Table of Contents: Cemex Corporation EIS
The authors of this Environmental Impact Statement initiated the planning process through consultation and coordination with the Environmental Protection Agency, the Colorado Department of Public Health, Cemex Corporation, the Sierra Club, local citizen╠s action groups and various industry personnel. Additional research was conducted by each member throughout CU╠s spring semester of 2003. Scientific journals, technical literature publications, and internet resources were consulted. Writing of this EIS followed a logical progression from scoping procedures to executing the technical evaluation.
1) This EIS assumes that Cemex will incinerate 1.4 million tires to accommodate 20% of their energy needs.
2) 5 million Btu╠s are required to produce 1 ton of cement. 3) Cemex is using a rotary cement kiln to produce Portland cement at their plant in Lyons, Colorado.
4) Assume that studies and information gained from industry and regulatory agencies are correct and factual.
5) Tire incineration is of significant public concern therefore there are many activist groups acting against many of the proposed plans.
6) That studies conducted by the Sierra Club are factual however lack pertinent information that is present in current state and federal studies.
7) Current technological developments inhibit the utilization of 100% tire incineration.
More specific assumptions are included in the analysis of each impact.
1) This EIS is based upon research accumulated from various technical literature publications
2) Government sources were contacted regarding regulations and current practices involving tire incineration
3) Industry personnel within waste disposal and Portland cement manufacturing facilities provided various elements of the research process.
4) John Lohr, Cemex Corporation plant manager provided specifications of tire incineration logistics.
5) This EIS was a collaborative effort produced by members of the ENVD 4023 class during CU-Boulder╠s spring 2003 semester. Members include: Laura Boocock, Michael Boyle, Stephanie Muirhead, Brian Peterson, and Shea Powell.
More specific methods are included in the analysis of each impact.
1.2 Purpose and Need for Proposed Action
The proposed action for the Cemex Corporation in Lyons, CO is to burn 1.4 million tires per year in order to provide the cement plant with 20% of its energy needs. Tires provide an inexpensive form of fuel that will allow the company to reduce their energy costs while recycling a hazardous product. Recent debate over tire incineration at the Cemex Plant in Lyons, Colorado has halted Cemex's desire to implement tire incineration.
Issues arise concerning this non-conventional source of fuel in that the composition varies from fuel sources such as coal or natural gas. This EIS analyzes the affect of this variability upon such factors as air quality, human health, and expected economic consequences.
Information on tire derived fuel is often highly contradictory. Cement manufactures tend to be in favor of tire incineration, largely due to its economic benefit; environmentalists oppose tire incineration, viewing it as a relatively unregulated form of cheap fuel, only allowable through exemptions of hazardous waste recycling. This EIS is written in response the controversy and potential environmental degradation associated with the use of Tire Derived Fuel. The purpose is to create a relatively unbiased account of the influence of tire derived fuel, and recommend a proposed action for Cemex Corporation.
Following is a more specific list of the issues and concerns that arise due to tire incineration. Later sections of this EIS will attempt to comment on many of these issues.
Issues and Concerns:
1. Cement kilns operate under weak standards that allow them to burn hazardous fuels with higher emissions than other hazardous waste incinerators. Regulation of emissions produced during the cement process is further hindered by the regulatory exemptions of recycled materials, i.e. tires. Expansion of fuel resources used by incinerators could negatively impact the environment in a manner that is not easily regulated.
2. Tire Derived Fuel could amplify the negative impact on air quality by introducing new compounds into the incineration process and increasing the concentrations of compounds already present. Compounds of interest include particulates, sulfur dioxide, nitrogen oxides, carbon monoxide, benzene, and heavy metals.
2. Numerous health effects ranging from increased respiratory problems to increased incidences of cancer can result from additional emissions that may be released during incineration of Tire Derived Fuel. The elderly and the young are at particular risk to these substances.
3. The Cemex Plant lies in close proximity to the city of Boulder, Colorado. Improper incineration and the release of additional emissions could put a large population at risk.
4. Workers may be exposed to high concentrations of metals and other compounds that are in the kiln due to the incineration of tires. This direct contact could severely impact the health of workers.
5. The method of tire incineration may simply be instituted as a means of reducing costs. Resulting economic benefit could hinder Cemex's ability to properly evaluate other options that are more beneficial such as more efficient technology.
6. Cemex has a poor environmental track record for compliance with the EPA. Safety issues are amplified due to the possibility of wide scale negative consequences. Research indicates problems at the Lyons plant as well as other Cemex operations around the country. Proper tire incineration relies on consistent management practices that may not be present at Cemex.
Agency Role in Authorizing the Action: The Boulder County Land Use Office validated the preexisting permit that allowed Cemex to burn tires as a source of fuel. This is somewhat questionable due to the fact that the permit was expired. This re-designation took place on September 5th, 2002. Even with this agency authorization progress in conversion of the plant has not continued due to resistance by members of the local community.
1.3 Project History
Lyons cement plant has been operating since 1950 under various ownerships by Martin Marietta, Southdown and currently Cemex. Cemex is the biggest distributor of Portland cement in the US and has operations in 33 other countries.
There have been a number of disputes between various activism groups in the local area and the Cemex plant. In August 2001 a Memorandum of Understanding was signed. This Memorandum of Understanding recommended that Cemex would improve certain procedures, notably the federally recommended practice of watering dust to keep it from becoming airborne. The terms of the memo are not legally binding.
EPA's Detailed Facility Report for Cemex shows the plant was in violation of the Clean Air Act from January 2001 until March 2003. All violations are outstanding at the time of press and state and local agencies are delegated enforcers.
The state board of health made an unannounced inspection of the plant in September after complaints of dust storms in the local area. They found that there were piles of dust where they shouldn╠t be. The board of health sent letters to the Cemex plant citing these infractions.
Cemex puts over 100 tons of Nitrogen, sulfur and carbon into the air each year, therefore it is subject to the regulations of the 1990 Clean Air Act. Cemex is required to monitor nitrous and sulfur oxides and carbon monoxide emissions. Only when those emissions exceed the federal standards is the company required to voluntarily report its data. Every 6 minute period where the opacity/ darkness of the smokestack is greater than 20%, or 10% for the clinker cooler component, must be reported to the state board of health. Between 1990 to 2002, Cemex reported 38 upsets, which were excused from violation or penalty.
