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Letter re: Hazards of Liquid Chem Fuel burned in
Castle Cement's new cement kiln
Public Inquiry
Issues Letter
Background
COMMENTS
AGAINST CASTLE CEMENT'S NEW KILN PERMIT TO BURN CEMFUEL AND TYRES
Toxic Cement used for public
drinking water pipes needs to be prevented in the United Kingdom...
Cement Kilns: Hazards Associated
with Waste Incineration
Engineering,
Design, Construction & Operation of Cement Kilns
Cement
Kilns lacking in second burn chambers: Afterburners
Combustion
Upsets
Stack
Flow Mass Rates
Cement
Kilns have more limited Air Pollution Control systems than Modern Incinerators
Cement
Kiln are not necessarily more effective at Thermal Destruction than Incinerators
High
Metal Content
Toxic
byproducts of Cemfuel incineration that no community needs to endure
Dioxin,
the US Environmental Protection Agency and Human Body Burdens
Hazards
of Cemfuel Waste Burning and Dioxin Pollution from Cement Kilns
Dioxin reported health effects in human and wildlife
populations
Summary
At
least eleven general areas of dangers exist to human health and the environment
from Castle Cement's activities
Mr. Anthony Vaughan
c/o Mr. Sion Charles
The Planning Inspectorate
Crown Buildings
Cathays Park
CARDIFF, CF10 3ND
United Kingdom
c/o Castle Cement Inquiry
Theatr Clwyd
Mold, Flintshire
United Kingdom
Re: Hazards of Liquid Chem Fuel burned in Castle Cement's new cement kiln
Dear Sir,
Attached is a letter submitted in support of the Campaign Against the New Kiln regarding Castle Cement's plans to incinerate waste, including a broad range of industrial materials, in a new state-of-the-art, 5-stage preheater and precalciner cement kiln at it's cement plant in Padeswood, North Wales.
Please enter the letter into the Public Inquiry record concerning Castle Cement's proposal.
The Sierra Club's Lone Star Chapter is a statewide non-profit environmental and conservation organization operating in Texas with 22,000 member and which is also part of the national Sierra Club in the USA. The Sierra Club is dedicated to efforts on a broad range of public health protection and environmental conservation issues, including government policy on pollution and waste incineration where public health and the environment may be impacted. I want to emphasize, that in 1983 because of national health concerns, the Sierra Club developed a new policy opposing all waste incineration as a disposal method in incinerators, boilers and industrial furnaces such as cement kilns. A major public health concern of the Sierra Club is that the pollution spewed by incinerators is now recognized by scientists to travel around the world and affect people and the environment so that there are no boundaries for this pollution.
Communities in the USA have vigorously opposed and stopped or
prevented more than a dozen cement kilns (including newer dry process preheater,
precalciner kilns and several old wet process) from burning toxic waste
in many states (Texas, California, Oklahoma, Michigan, Nebraska, Montana,
Ohio, Maryland, Florida, and others. In 2000 for instance, Lafarge
Cement at Alpena, Michigan on Lake Huron and Carolina Solite in North
Carolina agreed to stop hazardous waste incineration in part due to local
community pressures to end such dangerous practices. New US EPA pollution
standards are further discouraging cement kilns from burning toxic waste
since expensive pollution control technology and pollution monitoring systems
may be required if incineration is to continue. So several cement kilns
have been choosing to comply by ending incineration activities. However,
I have assisted the national efforts of the Sierra Club in filing legal
actions against the US EPA for failing to adopt the most protective public
health standards for cement kilns burning industrial waste as required
under
federal law. The so-called state-of-the-art preheater, precalciner
cement kilns are not considered as safe as dedicated incinerators.
PUBLIC INQUIRY
ISSUES LETTER
These comments address the first of the five items for consideration
which is:
a) the effect of the
proposed development on public health.
BACKGROUND
I served as a State of Texas air pollution control inspector
of industrial plants with the Texas Air Control Board's Odessa Regional
office for 12 years (1980-92). Technical experience emphasized compliance
investigations of industrial plants and their emissions; these large plants
were also industrial waste generators of liquid fuels. As a state government
official, my duty included conducting state air pollution inspections at
several hundred facilities including Portland cement kilns. During my
tenure with the state air pollution control agency, I inspected a large
cement manufacturing facility with two large kilns that produced Portland
cement, and based on my state experience and knowledge of these facilities,
I offer technical grounds to oppose the incineration of industrial and
other industrial wastes such as Cemfuel in cement kilns.
