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Re: E-M:/ Heads Up:Tire burning proposal at Dundee ement

Enviro-Mich message from "Alex J. Sagady & Associates" <ajs@sagady.com>


The problem down at Holnam is that this kiln...

...... is a wet process kiln so it requires much more fuel burning of whatever
    type producing greater amounts of pollutants per ton of clinker produced...

....  has a serious, pre-existing  problem with excessive emissions
produced in the cool end of the kiln from volatilization and thermal
degradation of kerogens 
(long chained, oil-like materials) contained in the limestone they use....

.....this causes a condensing plume of hydrocarbon aerosals, notwithstanding
the baghouse emission controls on the plant....

.....and expected high volatile organic compound emissions from partial
combustion of these straight chained materials, along with expected high 
carbon monoxide and other air toxics (i.e. aldehyde compounds).

I've been downwind of the Holnam plant and this facility causes, in my 
opinion, high levels of odors in the local community of an acrid, pungent
nature (so called "kiln gas")....

This is before Holnam even gets to the issue of tire burning....

Depending on where the tires are introduced into the kiln, such tire burning
exacerbate these problems.   I don't know off hand where Holnam intends to 
charge tires to the kiln, but, in general, charging tires in the cool end or
in the center of the kiln may cause serious problems with products of 
incomplete combustion and increased volatile organic/toxic emissions since
many kilns operate with extremely low (i.e.  0.5%-1%)  oxygen
at the kiln exit.

To my knowledge, MDEQ refused to require Holnam to do chlorinated dioxin/furan
testing during a test burn, and in general didn't require detailed anlytical
work on volatile organic toxicant emissions.

On the other side of this issue, with the exception of chromium and zinc,
tires may
have considerably less toxic metals than the coal and petroleum coke they
Petroleum coke, in particular, may have high concentrations of vanadium and 
selenium.   Tires may also have less sulfur than the coal they replace.
there are no Michigan regulations to control the amount of sulfur in coal
burned in 
cement kilns. 

In addition, to the extent that sulfur bearing water and sulfur bearing
limestone is 
used in such a kiln, reactions of inorganic sulfides with carbon dioxide in
flue gas
can cause the formation of hydrogen sulfide in emissions.

EPA recently published proposed regulations for the portland cement industry
that identifies that cement kilns (even ones that do not burn hazardous
waste) are
major sources of dioxins/furans, toxic metals and other airborne toxicants.

EPA has also strongly endorsed tire burning in cement kilns, although the
was made a number of years ago at a time when only limited data was
available on 
air toxics from tire burning operations.

I still owe you an answer on a previous question you posted concerning waste
at Dow Chemical.   Dr. Bill Cooper was kind enough to send me some background
information on this and I'll do this in another post..


Alex Sagady

At 02:57 PM 4/28/1998 EDT, you wrote:
>NOTE FROM: Craig Kendziorski              Phone: (517) 496-5373
>           DCC AEM Macro-Electronics PE    FAX:  (517) 496-7015
>           EMail:kendziorski@dcrn.e-mail.com     DCC Mail: #128
>SUBJECT: E-M:/ Heads Up:Tire burning proposal at Dundee ement
>A couple concerns/questions with the present "environmental approach" to
>cement kilns.
>If we dont burn/incinerate tires what do we do with all the tires in
>the US?  Piling them up or burying them till they rot and/or eventually
>burn uncontrollably doesnt sound like a very environmentally friendly
>Although I am all for improved control/requirements on the cement
>industry switching to better/cleaner fuels (oil/gas based fuels instead of coal
>based) has its own issues... Oil/Gas are very non renewable.
>Burning tires or coal helps to save oil and gas.
>Also, arent many of these emissions (HCl, lead, mercury) rather independent
>of the fuel source used?
>Rather than dictate specifics on what fuels cement kilns use would
>we be better off fighting directly for what we want...less emissions of
>VOC, lead, mercury etc (also dust which wasnt mentioned, but in my experience
>has been a very hazardous emissions from cement plants).
>*** Forwarding note from I3640929--IBMMAIL  04/28/98 11:17 ***
>Date: Tue, 28 Apr 1998 09:15:02 -0500
>To: enviro-mich@great-lakes.net
>From: ecaa@igc.org (ecology center)
>Subject: E-M:/ Heads Up:Tire burning proposal at Dundee ement
>Enviro-Mich message from ecaa@igc.org (ecology center)
>Dundee Cement (now Holnam, Inc.) has applied to the DEQ for a permit to
>burn 40,000 tons or 2.8 million tires at its two cement kilns located in
>Dundee (SE Michigan). The tires will replace approximately 18% by weight of
>the coal/coke fuel which the kilns presently use. The proposed permit is
>based on a test burn which occured at Dundee in April, 1997 which failed to
>measure Dioxin/Furans and produced emissions numbers significantly higher
>than many other cement kilns. Emissions from the facility include over
>7,000 tons per year VOC's, as well as significant amounts of  HCl, arsenic,
>cadmium, chromium, lead, and mercury. Comments should focus on the fact
>that better/cleaner fuels are available and improved emissions controls are
>not being installed.
>Public hearing will be held on May 5, 7pm at Dundee High School Cafeterium,
>420 Ypsilanti Street, Dundee.  For copies of proposed permit and staff
>report contact MI-DEQ permit engineer Assad Kahn (517)335-6825. For more
>info contact Jeff Gearhart/Hans Posselt (734)663-2400.
>Jef Gearhart
>Ecology Center of Ann Arbor
>117 N. Division
>Ann Arbor, MI  48104
>(734)663-2400 or (734)761-3186(ph)
>(734)663-2414 (fax)
>*please note new area code
>Ecology Center of Ann Arbor
>117 N. Division
>Ann Arbor, MI  48104
>(734)663-2400 or (734)761-3186(ph)
>(734)663-2414 (fax)
>*please note new area code
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NEW EMAIL ADDRESS!!!            ajs@sagady.com
Alex J. Sagady & Associates        Email:  ajs@sagady.com
Environmental Consulting and Database Systems
PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)

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