The plant had not burned tires since 1993 when the director of the Boulder County Land Use Department determined that the 1989 special use permit to the cement plant remained valid. Despite the fact that it had been over 5 years since the plant had burned tires, it was in violation of the 1996 revision of the Land Use Code. The permit allows Cemex to store up to 150,000 shredded tires and 50,000 whole tires on site at any one time. It also designates the cement kiln plant as the "Lyons Rubber Recycling Facility". In November 2002, the Sierra Club filed a lawsuit against the director of the Land Use Department, the Boulder Count Board of Adjustment and Cemex challenging the current validity of the 1989 special use permit.
In March 2003, Boulder County District Judge ruled in favor of the Sierra Club, determining the lapse provision of the Boulder County Land Use Code does apply to Cemex╠s special use permit to burn tires.
In preparation for using tires as fuel, Cemex hired an independent analysis company, Air Pollution Testing Inc. to do a four day test burn of whole tires added to coal.
1.4 Consultation and Coordination
Residents of the local area that will be affected by the proposed tire burning. This includes local resident activist groups as well as the local ¤watchdogsË of the community.
Members of local environment groups e.g. Sierra club (Pam Milmoe and James Burrus).
State health department.
Environmental Health Department- already carried out some test on the plant.
Meetings and Consultation:
Meeting with the Sierra Club representatives to discuss the findings which they have discovered as they have heavily researched the subject heavily.
Consultation with Cemex themselves as they still have some details of the survey which they are withholding.
The Boulder County Health Department as they have also carried out some of the testing in the area and have reported on some of the health risks which it has caused.
Attend public meetings regarding the issue of the CEMEX plant. There are numerous opposition groups which have formed in the local area; these could provide insight into the public which need to be taken into consideration when drafting the plan. Agencies with expertise
Environmental Protection Agency
The consultation companies which carried out the testing on the plant.
North boulder environmental task force.
California integrated waste management board
Colorado department of public health
Boulder county health department (Ms. Gabi Hoefler) Tracking and recording public involvement
Attend the public meetings which are held regarding the project.
Send draft EIS to the public mentioned previously and record the responses and take into consideration the comments.
Send draft EIS to the fore mentioned agencies.
Use surveys and public participation tools to get further feedback from the public.
1.5 Existing Laws
Congress exempted ¤recycledË chemical wastes from control under RCRA, and EPA ruled that chemical wastes burned as fuel in industrial boilers, industrial furnaces, aggregate kilns and cement kilns are being ¤recycledË and thus are exempt from RCRA regulation.
The main pollutants which are controlled by air emission regulation are criteria pollutants (particulate matter, SO2, O3, NOx, CO and lead). Air emissions associated with the combustion of scrap tires may contain non-criteria pollutants. These pollutants are of greater concern to the public and regulatory agencies when combusting non-traditional fuels. Non-criteria pollutants are: polynuclear aromatic hydrocarbons, VOC╠s, dioxins, furans, total hydrocarbons, arsenic, cadmium, nickel, zinc, mercury, chromium, vanadium, HCl, benzene and PCB╠s.
Summary of the Recycling loophole in the Resource Conservation and Recovery Act
The Resource Conservation and Recovery Act (RCRA) was originally created "to protect human health and the environment by establishing a comprehensive regulatory framework for investigating and addressing past, present, and in some cases future environmental contamination at hazardous waste treatment, storage, and disposal facilities" (DOE). This legislation does not currently include the recycling of hazardous waste due to issues surrounding the wording of the act. This loophole has resulted in an endless stream of debates over the current legislation and the need to amend RCRA to explicitly include hazardous waste recyclers.
The concern over this legislation is a result of the double standard that allows recyclers to incinerate the same material as other facilities and not be held to the same emission or regulatory requirements. It is assumed that this discrepancy was created to encourage the reuse and recycling of waste materials in order to get a handle on the ever-increasing amounts of waste being generated. Unfortunately, this has lead to the practice of "Sham Recycling", where companies claim that they are using the hazardous waste as an energy source (recycling) to avoid regulation, even though they are simply serving as hazardous waste incinerators (Porter 50). The difference between the regulation of hazardous waste incinerators and recyclers is large enough to raise significant environmental concern. Recyclers pose a significant risk to public health and the environment due to the possibility of incomplete combustion and releases of hazardous materials.
RCRA specifically states that EPA has the jurisdiction to regulate "hazardous waste". Thus, regulation relies on the definition of "waste" and "discarded material". Recycled materials do not currently fit this definition since they are being reused and are thus not technically waste. Many members of the EPA see the need to expand these regulations, but note the importance of striking a balance between encouraging recycling practices and increasing regulations to minimize unsafe and irresponsible recycling. All previous attempts to regulate these recycling processes outside of RCRA have been relatively unsuccessful and hard to enforce.
Environmentalists view the RCRA loophole as being too lenient, perpetuating the inadequate and unequal standards for recyclers. Even members of the Hazardous Waste Treatment Council, an association of hazardous waste managers, encourage the regulation of recycling practices. This is due to the bad name that many companies are creating by practicing Sham recycling and creating some of the worst Superfund sites in America. Fortuna notes that "we have better controls on the storage of the waste than on the very practices that have led to uncontrolled releases at Superfund sites", i.e. recycling (Fortuna 373). Fortuna notes that this dilemma is due to the definition of the word "discarded". He states that "due to the long history of regulatory and judicial interpretation of these terms, we believe that amending RCRA's solid waste definition to explicitly include recycling practices other than those that are directly connected to the manufacturing process is the most prudent course to follow" (Fortuna 379). The only way to solve this problem is to implement these changes through RCRA itself, not through separate subtitles that would only cause additional confusion over implementation.
Various cement kiln associations that operate under RCRA argue that cement kilns are doing society a benefit by disposing of this hazardous material in a way that is not harmful. This beneficial practice is a result of the cement process itself. Marston states that standards are automatically upheld when making cement because the process requires the proper combustion of hazardous waste. He also notes that the Boilers and Industrial Furnace rules provide sufficient regulation for kiln recycling. This is despite the fact that they are much less stringent than those imposed on other hazardous waste incinerators.
