Hazardous Waste Incineration and Southwestern Portland Cement

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03290
Hazardous W&te Incineration
and
Southwestern Portland Cement Company
an overview
assembled by Michael Jones
for the Greene Environmental Coalition
December 10.1992
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Introduction
This pamphlet has been assembled for the purpose of acquainting
the lay person with a number of the quesitons surrounding the
incineration of hazardous waste in cement kilns in general and
Southwestern Portland Cement Co. in Fairbom, Ohio in particular.
After reading these materials, one should have a preliminary
understanding of the processes, technology and attendant questions.
The parnplet has been organized into the following five sections:
I
“Cement Kilns as Toxic Waste Incinerators,”
by Michael Jones
This provides an overview of salient processes and
questions in quick question and answer form.
II
“Sham Recyclers, Part I - Hazardous Waste Incineration in
Cement and Aggregate Kilns”
A Greenpeace Report by Pat Costner and Joe Thornton
This offers more in depth treatment of the questions.
III
“Incineration Technology: Cement Kilns Inherently Unsafe,”
by Cherie Trine
This offers a more detailed discussion of how cement
kilns work. It compares them to Hazardous Waste
Incinerators and discusses their relative effectiveness and
safety.
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“Commercial RCRA Hazardous Waste Incinerators and Boilers
and Industrial Furnaces”
By US EPA
This shows location of different facilities and how national
distribution.
V
Letter from Sowash,Carson& Shostak to Greene Invironmental
Coalition
This lays out the legal basis for the lawsuit by GEC, Ohio
Environmental Council and the Village of Yellow Springs
requiring that southwestern Portland Cement be licensed
as a Hazardous Waste Facility.
I
“Cement Kilns as Toxic Waste Incinerators,”
by Michael Jones
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CEMENT KILNS AS TOXIC WASTE I@KXNE~TORS
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Prepared by
Michael Jones
Yellow springs, Ohio
(5 13) 767- 1387
April 13,1992
updated: Dee 1, 1992
Abstract:
There is a growing national trend to dispose of toxic wastes in
cement kilns rather than in Hazardous Waste Incinerators. This is
because the cement kiln venue is cheaper and less tightly regulated.
There is substantial evidence that cement kilns do not work for this
purpose. They discharge dangerous compounds into the air, and
produce contaminated O‘oxIC) cement which is then used to make
such things as concrete water mains.
The Southwestern Portland Cement Kiln in Fairbom, Ohio is
currently applying to expand its program to fuel its Linebaugh Road
Plant with hazardous waste fuels. The Linebaugh Road Plant is one of
the most modern cement kilns in the industry and yet has failed air
emissions tests when burning hazardous waste fuels. This raises .
questions about the efEcacy of the practice as a whole.
BACKGROUND
With the increasing levels of hazardous waste being produced by
industry in this country, government and industry leaders are
continually looking for new modes of disposal and recycling. In
recent years, Third World countries has been balking at the prospect
of becoming dump sites for the world’s industrialized nations. One
disposal venue is to use state of the art technology to design the most
advanced disposal facilities possible in the form of Hazardous Waste
Incinerators (HWI) .
Btit, in this country, the public has reacted increasingly unfavorably
to HWIs. It is now extremely difficult for a new HWI to get siting
approval.
Over the past two decades, a cheap and hypothetically problem-free
channel for hazardous waste disposal has emerged in the United
States and Canada. It involves the use of hazardous wastes as fuel in
cement kilns. Without the label of the HWI these cement kilns did
not at first arouse the same levels of public concern as HWIs. The
practice of using their kilns for this purpose is gaining widespread
popularity within the cement producing industry. At least 24
cement producers in the US are burning ever-increasing amounts of
toxics in their kilns.
While the industry pursues this practice in ever-increasing
dimensions, certain members of the scientific community argue that
the practice is questionable and that it may present a host of future
environmental problems. As they and environmental watch groups
make a negative case for this use of cement kilns, members of the
public invarious communities are rallying to have the practice more
rigorously scrutinized and/or stopped.
One such confrontation is currently taking place in and around
Fairbom, Ohio where the Southwestern Portland Cement Company
(SWPCCO), owned by Southdown Corporation, is making plans to
replace up to 505% of its coal fuel with hazardous waste. The
majority of this will eventually be in the form of solid hazardous
waste. Ordinary citizens have banded together to express their
concern and opposition to SWPCCO’s bid to use hazardous waste as
fuel. The municipal governments of Fairbom and Yellow Springs
have passed resolutions opposing SWPCCO’s plans. They, along with a
local concrete water main manufacturer, have taken steps not to use
SWPCCO cement for public projects.