It is a generally recognized regulatory fact that high levels of particulate
matter emissions are authorized from permitted cement kilns due to the
inherently dusty nature of the manufacturing process in addition to the
economic cost of controlling such emissions, and particulate emission rates
and annual volumes tend to be significantly higher from cement kilns as
a result than that allowed from any type of commercial incinerator facility.
I base this on direct experience and observations in the field in
addition to regulatory knowledge over the past 20 years.
In addition to other state enforcement cases, my work involved legal
actions against several waste incineration facilities that included lawsuits
brought by the State of Texas' Attorney General Office Environmental Protection
Division. Since 1992, my capacity with Sierra Club has involved preparing
technical evaluations of commercial waste incineration plants in a broad
variety of facilities including medical waste incinerators, municipal waste
incinerators, hazardous waste incinerators, hazardous waste burning cement
kilns, waste burning light-weight aggregate kilns and industrial waste
incinerators operating in Texas and more than a dozen states in the USA.
Based on this extensive experience and knowledge of significant non-compliance
issues, I
maintain a professional skepticism over the ability of these facilities
to operate in continuous compliance during industrial toxic waste treatment
operations and have serious concerns about the public health impacts that
these toxic air emissions have had on communities living downwind of these
plants.
Since 1992, I have worked with many communities across the USA to oppose the incineration of industrial wastes similar to the cemfuel and other toxic waste that Castle Cement is seeking to burn in its new kiln. Cement kilns in the USA call waste incineration "recycling" but citizens prefer to term it "sham recycling" since it turns the cement companies into sham incinerator operators in essence.
The attached comments should assist in providing a balanced perspective on the Castle Cement's proposal pending before the agency. Let me know if I may be of further assistance.
Respectfully yours,
NEIL J. CARMAN, PH.D.
Former Texas Air Control Board plant inspector
Clean Air Program Director
Lone Star Chapter of the Sierra Club
P. O. Box 1931
Austin, TX 78767-1931
USA
Phone (512) 472-1767
Fax (512) 477-8526
Email: Neil_Carman@greenbuilder.com
COMMENTS AGAINST CASTLE CEMENT'S NEW KILN PERMIT TO BURN CEMFUEL AND TYRES
Submitted October 11, 2000 to the Public Inquiry
These comments were prepared by Neil J. Carman, Ph.D., Clean Air
Program Director for the Lone Star Chapter of the Sierra Club.
A. TOXIC CEMENT USED FOR PUBLIC DRINKING WATER CEMENT PIPES NEEDS TO BE PREVENTED IN THE UNITED KINGDOM DUE TO A POTENTIAL FOR LEACHING OF TOXIC SUBSTANCES
A fundamental public health issue is the possible leaching of toxic substances such as hexavalent chromium, other toxic heavy metals, and dioxins into the public's drinking water from cement pipes constructed of the toxic cement from kilns burning hazardous toxic waste such as the new kiln at Castle Cement's Padeswood Works. Toxic cement from burning hazardous waste may contain significantly higher concentrations of metals since they can be present in the waste residues processed in the cement kiln and certain metals will readily partition into the clinker or cement portion. Chromium is one of these leachable metals including hexavalent chromium.
Leaching of harmful residues from toxic cement has prompted concerns in the USA. Officials with the US Environmental Protection Agency raised precisely this issue. Hugh Kaufman, US EPA's Hazardous Site Control Division (Office of Solid Waste and Emergency Response) sent a memo to then US EPA Administrator William Reilly on December 7, 1990 regarding toxic waste incineration issues in cement kilns.
On page 4 Mr. Kaufman's memo states:
"How many miles of cement drinking water mains produced from
these cement kilns will have to be dug up in the future, when the toxic
metals and other hazardous waste residues in the cement leach into water
supplies? How much taxpayer money will have to be expended to remediate
this problem, a problem which could be easily and cheaply prevented?"