There are a variety of opinions on whether hazardous waste recyclers should be covered under RCRA. The one thing that remains constant is the fact that RCRA currently does not regulate hazardous waste recyclers. A specific application of this loophole applies to this EIS. The Cemex Cement plant in Lyons, Colorado will be able to operate under lesser standards when it incinerates tires, which are considered to be a form of hazardous waste. This form of incineration is deemed to be a recycling practice and is thus not applicable to RCRA legislation.
Permit # 950PBO082 is the operating permit for CEMEX Inc, Lyons cement plant
This was issued on Feb 1 2000 and the last revision was Oct 2002.
The permit outlines:
Under Permitted Activities it is stated that ¤all conditions in this permit are enforceable by the US Environmental protection Agency, Colorado Air Pollution Control Division and its agents, and citizens unless otherwise specifiedË. There are a number of conditions which are only state enforceable, these are:
There is a memorandum of understanding which has been established between North Boulder County Environmental Health Community Task Force and CEMEX Inc. The Memorandum of Understanding constitutes a non-binding Agreement among the signatory parties to pursue a collaborative working relationship to improve health, environment, and the quality of life of the St. Vrain Valley.
Environmental Impact Assessment (EIA) can be used to evaluate the impacts likely to arise from a development which may adversely affect the environment. This process provides decision-makers with an indication of likely consequences of their actions. If properly utilized EIA will allow informed decision to be made on planning applications for potentially environmentally significant developments. One sphere which has necessitated the benefits of Environmental Impact Assessment has been waste management and in particular, incineration. The elements of waste incineration to be considered include waste management, energy recovery, assessing potential health risks from ash. These aspects encompass the significant concerns of public and private interest. The value of burning waste has been recognized to reduce and manage the quantity of surplus materials generated by households and industry. In 1999, U.S. residents, businesses, and institutions produced more than 230 million tons of municipal solid waste, which is approximately 4.6 pounds of waste per person per day, up from 2.7 pounds per person per day in 1960. The use of incineration can significantly reduce those numbers. The specific benefits of incineration include:
i. A reduction in the volume and weight of waste especially of bulky solids with high combustible content. Reduction achieved can be up to 90% of volume and 75% of weight of materials going into landfill.
ii. Destruction of some wastes and detoxification of others to render them more suitable for final disposal, e.g. combustible carcinogens, contaminated materials, toxic organic compounds, or biologically active materials that could affect sewage treatment works.
iii. Destruction of the organic component of biodegradable waste which when land filled directly generates landfill gas.
iv. The recovery of energy from organic wastes with sufficient calorific value.
v. Replacement of fossil-fuel for energy generation with consequent beneficial impacts in terms of the ╬greenhouse╠ effect. Although reliable data in quantifying these benefits is difficult to assess, they offer significant headway in determining the advantages of waste incineration. Positive and negative economic implications of waste incineration exist and can help calculating optimal economic scenarios. Although capital investment costs of incinerators are likely to be high, as are the social costs, which are ignored in this analysis, waste incinerators are capable offering significant cost reductions with in the waste management industry.
Incineration can greatly reduce waste volume and subsequently help to reduce the impacts associated with a continuing shrinking landfill space and accommodating rapidly expanding levels of municipal solid waste. However, public opposition to municipal waste conductors has grown and become more vocal recently. Criticisms revolve around airborne toxic emissions and ash. Municipal combustor ash consists of residuals that may contain considerable quantities of toxic materials including lead and cadmium, which at sufficient concentrations and improper disposal, can lead to surface and ground water contamination. A second public concern is human exposure to ash and the possible risks to area residents from ash dust. Various other criteria that regulations have included are whether a project is more than local importance in terms of size, if the project is intended to a sensitive location of scientific interest, or whether the project is likely to give rise to particular complex or adverse affects. With delayed construction, prolonged permit approval process and cancellation of some combustor plant, precedent illustrates that clear guidance for appropriately managing incinerator ash remains vague.
In the case of Seal Sands, Billingham, in north-east England, primarily as a result from public concerns, a full public Environmental Statement which included a quantitative risk assessment related to emissions from a chemical waste incinerator application was required by local planning authority. The Environmental Statement addressed the atmospheric environment and human health impacts by using emission dispersion modeling based on maximum concentrations of limit values similar to models used in this EIS. The quantitative risk form inhalation exposure was calculated with worse case exposure assumptions. Carcinogenic and non-carcinogenic risks were assessed by use of occupational standards and preferred linear models, accounting also for increased lifetime risk of developing cancer. Indirect exposure via the food chain was calculated using the U.S. Terrestrial Food Chain Model, also with worst case assumptions, and compared with acceptable daily intakes. The total incremental risk was calculated by the combined inhalation and ingestion patterns and compared with other lifetimes. The Environmental Statement was extended to address additive properties an additional 38 toxic compounds of concern, consideration of epidemiology evidence from other incinerators, considerations of risks to animals, and characterization and assessment of potential interactions between emissions from the proposed plant and other industrial plumes in the area. The Environmental Statement impressed planning inspectors with its highly encompassing attributes and was granted permission where other less encompassing assessments were not. Although examination of this particular incinerator application case explicitly highlights the role of risk assessment in such decisions in promoting public accountability and confidence, numerous similar empirical studies have been conducted and analyzed for effective environmental impact assessment. Similar studies, applicable to this EIS remain less encompassing and frequently altogether incomplete. This EIS was conducted incorporating all available comprehensive research, however it should be noted that certain risk assessments remain unclear because of lack of empirical data.
Recovering energy from waste incineration remains a significant potential energy source. Waste heat recovered to from combusting gases can be used to produce steam, and if available in sufficient quantities can be used in the plant itself, in other industrial processes, in residential and commercial facilities, for electricity generation or any combination of these. Again, a pivotal aspect of energy recovery potentiality is emissions. Various journal have given case studies of precedents with cost/benefit analysis and emission standard (set by such studies) for waste-to-energy plant. A waste-to-energy plant has to be built against some standard for the waste to burn and the raw gases it is to treat it. The key parameters are the net calorific value of the waste and the composition of the raw gases after consumption. Studies have shown that fuel from waste, typically has no more than half the calorific value of coal. While this is not the case for tire derived fuel (TDR) (TDR has a comparable caloric value to coal), it should be noted that as fuel, waste is not ideal and its benefits should be evaluated with this consideration. Moreover, to ensure the that emissions from waste-to-energy plants, pose no risk to human health or the environment, applying a combination of well-proven treatment technologies coupled with evolving chemical control systems will be needed. Waste incineration for energy recovery will require a high degree of control and predictability. Because of its relatively environmentally unknown properties, quantifying the impact both inherent and potential of waste incineration is complex.