Southdown, based in Houston, Texas is the parent corporation of
SWPCCO. In addition to some eight cement kilns it owns across the
country, Southdown has methodically been acquiring a wide range of
companies engaged in various aspects of hazardous waste
management, disposal, transport, and storage. As stated in its 1991
Annual Report, Southdown is now a corporation vertically organized
primariIy for the management transport, and disposal of hazardous
waste from producer to final cement kiln disposal. There is every
indication that the program being implemented in Fairbom. Ohio at
the SWPCCO Linebaugh Road plant to use hazardous waste as fuel is a
pilot program that Southdown will implement nationally.
The attractions of cement kiln incineration program include:
1.
Since a cement kiln operates at very high temperatures
(app 3,000 deg. F. at the hot end), it has occurred to some
that it might be possible to use a cement kiln for the
purposes of hazardous waste incineration thereby reducing
or eliminating the need for very expensive stand-alone
hazardous waste incinerators. This, then, could be viewed
as a potential public service.
2.
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Given the public unpopularity of hazardous waste
incinerators, it has become very difficult for hazardous
waste disposal companies to obtain permission to site and
build new facilities. Thus, cement kilns, if permitted,
offer an attractive alternative course of action for such
companies.
3.
Since the hazardous waste to be burned is a source of
energy in itself, a company engaged in the manufacture of
cement can save substantial sums by replacing traditional
fuels (coal, natural gas, etc) with hazardous waste “fuels”.
Because of this, they are in a position to charge less for waste
disposal than Hazardous Waste Incinerators.
4.
Cement kilns offer several attractions to producers of toxic
waste:
First, disposal by means of cement kiln treatment is
not as expensive as when done in a hazardous waste
incinerator (HWIJ.
Second, any waste a hazardous waste producer
sends to a Hazardous Waste Incinerator (HWI) must be
reported on the lproducerk Toxic Release Inventory (TRl) to
the US EPA This information is then used to draw an
accurate picture of the status of waste production nationally.
But, owing to a loophole in regulations, any hazardous waste
channeled via the cement kiln disposal route is not required
to be listed on the waste producer’s TRL By using this venue,
a producer can give the impression of “reducing’ waste
production, but really the materials are just being lost”.
Further, for a variety of reasons, no liabiliQ can be
traced in emissions Tom cement kiln treatment.
5.
For a company engaged primarily in the management and
disposal of hazardous waste materials, the option of
cement kilns is particularly attractive because these
facilities are not as tightly monitored o etiated as are
facilities which are designed with staterorf the art
technology to be proper hazardous waste incinerators.
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There is a general trend nationally to route as many toxic compounds
as possible through the cement kiln incineration venue as possible.
Some estimates have this figure as high as 90% of toxics going
through cement kilns rather than the more tightly regulated Hazard
Waste Incinerator route.
THE PROBLEM(S)
The following is a listing of a number of problems which have
emerged regarding SWPCCO’s application to expand its hazardous
waste fueling program. Some of these issues pertain to the SWPCCO
Linebaugh Road plant, and the particulars of that site, but the
majority of these issues pertain to the general practice of using
cement kilns as hazardous waste disposal sites.
1.. .
Can complete burning of hazardous waste materials be
accomplished in a cement kiln?
In order to completely burn and thereby eliminate organic
hazardous waste compounds, one must subject them to
high temperature in the presence of oxygen. When this is
done, they are theoretically broken down completely and
eliminated as a problem. However, even in incinerators
designed and built for the sole purpose of burning these
materials, it is still d.iBlcult to maintain thorough
mixing of these materials with the air needed to burn
them. During operation, burners and blowers do at
times gum up with various residues which alter air flow
patterns and compromise the effectiveness of operations.
A cement kiln is not designed with the same air-iixl
mixing criteria. In a state of the art Hazardous Waste
Incinerator (I-IWI) air and heat are applied to burn the
toxic materials: residues are collected, and then exiting
gasses are passed through a second combustion chamber
where they are reheated in the presence of additional air
in order to give a second assurance of complete combustion.
In a cement kiln, air and heat are introduced only once (at the
hot end of the kiln).