Cement made from toxic waste may actually be of inferior quality due to its chemistry. For example, high zinc levels may result in poor quality cement that may tend to set up too quickly thus prohibiting its use as well-plugging cement. Significant leaching of metals and toxic substances will be more predictable if the cement contains higher concentrations of metals, metal compounds and other toxic byproducts of cemfuel waste incineration.
Castle Cement's toxic cement must not be utilized for cement pipes constructed for transporting of public drinking water supplies and such cement needs to be labeled to avoid this dangerous use.
B. CEMENT KILNS: HAZARDS ASSOCIATED
WITH WASTE INCINERATION
1. ENGINEERING, DESIGN, CONSTRUCTION, AND OPERATION OF CEMENT KILNS
Cement kilns are not typically designed, constructed, operated, or intended
to be used as commercial industrial waste
incinerators, municipal waste incinerators, medical waste incinerators,
or hazardous waste incinerators, since they are designed to produce cement.
Cement manufacturing of high quality Portland cement is performed
counterproductive to the needs of
sound hazardous waste incineration and pollution control technology.
In addition, cement kilns are primarily 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 compared to permitted incineration
facilities.
The US EPA requires all modern waste incinerators to be built as dual-chambered
incinerators with each train possessing an afterburner chamber, but since
this type of facility is designed and operated rather differently than
a cement kiln, direct comparisons of stack test data during Cemfuel trial
burns are not appropriate due to basic technology differences and air pollution
control systems. Cement kilns typically can not meet the significantly
lower air pollution rates characteristic of
incinerators due to different designs and air pollution control
systems.
Retrofitting cement kilns with certain air pollution control systems
required of modern incinerators (i.e., quench systems, acid gas scrubbers,
baghouses) tends to be too economically prohibitive, and so cement kilns
tend not to burn waste including waste fuels unless they are authorized
to use fewer control systems and emit significantly higher mass rates of
toxic air pollution such as toxic heavy metals, dioxins, dibenzofurans,
and other byproducts of incomplete combustion.
2. CEMENT KILNS LACKING IN SECOND BURN CHAMBERS: AFTERBURNERS
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 US law today (all medical, municipal, and hazardous waste incinerators can not operate without their afterburner or secondary combustion chamber in normal operation). Secondary combustion or afterburner chambers have been a standard incinerator requirement for several decades as fail-safe devices to insure that large volumes of toxic byproducts do not result from incinerator operation.
Afterburners are required due to the serious potential for flame outs
and total combustion failure in the primary burn chamber or primary kiln;
the universe of approximately 120 U.S. cement kilns only possess a primary
kiln and no fail-safe secondary chamber exists to prevent large volumes
of toxic byproducts when the primary cement kiln undergoes a failure such
as
flameout. Afterburners also help to insure and attain the highest combustion
efficiency an incinerator can achieve. Cement kilns have no such fail-safe
combustion devices which is unthinkable today in all modern incinerators.
Requiring cement kilns to install afterburners is economically prohibitive.
Afterburners generally operate at somewhat higher temperature regimes than the primary incinerator chambers since the first burn is primarily to promote volatilization (from solid/liquid to gas state) because combustion occurs in the vapor state, and thus the majority of combustion in an incinerator takes place in the afterburner chambers. Early dual-chambered incinerators possessed large primary kilns and small afterburner units, but today, afterburners are typically far larger than the primary kilns.
Do cement kilns actually offer higher combustion temperatures, higher
residence times, improved turbulence, and higher oxygen than incinerators?
This is one of the chief technical myths perpetuated by cement kilns
to promote waste disposal in their facilities.
These are complex process questions that can be debated by different
technical experts to give very different sets of answers, and partly because
there are two different types of cement kilns such as:
1) old, energy inefficient wet process kilns and
2) newer, more energy efficient dry process cement kilns.
Generally cement kilns run at higher combustion temperatures than incinerators
at least within the hot end of the cement kiln (but which is a short zone),
but this ignores the cold end of the cement kiln and this fact may be ignored
by cement companies presenting testimony in public.