There are three main markets for scrap tire use; tire derived fuel, civil engineering applications, and ground rubber. For the 270 million scrap tires produced per year on average, tire derived fuel remains the biggest end use for discarded tires. Through a process called pyrolysis, the tires are shredded and then baked in an airtight oven under extreme heat. When the gases are vacuumed out, they separate into oil, methane, and butane. This produces an estimated 7.7 pounds of energy-laden oil from a 20 pound tire. The oil can be mixed with gasoline to improve its octane rating and the methane and butane can be used to fuel the whole process. Many states are engaging in projects that involve recycled tires to help alleviate landfill capacity problems. In New Mexico, 3,000 bales of scrap tires will be used in a riverbank rebuilding program along the Pecos River. There is also a growing market in the Taos area, to use tires as the building blocks for home construction. Each tire is filled with 300 pounds of soil, and then coated in stucco to form a virtually indestructible material to build with. The tires act as thermal batteries to store and release heat as well. In Louisville, KY, tire chips from the 6.5 million Firestone tires recalled since August of 2000, are being used to cushion landfill liners, embed drainage pipes, and capture gas emissions in bioreactor landfills. This is an important discovery, not only for disposal of tires, but also for maintenance of existing landfills which have uncontrolled leachate. Road projects are one of the most common end uses for tires when they are recycled. Uses of scrap tires in road projects include, lightweight embankment fill to increase slope stability or reduce settlement, retaining wall backfill, and thermal insulation to limit frost penetration beneath roads. Recycled tires have other uses as well. In Wyoming, scrap tires are often used in landslide repair projects. In Illinois, tires are shredded and used to making running tracks at schools. In North Carolina, one company breaks scrap tires down and makes tires for golf carts and other off-road maintenance vehicles that are smaller than cars. Tires can be reused to construct artificial reefs, as boat bumpers on docks, and crash barriers at racetracks as well. It is important to understand that no one market can absorb all the scrap tires produced each year, it takes a combination of all markets to be as innovative with the abundance of tires as possible. As the market for recycled tires grows each year and as technology advances, new opportunities will certainly be explored and utilized.
The city of Lyons is located in Boulder County, Colorado. Lyons is a small community of 3865 residents, which occupy 687 housing units (American FactFinder, Census 2000). All of the residents are classified as living in a rural location with 70 residing on a farm. Seven miles from the Cemex plant is the city of Longmont with a population of 80,000 people. This area experiences a semi-arid climate. Lyons is situated on the east side of the Colorado Rocky Mountains. Rocky Mountain National Park and the Eagles Nest Wilderness Area are both Federal Class I designated areas located within 100 km of Cemex. Emissions from tire incineration are able to travel a distance of up to 47 miles, though the highest amount of fallout occurs within an 11-mile radius. Lyons╠ economy has relied on quarrying limestone in the past, which is now changing to tourism. The area is designated as a historic district with 15 Sand stone structures built between 1879 and 1927. The oldest homestead is now the site for many folk and bluegrass festivals.
This EIS has not addressed the impacts to water quality or plant life. This is because the use of tires for fuel has shown a decrease in emissions, and the effects on water and plants are so small that they are below detectable limits.
2.1 Workings of the Plant
Cemex blasts out 3 million tons/yr of limestone from Dowe Flats, a quarry just North of Highway 66. Stone is transported above the roadway on a 2 mile conveyor belt system in an enclosed tunnel to the kiln.
The dust is filtered from the kilns exhaust, collected in long, tubular fabric bags that prevent particulates from being emitted out of the plants smokestacks. Bag houses are periodically cleaned out and the dust recycled either back into the kiln or deposited into the quarry pits from which the limestone is taken.
Currently the CEMEX plant uses coal for 100% of its energy needs. The coal is added to the lower end of the kiln near the burner. If TDF were used along with coal, it would be added above the coal flame. Whole tires would be added at the feed end of the kiln with a double gate method so that burning occurs as the tires move down the kiln. ¤Whole tire use reduces coal used at the firing end of the kiln, but too many whole tires would provide too much heat in the kiln feed end (EPA-450/3-91-024 p.4-18).Ë Using tires as a fuel source would require an operator to watch the kiln to make sure that complete combustion is occurring, that the right amount of air is let in, and to add the tires. The installation of a whole tire feeder is an option.
3.1Summary. Cemex would be allowed to burn tires for energy in compliance with its existing permit. The existing permit issued by the Colorado Department of Public Health and Environment. Permit number 95O...
This will allow the plant to burn between 1.4 million tires per year, resulting in a 20% decrease in coal need. The tires, will be incinerated whole rather than shredded. The tires will be delivered to the kiln through a different passageway than the coal, to increase the burning temperature and reduce emissions.
Desire to implement tires into the cement process is due to the high rate of combustion relative to coal. Tire incineration results in approximately 15,000 BTU╠s while coal yields 6,000 to 13,500 BTUs per pound (EPA-450/3-91-024, p1-5).
Scrap tires are readily available and can be obtained through various commercial outlets eager to dispose of this resource. Additional benefits are encountered due to the use of whole tires in that they do not require additional energy expenses associated with the shredding process
3.2 Summary. Cemex would not be allowed to burn tires for energy under any circumstance. This would result in the use of 100% coal consumption for the plant╠s energy needs. There would be no comprehensive plan for implementing emission control devices. Present management emphasis would be on maintaining existing conditions in the cement kilns.
This alternative mitigates Cemex╠s current action outlined in Alternative A. Mitigations include the use of shredded or shredded/dewired tires as well as the inclusion of an electrostatic precipitator to reduce emissions. The plant would continue to supplement 20% of their energy needs with the use of tire derived fuel.
