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Cement kilns are a growing concern of many environmental organizations not only in volume but type of emissions.  The cement manufacturing process is an energy intensive chemical manufacturing process that uses large industrial kilns with counter current flow to convert ground limestone and shale or clay into portland cement.

Very large quantities of fuel are required to produce these temperatures and the associated chemical reactions which occur, this process lends itself to the utilization of non-traditional fuels including refuse derived fuel, tires, auto battery casings, wood chips, rice hulls, tear off roofing tiles, diaper ends, and hazardous waste (HWF).  Throughout the country there are approximately 100 cement kilns of which approximately half utilize some type of hazardous waste as a fuel source. 

The cement industry claims that the high temperatures and oxidizing conditions necessary for cement production are ideal in the destruction of the organics in HWF, far better than commercial incinerators.  However, cement kilns have not been required to utilize similar pollution control equipment or dispose of cement kiln dust similar to that of a hazardous waste incinerator.  In response cement kilns perform the same function as a hazardous waste incinerator without abiding by the same standards.

In North Texas the emissions of the three cement kilns total that of 2.2 million pounds of toxic emissions and 41,000 tons of criteria pollutants annually.  Of the three plants located in a suburb of Dallas and Fort Worth, one burns hazardous waste and tires, one burns tires and tear off roofing tiles, and one burns only tires.  In Hudson, NY St. Lawrence Cement has requested a permit to emit up to 10,000 tons of criteria pollutants and refuses to deed restrict its property to alleviate concerns over the future burning of hazardous waste in the kiln.  Outside of St. Louis, MO a Holcim Cement plant (formerly Holnam) has proposed a plant that, if permitted will emit more than 27,000 tons of criteria pollutants annually.  Throughout the country grassroots organizations are participating in similar fights.

According to EPA’s toxic release inventory burning hazardous waste and tires in cement kilns produces a number of toxic air emissions such as mercury, sulfuric acid, lead, barium, manganese, chromium, toluene, 1,3-butadiene, styrene, and dioxin (to name a few).  These chemicals have been linked to cancer, retardation and brain damage, endocrine-disorders, anemia, endometriosis, depressed immune system, asthma, and diabetes.

The Coalition believes that citizens should be informed of the volume and type of emissions generated from these facilities as well as the associated health impacts. 

The Burning of Hazardous Waste

It is a fact that hazardous waste always flows downhill to the least regulated solution, and the least regulated solution is typically the cheapest and causes the most environmental problems.

In the U.S., cement and aggregate kiln incinerators are the least regulated and cheapest type of thermal treatment for combustible wastes.

A simplified historical context of cement kiln incineration in the U.S. is this: In 1984, Congress and the USEPA amended the Resource Conservation and Recovery Act (RCRA) to address the fact that most hazardous waste landfills were leaking. This action was meant to ban certain toxic industrial wastes from land disposal.

In order to meet time constraints and requirements of Congress in removing these hazardous wastes from ground storage, and being unable to permit hazardous waste incinerators fast enough to meet the disposal demands of the growing waste pyramid, EPA simply made the decision that they would instead allow cement and aggregate kilns to use loopholes in the law to burn hazardous wastes.

In the U.S., many cement companies have been burning hazardous waste for over a decade, but until late in 1991, the residents of the host communities were unaware that their friendly old cement plant was engaged in this questionable practice. This is because cement kilns were allowed to start up burning while circumventing the public participation requirements mandated for commercial hazardous waste incinerators.

There are approximately 23 waste-burning cement plants in the U.S. These facilities trivialized waste-burning to the citizens by using benign terms like "recycling", or"co-processing", and calling the waste "supplemental fuel", all the while receiving and burning the very same toxic waste that goes to state-of-the-art commercial incinerators.

Also, many cement companies in the U.S. are burning or seeking permits to burn tires in their kilns.

This has not set well with the American people and thus, the cement kiln factor in the overall combustion equation has become a troublesome and controversial one for local, state, and federal regulators.

The problem with burning hazardous waste in cement kilns is plain and simple: Thermal treatment of toxic and hazardous waste is a dangerous activity, and it needs to be done at the apex of available technology 100% of the time. You cannot do that in a facility that is not designed and operated for the sole purpose of burning these substances. In fact, many brand new, tightly controlled commercial incinerators can have dismal performance records.

The history of violations, non-compliance, and environmental harm caused by cement kiln incinerators across the country clearly reveal the difficulties and dangers of disposing of waste in a unit that is not designed for the job.

In 1991, under a court order, the EPA promulgated regulations that were to bring waste-burning cement and aggregate kilns into compliance and parity with the same regulations that govern other combustion devices. After the first round of inspections a year later, not one cement facility successfully demonstrated compliance with the new rules.

To date, only one cement plant burner, Ash Grove Cement in Chanute, Kansas, has received a full part B RCRA permit. That permit has been vigorously challenged to the EPA Environmental Appeals Board by Chanute citizens, along with various industry and environmental groups.

Cement kiln technology is rigid and has remained virtually unchanged since the turn of the century. A cement kiln can only be modified, refitted, or retro-fitted to a minimal degree to improve toxic waste destruction and removal efficiency, and still produce a quality cement. This is in contrast to a unit that has the sole purpose of burning hazardous waste. Single purpose units don't have to "juggle" technology between the incompatible purposes of cement production and safe, protective waste destruction.

In a unit with a singular purpose, there is a least the chance of upgrading the technology to eventually "close the loop" i.e., toxic waste goes in...nothing toxic comes out.

There are "alternate" thermal treatments that can do that today, but as long as cement and aggregate kilns are allowed to take the waste without expensive controls and "on the cheap", then the commodity (hazardous waste) and the disposal revenues are denied the entrepreneurs. Thus, incineration technology will not go forward.

As long as cement kilns, or other antiquated or inadequate disposal practices are allowed to be part of the combustion equation, the future of safe and protective thermal treatment of waste remains uncertain.

The trend we are facing is this: The cement kiln incineration lobby has been very successful at perpetuating myths about their incineration practices and is getting more powerful day by day. They spend the windfall waste-burning revenues well, and have garnered much weight and influence in Congress and EPA over the last decade. Even more interesting, Hillary Rodham Clinton sat on Lafarge's board of directors until 1992 when a pre-election news piece ran on CNN World News Tonight. She resigned her board seat without comment.

Most of these companies are foreign-owned and belong to a cartel that has been implicated in anti-trust and monopoly entanglements overseas. The cartel was revealed stateside in 1992 when an investigative report appeared in "The Nation" magazine, entitled, "The Sultans of Cement"..

Incinerator companies are going bankrupt one by one. If cement and aggregate kiln incineration is not dealt with specifically and soon, then they, (cement kilns), will become the only incineration game in town, and will be, for all practical purposes, untouchable.

When and if that happens, America...the greatest technological power in the world will be stuck with sub-standard "third world" technology to do the dangerous business of thermal treatment of toxic waste.

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