Cement kilns with preheaters/precalciners offer several locations for
cemfuel disposal, but some locations may not necessarily be hotter than
an incinerator's primary kiln. Temperature is not the only requirement
for good combustion, since residence time, turbulence and oxygen must be
available all together. Without all parameters working together, poor combustion
will result even in cement kilns. Cement kiln residence time of carbon
compounds tends to be exaggerated by technical experts because
the kiln conditions with many tons of fluidized materials prevents
an ideal condition for incineration to occur.
In terms of heavy metals in cemfuel and coal, the higher cement kiln temperatures may be operating too hot as they will result in higher stack pollutant gas and particulate concentrations since the higher temperatures encourage more metal volatilization and emission rates compared to an incinerator's temperatures.
With respect to the report that cement kilns provide longer residence times and adequate oxygen (i.e. as excess air) to yield complete combustion, this is certainly not always the case for several technical reasons.
a) Cement kilns when stack tested show products of incomplete
combustion (PICs). Various PICs include but are not limited
to:
dioxins, dibenzofurans, polychlorinated biphenyls (PCBs), polycyclic
aromatic hydrocarbons (PAHs), benzene, etc. just like incinerators and
other waste combustors demonstrating that ideal combustion is certainly
not being achieved. PICs are typically always observed during trial burns
in cement kilns, and this implies that combustion conditions are not able
to totally destroy organic compounds. So complete combustion is not necessarily
achieved even in cement kilns.
b) Turbulence for good combustion may not be as efficient as cement
company experts claim in cement kilns due to the
extraordinarily large volumes of solid materials in the kiln being
used to make clinker and then cement product, in part since a cement kiln
is a giant oven used to bake rock and turn it into clinker. Observers have
reported unmelted hazardous waste pails exiting the kiln as evidence of
poor combustion conditions, and high levels of PICs further demonstrate
that cement kilns are far from perfect in combustion of complex waste materials.
c) Cement kilns typically run on the lower limits of excess air for good combustion due to the huge quantities of air required to be heated from ambient temperatures to approximately 3,000 degrees F, and to heat this much air to such high temperatures requires tremendous energy and high fuel costs. So every single pound of air heated in a cement kiln exacts a certain operating cost in fuel use and thus cement kilns try to keep the excess air (and oxygen) at the borderline of safe combustion.
d) A major problem that cement kilns may experience is solid ring formation
and build up across the diameter of the kiln when
the solid material fuses into a wall blocking movement of clinker material
down the kiln. Cement kilns have to break the solid ring formation down
by shooting (with turret mounted shotguns) large shotgun blasts into the
ring to collapse it. Ring formation does not promote good combustion conditions
particularly in the presence of hazardous waste and chem fuel, and yet
this
routinely occurs in many cement kilns. A cement kiln may shoot hundreds
of shotgun blasts into the giant, thick solid rings built up inside the
cement kiln in order to break it down.
But during stack tests of cemfuel burning, cement kilns will do several
things to make emissions and combustion look good-to-decent for such facilities:
a) run at higher excess air conditions to briefly improve combustion
efficiency;
b) control kiln parameters more precisely than normal daily operations;
c) prevent kiln solid ring formation and buildup that creates havoc
for good combustion of any waste fuels like cemfuel;
d) burn lower cemfuel levels or possessing lower metal and chlorine
content during stack tests than they may be seeking to burn
operationally on a daily basis;
e) operate and maintain their ESPs or baghouses in top condition to
keep particulate emissions to a reduced level; and
f) operate at slightly higher kiln temperatures and other factors.
3. COMBUSTION UPSETS OCCUR IN CEMENT
KILNS IN WHICH HARMFUL EMISSIONS MAY
FALLOUT INTO THE COMMUNITY AND ENVIRONMENT
This is a significant public health issue near cement kilns. Cement kilns certainly do experience combustion upsets and smoke particles as well as other unburned waste that 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.
Other kinds of upsets. Cement kilns are subject to a variety of other problems, including a type of meltdown of the kiln when the ID fans lose power or fail to operate; without adequate air flow to control kiln temperatures at or below 3,000 degrees F, the kiln temperature may skyrocket quickly to more than 4,000 degrees F and the kiln is so hot that the steel shell sags toward the ground effectively destroying the kiln or major sections of the kiln. Kiln meltdowns are not rare events and have happened in many US states at cement plants in the last ten years. Cement companies prefer not to talk openly about this problem.