The use of shredded tires, in contrast to the use of whole tires in the incineration process, would dictate the substances which are combusted (i.e. rubber and/or metals) and therefore alter the emissions that would be released. Shredded/de-wired tires would result in a decreased amount of metal added to the incineration process, altering pollution levels. Installation of electrostatic precipitators would effectively regulate particulates (more so than lime scrubbers), the primary public and environmental concern of the tire derived fuel process. ¤Electrostatic precipitators (ESP) collect particulates from the mutual attraction between particles of one electrical charge and a collection electrode of opposite polarityË (Malcolm Pirnie Inc. 5-2). Implementation of shredded or shredded/de-wired tires with ESP will produce optimum environmental air quality standards and greatest energy efficiency.
Cemex will reduce their current management strategy to a 10% tire incineration procedure (700,000 tires per year). This will lessen the impact of Tire Derived Fuel (TDF), culminating in a compromise with surrounding environmental action groups. This alternative will adopt the use of whole tires in contrast to the preferred alternative which uses shredded or shredded/de-wired tires. The use of scrubbers of other emission control technologies will not be applied to this process.
This alternative is a complete reversal of existing management strategies. Cemex will altogether change from a coal-based incineration process to a tire derived fuel dependent cement operation. The emissions from this process will be vastly altered resulting in differing air quality.
The principle concern of this EIS is the impact to air quality and the emissions associated with the use of tires for fuel. This is of principle concern due to the nature of incineration and dispersion patterns of emissions. Evidence from previously published reports, obtained from the Colorado Department of Public Health and Environment and the EPA, establish a precedent for the potential incineration scenarios. Air quality emissions depend on many variables, each of which is estimated from figures within these reports.
Various assumptions are inherent in establishing the air quality effects of burning tires in reference to exclusively relying on coal for a cement plants energy needs. Determining factors for the results of each alternative rely heavily upon tests conducted through the Environmental Protection Agency as well as the Colorado Department of Public Health and Environment. These tests are used as a basis for predicting the effects on emissions at the Cemex Cement plant in Lyons, Colorado. These assumptions, along with others, are outlined below.
1) The data obtained by the EPA and the CDPHE is presumed to be factual. Controversy exists over current data, based on the notion that each test was performed in conjunction with the particular cement company that operated the kiln. It could be in the companies╠ best interest to attempt to discredit tests in favor of burning tires due to the large economic benefit of this resource in contrast to coal. This EIS analyzes a variety of tests conducted by these sources in an attempt to remove any discrepancies that might arise from the conditions outlined above.
2) If these reports are assumed to be entirely factual, additional concern arises due to the variety of tests that are consulted. Reports are often specific to kiln type. Fluctuations in incineration temperature, tire type, metal content of tires, etc., from plant to plant produce varying conditions. Analysis and application of appropriate variables were taken from these reports and used to predict most likely estimates for the Cemex Plant in Lyons.
3) The cement process, independently, removes many of the emissions that are created through incinerations and that are of significant public concern.
4) Several problems indicative to tire incineration pertain to upsets in the kiln such as derivation from stable temperatures, not in the incineration process itself.
5) Emissions depend on many variables, including but not restricted to the combustion temperature and nitrogen content and combustible carbon content of fuel.
6) According to industry standards, electrostatic precipitators have shown to be significantly more effective at removing particulates and other emissions specific to tire incineration than any other alternative technology at present.
7) All emissions considered fall under EPA guidelines.
1) Air quality statistics in this EIS are based upon research collected from various technical literature publications.
2) Consultation was conducted within various applicable industry and regulatory agency standards.
3) Primary research relied heavily on publications from the various above mentioned agencies, i.e., EPA, Boulder County Health Department, Colorado Department of Public Health and Environment, and Cemex Corporation.
4) Implementation of each of the alternatives is intended to be employed within the parameters of the applicable air permit (Permit Number 95OPBO082) (figure 4.0).
1) Background levels of pollution are assessed. EPA and Boulder County Health Department have standards for the surrounding area covering 20 key pollutants.
2) Regulations are reviewed. These include all state and federal laws that apply to the CEMEX plant.
3) Forecasting. Data is available for past burning practices which include when only coal was being burnt. Also data is available from other plants which are burning the proposed amount of tires.
4) Concentrations. Test burns have already taken place at the Cemex plant and that data will be made available in Early May. EPA recommended concentrations are also utilized.
5) Comparison with standards. Data from CEMEX is compared with EPA regulations.
6) Assess risk to human health. Compare EPA regulations as well as American Lung Association press releases with data.
4.1 No action. Allowing the plant to burn 1.4 million tires per year will result in a 20% decrease in coal requirements. Altering the composition of the fuel has significant impacts on air quality. Analysis of emission effects are in comparison to a cement process that uses 100% coal for its energy needs.
An environmental concern with the incineration of whole scrap tires is the elevated metal content. Scrap tires contain a significantly higher amount of metal than do shredded and de-wired tires because the radial wire is not removed before the incineration process.
Studies suggest that the particulate matter associated with using tires increases significantly when tires are incinerated whole. When feeding these tires into the kiln excess air enters the combustion chamber, resulting in increased emissions. Relative amount of air entering this process is a variable that is considered in this study but cannot be eliminated from the uncertainty of the data.
Trace metals levels illustrate varying degrees of concentrations when compared to bituminous coal. Tire content consist of decreased amounts of Aluminum, Antimony, Beryllium, Cadmium, Mercury, Tin, Uranium, Vanadium, while containing increased amounts of Chromium, Cobalt, Selenium, Zinc when compared to coal. (Figure 4.1.1).
A synthesis of the available data on tire derived fuel illustrates a decrease in most of the 6 EPA criteria pollutants (particulate matter, sulfur dioxide, ozone, oxides of nitrogen, carbon monoxide and lead). The most commonly tested pollutants include sulfur dioxide, nitrogen oxides, and carbon monoxide. Figure 4.1.2 compares the emissions of these three pollutants, demonstrating an increase in particulates, a decrease in SO2 and CO, and similar emissions of NOx. There is relative variability in these results when compared to other studies due to fluctuations in the amount of air in the kiln, as well as kiln temperature. In general studies conclude that tire derived fuel results in slight increases in particulates and deceased emissions of the three other key pollutants (EPA-450/3-91-024 p 24). Primary emissions of concern associated with coal, such as benzene and trichloroethane, are of significant importance to environmentalists. Estimates of the emissions and others are summarized in figure 4.1.3. Although this study uses natural gas as a baseline instead of coal, it demonstrates the miniscule differences in emissions in comparison to the incorporation of tire derived fuel.