When adequate air is not mixed with hazardous waste
fuels, these compounds, many of which are highly volatile,
can pass up the stack and into the atmosphere. Even
worse, when incomplete combustion occurs the kiln
actually becomes a high-temperature organic compound
“cooker” in which new (and potentially even deadlier)
compounds are formed. Thus, while such nasty compounds as
benzene and toluene may be introduced as fuel, such
compounds as fixrans and dioxins are created in the kiln and
released.
It is my understanding that an abundance of oxygen is
undesirable in the making of Portland cement. Perhaps it
is for just this reason that SWPCCO proposes a single
burning chamber with 4% oxygen in contrast to an HXVI’s
double burning chambers and into each of which an 8%
oxygen sur(:us is introduced. The HWI is obviously more
expensive to build and to operate. But fimdamentally, the
question emerges whether one can simultaneously burn toxic
waste (requiring an abundance of oxygen) and make proper
Portland cement (where an abundance of oxygen is not
desirable).
Furthermore, while liquid hazardous waste is injected
into the kiln through a nozzle at the hot end of the kiln,
solid hazardous waste is introduced at the cold end of
the kiln (where the atmosphere is the the coolest and most
oxygen- depleted) and allowed to tumble and burn as best it
can. One would expect large quantities of these materials to
simply vaporize and pass into the atmosphere, or be “cooked”‘
into new compounds and then released.
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It should be noted that thermal destruction refers only to
potentially “burnable” compounds. Heavy metals can not be
destroyed by incineration
It seems highly questionable whether the rigours of doing
two things at once (making cement and burning toxic
waste) are conducive to the proper disposal of this waste
in order to protect the public’s health.
2.
The amount of toxics to be burned is so huge it likely
overwhelms a cement kih~% ability to totally bum them.
SWPCCO has recently disclosed plans to increase its
hazardous waste fueling to replace 50?41 of its coal fuel.
They state this will be about 160 million pounds/year,
(that works out to
500,000 pounds/day; or
22,000 pounds/hr. or
3,666 pounds/minute. or
600 pounds/second)
At these quantities, even if the kiln’s destruction rate is
99?! perfect, there are still large numbers of toxics which will
escape.
And given the tiown fluctuations in cement kiln
atmospheres, and periods when these f&ilities are not
able to induce complete combustion, substantial amounts
of toxics will be cooked in the kiln and released up the
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Stack.
3.
The program adds to the waste stream.
We are all realizing that the only real answer to the
problems of pollution and waste disposal lies in measures
taken to reduce the waste stream. The use of toxic waste
as fuel does nothing to bring pressure to bear on various
manufacturers to reduce the hazardous waste they are
producing. It simply gives them a new, cheap, and
authorized disposal venue.
In its initial operations, SWPCCO as well as others in the
industry have found that, while many of the materials are
classified as “liquid hazardous waste,” they are often liquids
too viscous for the maintenance of efficient operations. In
such cases, solvents are introduced into the mix to make
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it more fluid. These solvents are currently being
reclaimed by recyclers for industrial reuse. By making
them part of the gross fuel mix and burning them, SWPCCO is
actually adding to the waste stream.
In addition, past burns have included motor oil that could
be redistilled and reused. Distillation, however costs more
than cheap incineration at a cement kiln. Inclusion of
motor oils in the fuel mix thus adds to our oil denendencv.
FlnalIy, not a.lI toxic wastes burn easily. Cement kiln
operators handle those compounds which have high BTU
(energy) content since these can also serve a fueling function.
The remaining hard to burn toxics are left for the HWI route.
When these materials reach HWIs, these facilities must use
additional fuel (such as natural gas) which they would not
have to if they received the total mix of hazardous
materials targed for incineration. Thus, overall, there is a
net increase in the nroduction of greenhouse k%3SSeS.
4.
There is less pressure on industry to reduce and recycle
waste with the presence of the cement kiln disposal
Veaue.
Since the environmental movement began, it has been
made abundantly cIear that business and industry develop
newer and cleaner modes of production and recycling only
when they are forced. The pressure comes from tight
regulations which are enforced. This eventualry develops
cost incentives to reduce and recycle wastes. The
presence of the cement kiln disposal venue by being a
“cheap out” effectively eliminates this pressure.
5.
What happens to &l of the compounds introduced?
Many of the organic compounds are highly volatile.
There are various heavy metals (cadmium and arsenic in
particular) which are also very volatile. It is hard to
imagine that at least some of these materials are not
becoming gaseous and passing through the kiln, out
the stack and into the atmosphere whereupon they are
breathed by residents nearby or enter the food chain.