These indicate just a few of the technical issues surrounding combustion
problems observed in cement kilns. The bottom line is that they are not
designed, not built and not operated as state-of-the-art incineration devices,
but are basically old model-T versions (especially old wet process kilns)
of first generation incinerators of the 1950's-mid 60's which had no afterburners
4. STACK FLOW MASS RATES HIGHER IN CEMENT KILNS COMPARED TO INCINERATORS AND MASS EMISSION RATES IN CEMENT KILNS ARE TYPICALLY HIGHER THAN INCINERATORS
Cement kilns tend to be larger in size than incinerator kilns and larger
volumes of air move through a cement kiln to control temperature and other
kiln conditions. Stack flow rates of air in a cement kiln may be 6-10 times
higher than an incinerator's flow rate, and this means that equal concentrations
of a pollutant (like PM10 and PM2.5) would result in greater emission volumes
by mass calculations from the cement kiln. Mass emission rates typically
are much higher from cement kilns and this is a major public health concern,
since it means that cement kilns are being allowed to pollute more than
incinerators operating under normal conditions.
5. CEMENT KILNS HAVE MORE LIMITED AIR POLLUTION CONTROL SYSTEMS THAN MODERN INCINERATORS
Cement kilns are not required to install and operate as many air pollution
controls as waste incinerators such as acid gas scrubbers and other devices.
Without such equipment, cement kilns will probably emit more harmful air
contaminants over time in both pounds per hour and tons per year emission
rates.
6. CEMENT KILNS ARE NOT NECESSARILY MORE EFFECTIVE AT THERMAL DESTRUCTION THAN INCINERATORS
Cement kilns do not necessarily destroy hazardous wastes more efficiently
than modern commercial waste incinerators. Cement kilns still emit significant
rates of unburned byproducts of toxic waste incineration as evidence that
they are not more efficient and may be less efficient than dedicated incinerators.
Metals certainly are not destroyed in cement kilns and may tend to vaporize
more readily at the higher kiln temperature conditions.
7. METAL CONTENT OF CEMENT KILNS EMISSIONS MAY BE HIGH
Cemfuel will contain a broad array of toxic heavy metals and the amounts
vary somewhat according to the waste generators. Lead, mercury, cadmium,
chromium, beryllium and other metals can be at highly elevated concentrations
in the waste streams and emitted from the kiln stack.
These metals are harmful to the community and the environment. The
cement kiln problem is that 100% of the metals going into the kiln will
be emitted as air pollution, end up in the clinker to leach later back
into the environment, or be found in the cement kiln dust to be disposed
of in a landfill where leaching into the water and environment is likely
to occur.
8. TOXIC BYPRODUCTS OF CEMFUEL INCINERATION THAT NO COMMUNITY NEEDS TO ENDURE
Cement kilns are well recognized as emitters of significant rates of
toxic emissions resulting from toxic waste incineration. Burning of hazardous
toxic waste in cement kilns creates an array of toxic byproducts such as
dioxins, dibenzofurans, PAHs, PCBs (polychlorinated biphenyls), arsenic,
hexavalent chromium, mercury, and cadmium and others depending on the metals
in the waste streams. These chemicals are recognized by health officials
as causing cancer or reproductive toxicity. Other toxic
byproducts from Cemfuel burning include mercury, lead, nickel, beryllium,
xylene, toluene, phenol, monochlorobenzene, naphthalene, formaldehyde,
acetaldehyde, and dozens of more products of incomplete combustion. A chief
health issue is the fact that chlorinated chemicals (dioxins, dibenzo-furans,
and PCBs) emitted from burning waste are linked to the increase incidence
of breast cancer.
9. DIOXIN, THE U.S. ENVIRONMENTAL PROTECTION AGENCY AND HUMAN BODY BURDENS
Dioxin (family of 75 congeners) was recognized by the US EPA in 1985
as the most potent manmade carcinogen known. Daily intake of 14 trillionths
of an ounce represents a lifetime cancer risk of one in a million. Yet
average US intake is probably high enough to produce an additional
50 to 1,000 cancer cases per million people. And recently US EPA acknowledged
dioxin's
harmful effects on reproduction and development as well. Dioxins, moreover,
are stable compounds that persist in the environment and bioaccumulate
in the food chain, concentrating in meat and dairy products. Sadly, the
ultimate outcome of bioaccumulation is that dioxin passed from mother to
child in breast milk typically amounts to 4 to 12% of a person's lifetime
exposure.