4.2 Reversal of current permit. Cemex would not be allowed to burn tires for energy under any circumstance. The use of 100% coal consumption for the plant╠s energy needs would result in a net gain in emissions compared to a combination of coal and tire derived fuel. Pollution tests suggest that levels of particulates may be slightly lower using coal as the only source of fuel. However, sulfur dioxide, nitrogen oxides, and carbon monoxide are comparatively higher without the incorporation of TDF (Refer to figure 4.1.2). An additional problem indicative of Bituminous coal, when compare to TDF, is that it contains substantially higher moisture content resulting at a less efficient incineration temperature.
4.3 Implementation of shredded or shredded/de-wired tires in addition to with Electrostatic Precipitators. (Preferred alternative). The use of shredded or shredded/de-wired tires exhibits considerable improvements in decreased emission levels and greater energy efficiency.
Scrap tires contain a significantly higher amount of metal than do shredded/de-wired tires because the radial wire is not removed before the incineration process and this wire is problematic is in fuel applications. In the absence these metals, emission levels are improved. For a complete synthesis of applicable metals in tires see figure 4.2.1.
The use of shredded tires in the incineration process results in positive implications compared to the use of whole tires. The decreased size of shredded tires does not require large inputs of oxygen because small fragments of tires can be delivered to the kiln without necessitating the input hatch required for whole tires. Shredded tires will allow for more efficient incineration temperatures therefore maximizing performance and reducing pollution levels.
EPA criteria pollutants of concern are particulate matter, sulfur dioxide, ozone, oxides of nitrogen, carbon monoxide and lead. While tire derived fuel typically results in decreased levels of the criteria pollutants, it produces increased levels of particulate matter, a primary environmental concern. Air pollution control equipment typically utilized to remove particulate matter and reduce gaseous emissions. Optimal air quality levels can be attained with the implementation of electrostatic precipitators. ¤Electrostatic precipitators (ESP) collect particulates from the mutual attraction between particles of one electrical charge and a collection electrode of opposite polarityË (Malcolm Pirnie Inc. 5-2). Implementation of shredded or shredded/de-wired tires with ESP will produce optimum environmental air quality standards and greatest energy efficiency.
4.4 10% Tire Use. Cemex will reduce their current management strategy to a 10% tire incineration procedure (700,000 tires per year). This will lessen the impact of Tire Derived Fuel (TDF), culminating in a compromise with surrounding environmental action groups. This alternative will adopt the use of whole tires in contrast to the preferred alternative that uses shredded or shredded/de-wired tires. The use of scrubbers of other emission control technologies will not be applied to this process.
Emissions resulting from a mixture of 10% TDF tend to average the emissions when incinerating 20%TDF (Alternative A) or 100% coal (Alternative B). (Reference Figure 4.4.1 and 4.4.2)
4.5 The use of 100% tire derived fuel is often an attractive option for cement manufacturers because of their high energy content and its high rate of combustion. Resulting heating values for exclusive tire incineration are 15,000 BTU╠s per pound in comparison to coal at 6,000 to 13,500 BTUs per pound (EPA-450/3-91-024, p1-5). The primary problem with exclusive tire incineration is that too many whole tires would provide too much heat in the feed kiln.
Tests results of this alternative are currently unavailable due to the unfeasibility of this process. However, estimates of incinerating 100% TDF can be seen in Figure 4.5.1. Varying levels of estimated emissions of metals refer to slight increases in elements when compared to the use of natural gas. However, when compared to 100% coal use it is assumed that differences would decrease, due to the poor quality coal used in cement kilns.
Air Pollution and Health Impacts
Numerous studies have concluded that any long term or short term exposure to air pollution has negative effects on health. ¤It is possible that even low levels of air pollution have an effect on health, indicating that there is no threshold below which air pollution would have no effect on health (Brunekreef &Holgate 1).Ë The problem is determining which health impact was caused by which source of pollution. Automobiles, industry, and personal lifestyle all contribute to air pollution. Those who live in the city are exposed to more sources of air pollution than those who live in more rural areas. Because there are too many variables, there is not information available on how the quantity of polluted air breathed will contribute to illness, though there are set standards for chemicals that can be harmful to one╠s health. An increase of these chemicals in emissions can have an effect on the air quality of the surrounding area. The surrounding area in this case contains neighborhoods with children, adults, and elderly people. The elderly and children are especially susceptible to illness from poor air quality for their immune systems are weaker than an average healthy adult. Those who live closer to the site of incineration are more susceptible to illness from the emissions than those who live farther away. One thing that can be determined is that certain chemicals are known to have impacts on certain body organs. If a certain pollutant is found at a high level in an area, it may be possible to correlate this to an illness that has developed in a local neighborhood.
There is a decrease in the levels of nitrogen oxides and sulfur oxides by using tires as fuel instead of coal. Nitrogen dioxide has the capability of increasing lung infections through the impairment of alveolar macrophages and epithelial cells (5). Studies on rats have shown that prolonged exposure to nitrogen dioxide can cause destruction of peripheral airways. ¤Air pollution has been linked to asthmas, acute respiratory infections, allergies, and other ailments in children (Romm & Ervin 7)¸ Studies have confirmed the link between air pollution and increases in respiratory-related hospitalizations and visits to doctors (2)¸ Researchers observed a nearly linear relationship between particle concentrations in the air and increased mortality rates, indicating that even relatively low levels of air pollution fine particles contributed to adverse health effects.Ë
It is clear that air pollution has health impacts on humans, and that those who live closer to the source of pollution are more likely to experience the impacts. A reduction in the emission levels of pollutants could show an improvement in the health of those in the area. The lower the pollution levels, the lower the health impacts.
