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LAFARGE RAVENA
NY
ARTICLES
LaFARGE CEMENT
while not in compliance
to current regulations,
has applied to DEC to burn
tires as fuel
AUGUST 25. 2005
LAFARGE PUBLIC HEARING - August 24th There were 21 speakers at last night's public hearing on Lafarge's proposal for tire burning at its Ravena cement plant . One person spoke in favor of the project; 20 were opposed. All the speakers were interesting and informative and articulate. There will be another public hearing on this matter on Wednesday, Sept. 21 at 7 Pm at the Ravena-Coeyman's-Selkirk H.S. Here for the moment is Friends of Hudson's statement. Please feel free to forward this message and also check out www.friendsofhudson.org for more information on this proposal. SUSAN FALZONE SPEAKS AT LAFARGE HEARING Thank you for providing this opportunity for the public to comment, for extending the comment period and providing a second public hearing. My name is Susan Falzon. I am the Deputy Director of Friends of Hudson a 4,100-member citizen organization. Our attorney will be submitting more detailed comments during this comment period. Friends of Hudson has been examining this proposal since the first submission of the application back in December 2003. We had major concerns at that time and I am sorry to say tonight that those concerns remain. In fact, after a year and a half of research, and an in-depth examination of the current application and draft permit, our concerns have grown rather than diminished. Our primary concerns have been and remain: 1. The difficulties and complexities of burning whole tires in cement kilns 2. The potential increased emissions of deadly toxins, including the highly carcinogenic dioxins and furans that typically result from tire burning 3. Lafarge’s track record of air permit exceedences over the last 4 years 4. Lafarge’s inability to operate this plant safely and effectively at its current configuration given that track record 5. Lafarge’s inability therefore to effectively handle the increased complexity that would be introduced if tire burning were to be permitted In July when the draft permit and application were released Friends of Hudson retained two engineering firms to do a comprehensive review of it and relevant scientific and technical literature. Camp Dresser McKee is a global engineering firm whose clients, except for Friends of Hudson are major corporations and governmental agencies. It is Friends of Hudson’s policy to undertake such reviews, leaving no stone unturned, before we take a position on any proposed development or action. We instructed CDM to conduct a careful review so that we could have the highest degree of confidence in their findings before we took a position on Lafarge’s proposal. Whole vs. shredded tires To project their expected emissions Lafarge has used data from other tire burning facilities. However there is little supporting data for what Lafarge is projecting. Since the data Lafarge submitted were essentially from facilities burning true tire derived fuel—that is shredded or chipped tires – there is little to compare with a facility such as Lafarge’s. In their research our engineers found one stack test for a facility in Colton CA that is burning whole tires. That stack test showed an increase in dioxin/furan emissions. Yet the Lafarge application claims there would be no increase in these deadly toxins at Ravena. We would like to know why, when the one comparable facility in the literature belies Lafarge’s claim. It is also striking that although Lafarge operates numerous plants in the US and claims to burn tires at several, it has not submitted any stack test data from those plants? We think DEC should be requesting that information – we are. CO EMISSIONS The draft permit places a limit on increased CO emissions at 99.5 mty, The public might be interested to know that the 99.5 mty cap has clearly been chosen to avoid the costly, and much more thorough NSR that would be required if CO emissions were projected at 100mty or more. Other facilities that burn whole tires have reported no increase in CO emissions, for example, the Ashgrove facility in Midlothian TX, which burns 22% whole tires compared to Lafarge’s requested 20%. In fact it is interesting to note that the 20% limit was arrived at after it was recognized that the 40% requested on Lafarge’s original application would in fact have triggered NSR. What did Lafarge then do? They reduced the limit to 20% rather than examine howthey could further reduce CO emissions using better technology , better operating procedures or reduced number of tires. CO increases are an indication of incomplete combustion that can be tied to an increase in Hazardous Air Pollutants. If the DEC permit allows this increase in CO emissions then Lafarge will have been given a permit to be sloppier in their operation, rather than being held accountable for more effective procedures to prevent more incomplete combustion. Zinc The application and draft permit project an increase in zinc, which is a catalyst in the formation of increased levels of dioxins and furans. Whole tires may have higher levels of condensable Particulate Matter which when combined with zinc can lead to the formation of increased levels of TCDD/TCDF on the particles. This can lead to higher levels of 2378 TCDD, an extremely carcinogenic compound. Incomplete combustion – permitted by the increase in CO – will lead to increased presence of zinc that will be the catalyst for increased dioxins and furans What it comes down to then, is that there are areas of inconsistency and areas of concern in this draft permit. Before consideration of this permit application the DEC should require Lafarge to show how it arrived at projected emissions levels and to demonstrate why increased CO emissions and burning whole rather than shredded tires are not problems. When this process began we heard that Lafarge is not St. Lawrence Cement, the company whose proposed Greenport project was defeated by opposition of a partnership of FoH and several other organizations. Sadly we have found that Lafarge has more in common with SLC than cement. As with SLC we have discovered it is as important to doubt any and all claims until they can be proven, or more likely disproven by research. Last November