The fetus is at grave risk of dioxin exposure due to its ultrasensitive
developmental process and breast feeding babies even more at risk.
Cement plants have inadequate pollution control equipment for Cemfuel disposal. Cement kilns are designed to bake rock until it makes cement "clinker," not to burn wastes. All kilns rely on only one air pollution control device to filter stack emissions - the same device they use whether they are making cement or burning waste. This device, designed to remove particles, does not remove heavy metal vapors like mercury or other toxic gases released from burning Cemfuels. Nor does it remove all dioxins, PCB's, or furans which tend to be created when Cemfuels are burned in cement kilns and for which many scientists say there is no safe level of exposure. (US EPA's draft Scientific Reassessment on Dioxin, September 13, 1994)
Health problems from heavy metals, hydrocarbons, products of incomplete combustion, and newly created substances like dioxin emitted when burning Cemfuels 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 and 2000)
Typically, 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.(Breath
Taking: Premature Mortality due to Particulate Air Pollution in 239 American
Cities, Natural Resources Defense Council Report May 1996)
When waste is burned in cement kilns, this Particulate
Matter acts a magnet for unburned toxic metals such as lead, arsenic,
cadmium and chromium and Products of Incomplete Combustion emitted from
their stacks.(Breath Taking report)
This "toxic enrichment" of the tons of Particulate Matter these cement
kilns release into the atmosphere when waste is burned creates a major
public health hazard which we believe should not be imposed upon us or
our children.( Breath Taking report)
Cement kilns are one of the largest source of dioxin emissions in the
U.S. (US EPA's draft Scientific Reassessment on Dioxin, September 13, 1994
and 2000)
The most toxic dioxins have been found primarily in cement plant
emissions where synthetic waste substances are burned compared to conventionally
fired kilns. (US EPA's draft Scientific Reassessment on Dioxin, September
13, 1994 and 2000)
If they are allowed to burn wastes that could result in the creation
of dioxin, we believe that cement kilns should be required to install continuous
dioxin monitoring and control equipment.
Incineration plus chlorine makes dioxin. (US EPA's draft Scientific
Reassessment on Dioxin, September 13, 1994 and 2000) Dioxin is a
potent toxin capable of a variety of adverse health effects, including
hormonal disruption, decreased sperm count, decreased testis size, altered
male sexual behavior, cancer, endometriosis, ovarian dysfunction, reduced
fertility, immune system suppression, spontaneous abortion, birth defects,
impaired child development, thyroid changes and diabetes, according to
EPA's draft reassessment on dioxin. The average person currently carries
a body burden of 15-20 parts per trillion of dioxin. (Arnold Schecter,
MD, Dioxins and Health, 1994)
Even a single, minute exposure to dioxin can cause irreparable harm
to unborn children. Evidence that body burdens are
increasing or decreasing conflict and are inconclusive. There
are significant reservoirs of dioxin already in the environment. We don't
need any more dioxins created. My position is that cement kilns should
not be allowed to use wastes that contain chlorine (or other halogens like
bromine) without continuous dioxin emission monitoring and control equipment.
Many people who live downwind of cement plants already carry unhealthy
body burdens of toxic heavy metals and/or synthetic chemicals many of which
mimic hormones and have other toxic effects. The slightest additional exposure
will cause these people harm.
10. HAZARDS OF CEMFUEL WASTE BURNING AND DIOXIN POLLUTION FROM CEMENT KILNS
Cemfuel burning is dangerous due to increased dioxin pollution. Why be concerned over cement kilns and dioxin pollution? Here is a brief summary of recent scientific concerns stating why dioxin is a significant public health threat.
Dioxin reported health effects in human
and wildlife populations:
A. Cancer
B. Endometriosis increasing.
C. Immune System depressed resulting in increased
susceptibility to infections.
D. Immune system compromised in wildlife and
human populations.