Aluminum: Suspected cardiovascular or blood toxicant, neurotoxicant, reproductive toxicant, and respiratory toxicant
Anthracene: Suspected endocrine toxicant, gastrointestinal or liver toxicant, and skin or sense organ toxicant
Arsenic: Recognized carcinogen and developmental toxicant, suspected cardiovascular or blood toxicant, endocrine toxicant, gastrointestinal or liver toxicant, kidney toxicant, neurotoxicant, reproductive toxicant, respiratory toxicant, and skin or sense organ toxicant
Ash: Suspected gastrointestinal or liver toxicant and respiratory toxicant
Benzene: Recognized carcinogen, developmental toxicant, and reproductive toxicant. Suspected cardiovascular or blood toxicant, endocrine toxicant, gastrointestinal or liver toxicant, immunotoxicant, neurotoxicant, respiratory toxicant, and skin and sense organ toxicant. High levels of exposure may result in death, drowsiness, dizziness, rapid heart rate, headaches, tremors, confusion, and unconsciousness.
Benzedrine: Recognized carcinogen, suspected gastrointestinal or liver toxicant, immunotoxicant, kidney toxicant, and neurotoxicant
Beryllium: Recognized carcinogen suspected cardiovascular or blood toxicant, gastrointestinal or blood toxicant, immunotoxicant, kidney toxicant, reproductive toxicant, respiratory toxicant, and skin or sense organ toxicant
Butadiene: Recognized carcinogen suspected cardiovascular or blood toxicant, developmental toxicant, gastrointestinal toxicant, neurotoxicant, reproductive toxicant, respiratory, and skin or sense organ toxicant
Cadmium: Severely damages lungs and can cause death, long-term exposure can cause buildup in kidneys and result in kidney disease, lung damage, and fragile bones. Recognized carcinogen. Exposure to high levels during pregnancy can result in changes in behavior of child and learning ability, and can affect the birth weight.
Carbon: No documented health effects
Carbon Monoxide: Recognized developmental toxicant suspected cardiovascular or blood toxicant, neurotoxicant, reproductive toxicant, and respiratory toxicant
Chromium: Recognized carcinogen (can cause lung cancer), suspected gastrointestinal or liver toxicant, immunotoxicant, kidney toxicant, reproductive toxicant, respiratory toxicant, and skin or sense organ toxicant. Breathing high levels can cause irritation to the nose resulting in a runny nose, nosebleeds, and ulcers and holes in the nasal septum.
Copper: Suspected cardiovascular or blood toxicant, developmental toxicant, gastrointestinal or liver toxicant, reproductive toxicant, and respiratory toxicant. Long-term exposure may cause irritation of the nose, mouth, and eyes, headaches, dizziness, nausea, and diarrhea.
Hydrogen: Suspected respiratory toxicant, meaning that exposure may produce irritation in the lungs or airway
Lead: Recognized carcinogen, developmental toxicant, and reproductive toxicant. Suspected cardiovascular or blood toxicant, endocrine toxicant, gastrointestinal or liver toxicant, immunotoxicant, kidney toxicant, neurotoxicant, respiratory toxicant, and skin or sense organ toxicant. May cause anemia and decreased memory, and a possible cause of increased anger, depression, and mental disorders.
Nitrogen Oxides: Low levels of exposure can irritate eyes, nose, throat, and lungs possibly causing one to cough and experience shortness of breath, tiredness, and nausea. Can result in fluid build-up in the lungs 1-2 days after exposure. High levels of exposure can cause rapid burning, spasms, swelling of tissues in throat and upper respiratory tract, reduced oxygenation of body tissues, and build-up of fluid in the lungs.
Oxygen: No documented health effects
Sulfur Dioxide: Exposure to high levels can be life threatening. Can cause burning of the nose and throat, breathing difficulties, and severe airway obstructions. Long-term exposure may cause changes in lung function. Asthmatics may be sensitive to respiratory effects of low concentrations.
Tetrachloroethane: Recognized human carcinogen (causes cancer), suspected developmental toxicant, gastrointestinal or liver toxicant, neurotoxicant, and respiratory toxicant. Can cause liver damage, stomachaches, and dizziness.
VOCs: Suspected carcinogen, developmental toxicant, and reproductive toxicant.
Zinc: Suspected cardiovascular or blood toxicant, developmental toxicant, immunotoxicant, reproductive toxicant, respiratory toxicant, and skin or sense organ toxicant.
Information on chemical profiles obtained from www.scorecard.org/chemical-profiles/ and www.atsdr.cdc.gov/toxfaq.html.
The health impacts in this EIS have had to assume that the following are true:
1) That the chemicals emitted as a result of coal and/or tire combustion are correct.
2) The effects of the chemicals on humans are factual.
3) That there is no way to determine, in numbers, the level of risk that a local population will experience with an increase or decrease in the chemicals in emissions.
4) That a reduction of harmful chemicals in emissions will benefit health or lessen risk.
1) Information regarding the health impacts from emissions for each alternative for this EIS was obtained through research of documents pertaining to the combustion of tires in cement kilns as a fuel source.
2) Research was applied to air quality changes for each alternative
3) Determine the health risks of the local population.
Alternative A will decrease coal use at Cemex by 20%. This means that 20% of their energy needs will be produced through the incineration of whole tires. Studies have shown an increase in carbon, hydrogen, tetrachloroethane, and 1,1,1-tetrachloroethane but a decrease in oxygen, nitrogen, sulfur, ash, moisture, volatile organic compounds (VOCs), cadmium, chromium, copper, lead, zinc, and hazardous air pollutants (HAPs) when replacing coal with tire incineration. The decrease of so many chemicals is favorable, but the increase of some chemicals in emissions is harmful. The effects of the listed chemicals are described in the chapter 5 summary.
Implementation of Alternative B would result in the use of 100% coal for Cemex╠s energy needs. 100% coal use would mean that there would not be a reduction of ash, nitrogen, sulfur dioxide, VOCs, Cadmium, Chromium, Copper, Zinc, Lead, and HAPs, however there would not be an increase in emissions of these chemicals, for this is the current form of energy used at the plant. The most common affect of these products of combustion is respiratory irritation, though each chemical varies in its affects. With the use of 100% coal there will be continued emissions of benzene and trichloroethane, both of which are of high concern.