at the public meeting at RCS H.S. I directly sked Lafarge representatives about the potential of increased dioxins and furans. I was incredulous when they replied that there would be none. How could you say that I asked. I was told “Because we know what is in tires so we know what comes out.” Clearly a lie- as their application now before us shows. Why would they make such a statement in the heart of the community which they are asking to trust them? So now lastly we come to one of the more troubling aspects of this permitting process—the issue of Lafarge’s track record. When I speak of track record I am speaking both of Lafarge’s inability to safely and effectively operate its Ravena plant over the past 4+ years, and the way that Lafarge has repeatedly mis-led the public about that track record. In April of this year Friends of Hudson obtained via FOIL the Title V Air Permit Compliance Summary reports that Lafarge is required to submit to DEC twice a year. In these reports they must detail any deviances that occurred with respect to the conditions required in their existing Title V permit—the permit they are now applying to modify in order to burn tires. We found an increasing number of deviations and no DEC enforcement actions. In particular we noted that there were a steadily increasing number of opacity exceedences. As Lafarge has told us, “Opacity monitoring serves as a surrogate for PM emissions that, in turn, serve as a surrogate for metal HAP (Hazardous Air Pollutants) emissions.” (Application for Mid Kiln Firing of Rubber Including Tire Derived Fuel, LaFarge Building Materials, Inc. Ravena NY, January 2005, page 17) These opacity exceedences concerned us because they are reportedly caused by equipment malfunctions, the cause might be equipment related—equipment wearing out, poor or inadequate maintenance or inadequate operating procedures. In those Compliance Summary reports we also found increasing incidences of both equipment malfunction and human errors. When we discovered these reports we issued a press release and called upon DEC to meet with us to discuss these disturbing trends. It was our intention to ensure that these problems were adequately addressed before Lafarge would be permitted to add the complexity of burning whole tires—which as our research has shown are more likely to cause kiln upsets and are typically expected to cause an increase in condensable PM, higher levels of phenols in a chlorinated atmosphere and ultimately therefore higher levels of dioxin and furan. Lafarge has repeatedly denied these problems implying that we didn’t know what we were talking about. As recently as the information session held in this building on August 4, and in follow-up newspaper interviews, Lafarge implied that their exceedences were well below a level of concern. They argued that “yes, perhaps they had exceeded conditions for a few seconds or even a few minutes at minutes levels such as .1%” for example. Well I am telling you here tonight that that is not the truth. Friends of Hudson did not make up our concerns out of thin air. When told by DEC that there was information we were lacking, we requested that information via FOIL. It took weeks to receive. We finally received it last week. Our experts have reviewed that material and it shows a substantial and significant amount of noncompliance. For example, during the first 5 months of 2005, the record shows 20 instances of opacity over 20% for longer than 30 minutes including an average opacity reading of 24.38% for 2 hours and 24 minutes on Feb 16, 2005; average opacity reading of 23.67% for an hour and 12 minutes on March 5, 2005; and an average opacity reading of 31.5% for an hour and 6 minutes on April 5, 2005. Remember opacity is limited to 20% by permit. A reading of 31.5% is more than 50% over the limit—not a miniscule amount—and not for just a brief moment. Our questions are – Why these exceedences? What has been done to prevent their reoccurrence? And why have no enforcement actions resulted? We are now in the position of having to consider filing a Clean Air Act citizen lawsuit in this matter. Lafarge is not the good neighbor it would like the residents of the area to believe. This is not the way to build a foundation for a relationship of trust in the host community or in the region. Perhaps it is time for the public to better scrutinize it—and challenge more of the claims it has made over the years and at this time. Friends of Hudson is continuing our review. We will do everything we can to ensure the highest standards of public health and safety. At the very least Lafarge needs to provide more data regarding whole tires at similar application rates. And there has to be an explanation and a plan to remedy the past operating deficiencies--the violations. As I said at the beginning of my statement our attorney will be submitting more detailed comments before the close of the comment period. During the remainder of this comment period we will continue to diligently review and research the issues raised by our analysis of this application and draft permit and will provide both the public and this agency with the results of our findings. Thank you. For more information, including directions to the hearing, please contact Susan Falzon at (518) 822-0334 More info on the Lafarge issue can be found at: http://www.friendsofhudson.org/lafarge Friends of Hudson News Release April 5,
2005
LAFARGE CEMENT HAS NOT DISAPPEAREDThe Lafarge cement plant, located only 9 miles from
Kinderhook across the river is still producing pollutants that could be
dangerous to our health. Our friends at
Friends of Hudson have been keeping tabs in the
situation. Below is a copy of their latest news release. This is very serious. Please take a
look:
FRIENDS OF HUDSON a project of
The Open Space Institute FOR IMMEDIATE RELEASE: Wednesday
5 April 2005
CONTACT: Susan Falzon, Deputy Director (518)
822-0334 Total reported problems jumped nearly 12 times from the
first six-month reporting period after Lafarge took over the plant, when there
were 11 deviations from permit conditions, to the last six months of 2004
when there were 129. please call Deputy Director Susan Falzon at (518)
822-0334 Bold print
added by KNGG for emphasis.
MARCH 12, 2004 - Meeting
on Ravena NY TIRE BURNING PLAN draws crowd |
