Re: Opposition to AB 2181 West Valley Citizen's Air Watch
Scientist's evaluation of Dangers & Problems of
Burning Tires for Fuel in Cement Kilns

The following are the excerpts from the written comments that Dr. Neil Carman sent to the California Integrated Waste Management Board that I read at the CIWMB hearing in Sacramento, 10/23/97. Joyce M Eden (This was again read into the record by WVCAW at the CIWMB in 2003)
My name is Joyce Eden. I will be reading excerpts from a 14 page written document by Dr. Neil Carman sent to the CIWMB:

Dr. Carman has a PhD in Chemistry. He served as a Texas Air Control Board Regional investigator for 12 years with technical experience in synthetic rubber plants making rubber for tires. As a TACB official, [he] conducted state air pollution inspections in one of the largest synthetic rubber plants in the US.

Many inspections were performed at the facility for compliance purposes and they lead to three state enforcement actions, including a major lawsuit by the State Attorney General's Environmental Protection Division, in which [he] served as the state's chief investigator on the case. [He] became knowledgeable with toxic air emissions being released and their relationship to plant problems in the synthetic rubber process.

During [his] tenure as a state air pollution control official, [he ] also inspected a large cement manufacturing facility with two large kilns that produced portland cement, and based on [his] state experience and knowledge of these facilities, [He] offer[s] technical grounds to oppose the disposal of wastes such as Tire-Derived Fuel (TDF) in cement kilns.

Hazardous Chemicals used in Synthetic Rubber Manufacturing are Regulated under the Federal Clean Air Act Title III as Hazardous Air Pollutants (HAPs).
Tires are often made from petrochemical feed stocks including two organic chemicals: styrene and 1,3-butadiene. Substances used to produce synthetic rubber for tires contain several hazardous chemicals as the primary constituents, which may be emitted into the air during high temperature incineration of tires in cement kilns, for example, ..Styrene-butadiene rubber has four major components, styrene, 1,3 butradiene, extender oils and carbon black.

The large volume of benzene present in the TDF waste stream and its high temperature requirement for complete combustion provides a pathway for creation of more highly toxic species such as dioxins, furans, PCBs and PAHs.

Additional (hazardous) chemicals (are) used in synthetic rubber -- [too numerous to list at this time.] [I held up page 5 which shows substances used in synthetic rubbers which are typically not naturally found in coal.]

In summary, synthetic rubber tires contain significant concentrations of toxic and hazardous chemicals. Incineration of tires has the clear potential to produce toxic emissions of numerous carcinogenic, mutagenic and teratogenic chemicals.   1 of 3    [Teratogenic chemicals disrupt normal fetal development.] The fact that the synthetic rubber industry utilizes large volumes of so many toxic chemicals in their processes is testimony to the issue that burning tires even in relatively well controlled combustion devices may result in harmful emissions and cause undesirable impacts in neighboring communities.

Cement kilns are not designed, constructed, operated, or intended to be used as scrap tire incinerators. Also, they are ...permitted and regulated as cement manufacturing facilities under different rules, regulations and regulatory policies with respect to BACT (best available control technology) review, air modeling, and public health evaluation.

Cement kilns are not designed or required to have major fail-safe combustion devices such as large afterburners that all state-of-the-art incinerators must have by federal law today (all medical, municipal, and hazardous waste incinerators can not operate without their afterburner or secondary combustion chamber in normal operation).

Cement kilns have no such fail-safe combustion devices which is unthinkable today in all modern incinerators.

..during stack tests of TDF cement kilns will do several things to make emissions and combustion look good-to-decent for such facilities:
        * run at higher excess air to improve combustion efficiency;
        * control kiln parameters more precisely;
        * prevent kiln solid ring formation and buildup that creates havoc for good combustion of any fuels;
        * operate and maintain their ESPs or baghouses in top condition to keep particulate emissions to a reduced level; and
        * operate at slightly higher kiln temperatures and other factors.

Combustion Upsets. This is a significant public health issue near cement kilns. Cement kilns certainly do have combustion upsets and smoke particles as well as other unburned waste may be emitted during such events. Different operating problems and fluctuating conditions in the cement kiln may trigger a combustion upset. Higher rates of toxic emissions will be more probable during a combustion upset and malfunction.

These indicate just a few of the technical issues surrounding combustion problems observed in cement kilns.

Pollution Hazards of Tires. It is highly inaccurate to state that TDF do not contain hazardous materials. [Some of the substances that increased when adding TDF to the coal in test burn results are] Carbon monoxide, particulate matter, chlorine, benzene, dioxins, PCBs, PAHs, Hexavalent chromium, Copper, Lead, Manganese, Mercury, Zinc, Nox and PM10. [These] stack test results show that  increases in toxic emissions are consistent with a variety of stack test results at other cement kilns.

Toxic byproducts of tire burning that no community should endure.                   2 of 3
Burning of scrap tires in cement kilns creates an array of toxic byproducts such as dioxins, furans, PAHs, PCBs.., hexavalent chromium [the Erin Brokovich toxin], and cadmium. These chemicals are recognized by health officials as causing cancer or reproductive toxicity. Other toxic byproducts from tire burning include mercury, lead, nickel, beryllium, xylene, toluene, phenol, mono-chlorobenzene, napthalene, formaldehyde, acetaldeyde, and dozens of more products of incomplete combustion. A chief health issue is the fact that chorinated chemicals (dioxins, furans, and PCBs) emitted from burning waste are linked to the increased incidence of breast cancer. are a toxic waste when they are burned. Tires are made out of materials that are considered toxic when they are in a liquid form. These are released when they are burned. The legal and "technical" exemption of tires from the definition of hazardous waste is not protective of public health when they are burned.

Cement plants have inadequate pollution control equipment for tire disposal.

Health problems from heavy metal, hydrocarbons, products of incomplete combustion, and newly created substances like dioxin emitted when burning tires are magnified when combined with dust emissions that are part of cement production process (US EPA's draft Scientific Reassessment on Dioxin, September 13, 1994)

No matter what kind of waste or fuel is being burned in them, cement kilns are large air polluters. They are a major source of Particulate Matter (soot and dust) which has been found to be toxic to human health in its own right, even at the smallest measurable levels of exposure. When waste is burned in cement kilns, this Particulate Matter acts [as] a magnet for unburned toxic metals such as lead, ...cadmium and chromium and Products of Incomplete Combustion emitted from their stacks. This "toxic enrichment" creates a major public health hazard which we believe should not be imposed upon us or our children. [NRDC report]

Cement kilns are one of the largest source of dioxin emissions in the U.S. (US EPA's draft Scientific Reassessment of Dioxin, September 13, 1994) The most toxic dioxins have been found only in cement plant emissions where synthetic substances are burned.

Incineration plus chlorine makes dioxin. Dioxin is a potent toxin capable of a variety of adverse health effects, including hormonal disruption...

Many people who live downwind of cement plants already carry unhealthy body burdens of toxic heavy metal and/or synthetic chemicals many of which mimic hormones and have other toxic effects. The slightest additional exposure will cause these people harm.

Tire incineration in cement kilns is not recycling. For obvious reasons cement kilns allow 100% or the metals to be returned to the environment as air pollution, cement kiln dust, or cement product. This is not recycling.

Cement kilns are not designed to be incinerators and do not have to meet the same stringent standards of performance and emission limits required of commercial incineration facilities.
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