Holcims draft EIS - Missing Data, Missing Analysis Missing the Point Anne Hedges Montana...

Holcim’s draft EIS -Missing Data, Missing Analysis

Missing the Point

Anne HedgesMontana Environmental Information Center

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Particulates & Gases

CEMENT KILNS - How do they work?

What’s the Baseline?KILNS USED IN BASELINE

Process

Pollution Control Type

Whole or chipped tires

Holcim Trident wet ESP Whole Holnam, MO wet ESP chipped Ash Grove, OR dry ESP chipped Holnam, WA wet ESP chipped Boxcrow, TX dry baghouse chipped Lehigh, MD dry ESP whole RMC Lonestar, CA

dry ESP whole

Southwestern, CA dry baghouse whole CA Portland, CA dry baghouse whole Mistubishi, CA dry n/a whole Dundee, MI wet baghouse chipped

How Was Baseline Calculated?

What’s in the baseline? Coal (what type of coal) natural gas, coke, slag? How much of each?

No similar sources used-based on other kilns that aren’t wet process, whole tire, slag burning

Company is relying on “baseline testing” to verify its findings but DEQ doesn’t have the baseline testing.

Where’s the Slag?

“The risk assessment evaluated risks to human health and the environment associated with currently permitted operations (the baseline condition) and with proposed operation alterations (the cumulative condition) at the facility. Both conditions included emissions from smelter slag used as an iron source.”

Slag comparison to Iron Ore

Arsenic Chromium Manganese Selenium Zinc ASARCO 114 106 9340 8.8 23300 ASARCO 148 107 9320 6.4 18400 ASARCO 130 101 8940 5.9 18000 ASARCO 160 113 9510 6.0 19600 ASARCO 145 113 9510 9.5 19000 ASARCO 150 94.6 9370 5.7 18300 Iron Ore 24.8 20.3 214 <5 220

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RISK: The Magic Number1x 10-6

DioxinMagically at 1x10-6

Chlorine content goes up by 1,083 lbs but miraculously dioxin remains the same

Based on an EPA standard. Baseline emission is the same as cumulative exposure.

Testing every two and a half years EPA report:

wet kilns burning coal and coke produce about .4 nanograms of dioxin per dry standard cubic meter.

Another kiln burning coal, coke and tires produced 1.2 nanograms of dioxin per dry standard cubic meter.

Risks aren’t added together Eat Fish from local ponds 6 x 10-6 Live in the area 1x10-5 Drink local dairy products - below the limit Hunter risk - below the limit

But if you are a hunter who fishes from local ponds, who drinks local dairy, and you live in the area we don’t know what your risk is.

What is not in the document…Risk assessment: Figures & Tables Air Emission Calculations Human Health Risk Assessment Calculations -

Baseline Conditions & Cumulative Conditions Water Concentration Calculations Food and Forage Calculations

In total 24 attachments are not attached!

Whole v. Shredded Tires Why does it matter? It’s about surface

area. Crumb and shredded tires are inserted at

the hot end of the kiln in a steady stream. 1000 degrees hotter than middle of the kiln. No new opening.

No design specification on insertion of whole tires and the potential impacts on temperature and emissions