SWPCCO takes the cement industry stance maintaining that all
remaining toxic substances are being “entrained” in the
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cement clinker which is later ground up and mixed with
gypsum to become Portland cement. However, the little
monitoring that has been done of stack emissions gives strong
indication that not alI toxics are being captured in the cement
clinker.
6.
Should the cemen produced be considered “toxic waste”?
Cement producers maintain that all or at least most of the
remaining toxic materials become part of the cement that
the company makes.
This cement is then used to build streets, sidewalks,
buildings, and even concrete water mains which supply
public drinking water.
But cement does not last forever. Eventually sidewalks
crumble and become dust. And the inner surfaces of water
mains erode. How then are we to look at this material.
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Won’t a sidewalk that crumbles in 50 years made of this
cement be considered toxic waste? Will not a decaying
concrete water main eventually contaminate drinking
water (with the likes of arsenic, or cadmium). Shouldn’t
the bag of Portland cement itself be considered toxic
waste today? After all, incineration conce.nIrates the
residue and toxici@ is directly related to concenlralion.
7.
Since Greene County and the Miami Valley in SW Ohio
already do not meet EPA air quality standards, why is this
program of Hazardous Waste Disposal even w
entertained for this area?
8.
Given their substantial potential for further environmental
pollution, why is the cement kiln venue for the disposal of
toxic waste even being considered for any part of Ohio, given
its existing health and environmental problems?
Ohio ranks third in the nation with regard to
environmental pollution. It also has one of the highest
cancer rates in the country.
9.
Why are cement kilns being used to dispose of hazardous
waste when there is already plenty of disposal capacie in
existing Hazardous Waste Incinerators both in Ohio and
MtiOIdlJf?
Simple, it is a cheaper and less tightly regulated venue for
hazardous waste producers.
10.
Does SWPCCO plan to commision independent long term
epidemiological studies in the area to monitor the saxfee of
its operations?
SWPCCO plans to store and to burn toxic waste
materials in mixes containing as many as 300 d.ifTerent
organic compounds and heavy metals. All of these are
listed as hazardous materials because of their deleterious
effects on the environment and on public health. Little is
known about the synergetic effects of these in combination
with one another once they enter the body or the
ecosystem. It seems that if operations are permitted to
continue as planned, then at least the company should
retain an independent outside institution such as one of
the region’s universities to do long range epidemiological
studies in order to determine whether these operations
may be deemed unsafe for current and/or future
generations. These studies are not currently part of their
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ph.ns.
Furthermore, one can generally figure that epidemiological
studies will show that these operations will have some
traceable adverse effects on the public’s health. Logically,
the company should be required to establish a fund to pay
for any possible health effects resulting from its
operations.
11.
Should an accident in storage or burning operations occur at
SWPCCO, what emergency procedures will be implemented?
The response time of various emergency crews which have
to come from Dayton (HAZMAT-, or Xenia is at least 15-17
minutes, possibly longer. In the event of a small accident
or gaseous leak of stored materials, a number of residents
who live within 2 miles of the Linebaugh Road facility
could be affected by airborn toxics before emerrrencv
crews arrive on the scene. When asked about this
situation, the company’s response was that they “did not
foresee such incidents taking place.”
In the case of a major catastrophe such as a tornado (in
1974, Xenia, Ohio, which along with the rest of this area
lies in “tornado alley”, was the site of the nation’s worst
tornado disaster), or earthquake (this area of Ohio
experienced major damage from a huge earthquake in the
early 1800s centered on the Madrid Fault in Arkansas
Another such quake could be expected in the next
century) which could register 5-6 in Ohio. While this is of
the magnitude of the quake experienced in San Francisco
in 1990, buildings here are not engineered to California
standards. In the event of such a calamity, emergency
crews would certainly be consumed with work all over the
area and might never go to the SWPCCO facility. Also, in
such a calamity, the plant could likely anticipate
simultaneous fires and tank ruptures presenting risks to
workers, residents and contamination of ground water all
at the same time. Yet SwpcCO has not planned to
maintain apermanent 24hour emegency crew. The
company’s emergency crew would be based in Findlay, Ohio
approximately 100 miles away.
12.
How will the materials being burned as fuels be
monitored?
While the company says it will not handle certain kinds
of hazardous waste (eg: nuclear waste, PCBs, or pesticides)
the pressures somewhere along the line to include various
of tb se materials in shipments will be large.
There is already evidence that waste from the production
of various pesticides produced for markets here and
abroad are being burned in cement kilns in the country.
In some cases, these include DM’ and other pesticides not
approved or registered for the domestic market. It is very
.