E. Immune system hyper-stimulation leading
to 10 illnesses:
1) Scleroderma
2) Graves' disease
3) Addison's disease
4) Arthritis
5) Asthma
6) Type I diabetes
7) Hashimoto's disease
8) Myasthenia gravis,
9) Lymphocytic adenohypophysitis
10) Thyroid diseases
F. Human Fetal Development impaired
G. Birth Defects
H. Sterility - Reduction in sperm count by 40-50%
and increased sterility among men in industrialized countries since
the 1930's.
I. Reduced Liver Function
J. Decreased size of human reproductive organs
(non-functional)
K. Endocrine system impaired
L. Lower IQ
M. Fatigue
N. Reduced glucose tolerance
O. Emotional problems
P. Heart disease
Q. Reproductive effects:
1) Increases in cancer of the testicles in many industrialized countries.
2) Increased incidence of undescended testicles in humans and in wildlife.
3) Increased incidence of hypospadias -- a birth defect of the male
genitalia.
4) Reduced fertility and increased sterility in birds, fish, shellfish,
and mammals.
5) Decreased hatching success in birds, fish and turtles.
6) Demasculinization and feminization in male fish, birds, and mammals.
7) Defeminization and masculinization of female fish and birds;
R. Gross birth deformities in birds, fish and turtles.
Cemfuel incineration in cement kilns is not recycling. For obvious reasons cement kiln allow 100% of 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.
At least eleven general areas of dangers exist to human health and the environment from Castle Cement's activities:
1). Air pollution
transported over at least nearby regions that is produced by Castle Cement's
stack and fugitive
emissions involving various contaminants such as metals, products of incomplete
combustion, particulate matter, sulfur
compounds, hydrochloric acid/hydrogen chloride gas, radioactive materials,
and miscellaneous contaminants. This
includes emissions of ozone precursors such as NOx and VOCs. Also
emissions of various sulfates and nitrates that
contribute to acid rain impacts.
2). Ground water
pollution on and off-site produced by Castle Cement's toxic emissions,
especially metals but also
products of incomplete combustion such as dioxins and furans plus other
products of incomplete combustion,
particulate matter, sulfur compounds, hydrochloric acid/hydrogen chloride
gas, radioactive materials, and any other
miscellaneous contaminants that may be cause for concern.
3). Soil contamination
on and off-site from airborne fallout produced by Castle Cement's stack
and fugitive emissions involving metals, dioxins, furans and other products
of incomplete combustion, particulate matter, sulfur compounds, radioactive
materials, and any other miscellaneous contaminants that may be cause for
concern.
4). Drinking water pollution in area lakes, ponds and
rivers produced by Castle Cement's toxic emissions, especially metals but
also products of incomplete combustion such as dioxins and furans, radioactive
materials, as well as any other miscellaneous contaminants that may be
cause for concern.
5). Water pollution in nearby area recreational waters
produced by Castle Cement's toxic emissions, especially metals but also
products of incomplete combustion such as dioxins and furans, radioactive
materials, as well as any other miscellaneous contaminants that may be
cause for concern.
6). Agricultural contamination and damage in the nearby
area produced by Castle Cement's stack and fugitive emissions involving
various contaminants such as metals, products of incomplete combustion
such as dioxins and dibenzofurans as well as other products of incomplete
combustion, particulate matter, sulfur compounds, hydrochloric acid/hydrogen
chloride gas, radioactive materials, and any other miscellaneous contaminants
that may be cause for concern.
7). Toxic cement product made from Castle Cement's hazardous
waste firing in its cement kilns; such cement may contain metals,
products of incomplete combustion, toxic particulate matter, sulfur
compounds, radioactive materials, and miscellaneous contaminants.
8). Hazardous waste transportation by truck through the
nearby area and large scale volume storage, handling and processing (blending)
at Castle Cement.
9). Potential of fires, explosions and accidents at Castle
Cement involving industrial waste activities.
10). Cumulative or aggregate pollution impacts produced
by combining Castle Cement's emissions with other polluting manufacturing
plants in nearby areas.
11). Drinking water pipes may leach toxic materials is Castle
Cement's toxic cement is utilized in public drinking water pipe construction.