,
why does the commercial hazardous waste
incinerator industry endorse the new
air emissions controls proposed by the EPA
to implement the Clean Air Act, and the CKRC
oppose them? See Chart 7.
Myth #10
Cement plants
have an excellent worker health record.
Congress has prohibited enforcement by MSHA
of [safety and health training] since
October 1, 1979."
MSHA
Bulletin, A Guide To Miners' Rights and
Responsibilities Under the Federal Mine
Safety and Health Act of 1977," Revised
1994.
Facts
Cement worker
health and safety is governed by the Mine
Safety and Health Administration--not the
Occupational Health and Safety
Administration. MSHA standards are not
protective of the cement worker when
handling hazardous waste at the cement kiln.
This is because MSHA is hamstrung by
Congressionally-mandated prohibitions that
bar the enforcement of hazards communication
requirements.
-
Commercial hazardous waste incinerator
facilities must comply with all
hazardous communications and operator
requirements contained in Section
1910.120 of the OSHA rules.
-
Commercial hazardous waste incinerators
are required to perform comprehensive
medical monitoring on each incinerator
worker on an annual basis.
-
Commercial incinerators must provide 40
hours of hazardous operator training to
all facility employees and site
contractors.
Cement
kilns do not need to comply with OSHA
1910.120, or conduct annual medical
monitoring, or provide 40 hour hazardous
operator training.
Myth #11
Risk assessments
have been performed recently which indicate
that the public's risk from cement kiln
emissions is very low [and] no different
from the risks from conventional fuel
emissions.
Fact
Cement kilns
burning hazardous wastes are currently
attempting to avoid performing detailed
health risk assessments to determine the
risks posed to human health and the
environment from smoke stack emissions and
cement kiln dust disposal practices.
Proposed rulemaking under EPA's Combustion
Strategy will require that inhalation and
food consumption pathway analyses be
performed by all hazardous waste combustion
facilities as part of the RCRA permitting
process. However, the CKRC still searches
for Congressional support to exempt them
from risk assessments.
In a brazen display of the power of these
special interest groups, the House added 18
separate loopholes, giveaways, and
stop-in-your-tracks orders, stripping away
very specific safeguards to benefit very
specific interest groups . . . Another
(provision) permits cement kilns and other
incinerators to burn cancer-causing
chemicals without effective control.
President
Bill Clinton
August
8, 1995
- The
practice of blending solids containing
high concentrations of heavy metals like
lead, chromium and arsenic has
dramatically increased according to E.I.
Digest. Adoption of the Boiler and
Industrial Furnace (BIF) Rules in 1991
has allowed cement kilns to burn a wide
variety of chlorinated and heavy metal
contaminated wastes. See Chart 8.
- EPA has
recently determined that up to 2000
additional infant mercury poisonings are
expected to occur annually if
cement kiln mercury emissions are not
checked.
Myth
#12
Cement
manufacturers call for stricter
environmental and health standards for all
hazardous waste-burning facilities,
standards stricter than those recommended in
EPA's draft combustion strategy. These
standards would:
- Update
older commercial hazardous waste
incinerator permits;
- Reduce
metals emission limits;
- Reduce
the potential toxicity of dioxin/furan
emissions.
Fact
Cement companies
fought for years against adoption of the BIF
Rules which now regulate them, delaying
their implementation, and achieving loose
standards for heavy metals emissions such as
lead, cadmium, and arsenic and for hazardous
waste combustion efficiency measured by
carbon monoxide and hydrocarbon emissions.
Fact
Cement companies
obtained an exemption from rules requiring
that ash residues from incineration be
placed in high technology landfills and
their ash, CKD, which may be full of heavy
metals and dioxin, currently may be dumped
freely on the ground. It is often placed in
limestone quarries which may be in or above
groundwater aquifers.
Fact
According to
[Office of Solid Waste Officials], because
dioxins and furans were found in dust from
cement kilns burning hazardous waste, EPA is
considering revising its regulations for
boilers and industrial furnaces to control
their emissions.
GAO Report on
Interim Actions to Better Control Cement
Kiln Dust
August
1995
Despite the fact
that there are 3 Superfund sites and 13
other locations subject to government
clean-up orders from CKD contamination, the
CKRC has vigorously protested the EPA's
determination that CKD should be subject to
hazardous waste regulation. The CKRC takes
the position that no regulation of CKD of
any kind whatsoever is justified, and they
have petitioned the EPA for an AEnforceable
Agreement. The agreement would reverse the
EPA determination, allow current unregulated
practices to continue for a minimum of 5
additional years, then impose minimal
standards, and reduce all penalties for
non-compliance by 95% or more.
Fact
The CKRC took
the EPA to court shortly after announcement
of the Combustion Strategy in 1993 to
prevent its implementation, and more
recently sought provisions in the Regulatory
Reform bill to delay its effect. When these
efforts were unsuccessful, the CKRC
sponsored riders to the EPA Appropriations
bill (adopted by the House on July 31, 1995)
to stop the EPA from enforcing strict
emissions standards under the Clean Air Act.
The CKRC has petitioned the EPA for metals
emissions limits and dioxin/furan emission
limits substantially above what the
EPA has determined is technologically
feasible.
Fact
While it is
noble for the CKRC to seek updating of
commercial hazardous waste incinerator
permits (which require renewal every 5 or 10
years by their own terms), the CKRC might
better tend to its own back yard: not a
single cement kiln has a permit despite
years of burning hazardous waste, no
formal public involvement in the permitting
process has yet been initiated, no
formal trial burns have been concluded, and
cement companies have been in a stalling
mode dragging out the process while they
operate under Ainterim (e.g. non-permit)
operating status, fighting the Combustion
Strategy at every turn.
Myth #13
The CKRC
endorses the EPA's Combustion Strategy: Ato
develop and impose implementable and
rigorous state-of-the-art safety controls on
hazardous waste combustion facilities by
using the best available technologies and
the most current science. (CKRC quoting EPA
goals statement for new combustion strategy,
May 18, 1993)
Fact
The CKRC filed a
lawsuit shortly after the EPA announced the
Combustion Strategy to prevent the EPA from
implementing it. More recently, the CKRC
sought provisions in the Regulatory Reform
Bill that would have delayed the Combustion
Strategy and when these efforts were
unsuccessful, the CKRC only weeks ago
drafted riders for the EPA Appropriations
bill to stop the Combustion Strategy, which
were adopted by the House on July 31, 1995.
Introduction
The week of
August 28, 1995 the Cement Kiln Recycling
Coalition gave wide circulation to a
pamphlet entitled Protecting Human
Health & the Environment which purports
to describe why burning hazardous waste in
cement kilns is a good idea. Defending a
wide-spread practice that has expanded in
the last several years involving the
indiscriminant addition of all kinds of
hazardous waste into cement kilns while
cement is being made, the document glosses
over important environmental questions
concerning the practice of burning hazardous
waste in cement kilns. The pamphlet mostly
over-simplifies or misstates crucial facts
about disposal of hazardous waste in cement
kilns, and discusses to the point of
misrepresentation the real policy positions
of the cement industry--to undercut our
nation's hazardous waste laws. In some cases
the document makes claims that are
contravened by the Cement Kiln Recycling
Coalition's own Scientific Advisory Board.
The following commentary is designed to shed
light on these distortions by quoting from
the document itself and providing responsive
information that we hope will allow for a
fuller understanding of the basic issues
presented when hazardous waste is burned in
cement kilns.
Return to the National Citizens Cement Kiln
Coalition Home Page
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