Benzene: Recognized carcinogen, developmental toxicant, and reproductive toxicant. Suspected cardiovascular or blood toxicant, endocrine toxicant, gastrointestinal or liver toxicant, immunotoxicant, neurotoxicant, respiratory toxicant, and skin and sense organ toxicant. High levels of exposure may result in death, drowsiness, dizziness, rapid heart rate, headaches, tremors, confusion, and unconsciousness.
Trichloroethane: Suspected carcinogen. May feel dizzy, light-headed, experience unconsciousness, and/or low blood pressure.
The implementation of Alternative C includes the use of shredded and de-wired tires in addition to the use of ESP. This combination will provide optimum air quality in emissions and will decrease the health effects of many harmful chemicals. There may still be some health effects due to the emissions because combustion is still taking place, but the levels of exposure in this scenario would be the lowest.
The implementation of this alternative will have a decrease in the amount of carbon, hydrogen, and tetrachloroethane released from tire combustion; therefore the impacts of these chemicals will also decrease. The use of 90% coal would increase the levels of the chemicals emitted from coal combustion. More chemicals are decreased by the use of tires than by the use of coal, so this alternative will only decrease the levels of emissions by a little bit compared to the use of 20% or 100% tire combustion. Another factor in increased emissions from this alternative is the lack of scrubbers.
There are several other cement plants that use 100% TDF for their energy needs. Studies have concluded that the use of 100% TDF under proper management and operation can provide low levels of emissions. The harmful emissions from coal are eliminated. The increased emissions of concern are carbon and tetrachloroethane, yet the remaining emissions including nitrogen oxides, lead, etc. will all decrease. Lower levels of emissions mean cleaner air and healthier lungs, and fewer visits to the hospital due to any of the impacts as a result of air pollution.
Cement manufacturing is a power-intensive process in which fuel expenses can encompass over 35 percent of the total cost of operating the plant. The large expenditure required for fuel results in a significant motivation to reduce the cost of energy. The major incentive to implement tire derived fuel into the cement process is the economic benefit of using this relatively inexpensive and highly efficient form of fuel.
Examination of the benefit/cost analysis of each applicable alternative provides comprehensive insight into the economic efficiency of each method. Included in this report is the cost of installing the equipment as well as the price of the fuel, per amount of heating value that is derived.
Portland cement production requires between 4 and 6 million Btu╠s to make a ton of product (EPA-450/3-91-024, p. 4-1). Coal heating values range from 6000 to 13,500 Btu╠s per pound. Tires contain about 15,000 Btu╠s per pound (about 300,000 Btu╠s per tire).
This report assumes the following estimates with regards to profitability for each energy source:
1) While environmental concern was of primary concern in this EIS, consideration was giving to economic analysis with reference to benefits/cost ratio models for Cemex Corporation with regards to profitability for each energy source.
2) 5 million Btu╠s are required to produce 1 ton of cement.
3) Estimated Cost of Coal: $30.00 per ton
4) Estimated Cost of Coal: $30.00 per ton
5) Anticipated tire use by Cemex: 1.4 Million tires per year.
5) Preferred alternative╠s inclusion of costly electrostatic precipitators indicates negative economic gains for an indefinite short term payback period. Economic gains are assumes to accumulate after this period.
Estimated of economic benefits and costs were calculated using the following methodology. These statistics are based on current industry and regulatory standards, primarily from documents issued by the Colorado Department of Public Health and Environment.
Therefore, 500 pounds of coal will produce 1 ton of cement.
Therefore, 333 pounds of tires will produce 1 ton of cement.
Cemex would be allowed to burn tires for energy in compliance with its existing permit. This will authorize the plant to incinerate 1.4 million tires per year, resulting in a 20% decrease in coal need.
Replacing energy Cemex needs with 20% whole tires will eliminate 20,000 tons of coal at an average estimated cost of $30.00 per ton. (John Lohr, Plant Manager-Cemex)
Economic savings: $600,000
Cemex will be paid a disposal fee of $.50 per tire. Authorization to supplement energy needs with 20% tires derived fuel will result in disposal of 1.4 million tires per year.
Economics benefit: $700,000
Gross economic gain: $1,300,000
Additional cost: $400,000 (Whole tire feed system)
Total net economic gain under alternative A: $900,000
Cemex would not be allowed to burn tires for energy under any circumstance. This would result in the use of 100% coal consumption for the plant╠s energy needs. There would be no comprehensive plan for implementing emission control devices.
Supplying Cemex annual energy needs with 100% coal needs will necessitate approximately 1 million tons of coal at an average cost of $30.00 per ton. (Derived from 20% TDF figures, see alternative A).
Economic Cost: $30 million (no savings)
Shredded/de-wired tires would result in a decreased amount of metal added to the incineration process, altering pollution levels (Primary reason for preferred alternative). Installation of electrostatic precipitators would effectively regulate particulates (the primary public and environmental concern of the tire derived fuel process.)
Under this alternative Cemex would supplement 20% of the plant energy needs with TDF (1.4 million tires). The expected use of 1.4 million tires will weigh approximately 38 million pounds (based on average tire weight of 27 pounds). This approximation is equivalent to 19,000 tons.
Cost of for shredded tires per ton: $20.00 Economic Cost: $380,000 per year
Economic savings from 20% decrease in coal requirements: $600,000 Total gross economic gain: $220,000
Additional Costs: Electrostatic precipitator $1,000,000
Cemex will reduce their current management strategy to a 10% tire incineration procedure (700,000 tires per year). This alternative will adopt the use of whole tires in contrast to the preferred alternative which uses shredded or shredded/de-wired tires. The use of scrubbers of other emission control technologies will not be applied to this process.
Replacing energy Cemex needs with 10% whole tires will eliminate 10,000 tons of coal at an average estimated cost of $30.00 per ton. (John Lohr, Plant Manager-Cemex)
Economic savings: $300,000
Cemex will be paid a disposal fee of $.50 per tire. Authorization to supplement energy needs with 10% tires derived fuel will result in disposal of 700,000 tires per year.
Economics benefit: $350,000
Gross economic gain: $650,000
Additional cost: Whole tire feed system: $400,000
Total net economic gain under alternative A: $250,000
This alternative is a complete reversal of existing management strategies. Cemex will totally change from a coal-based incineration process to a tire derived fuel dependent cement operation.
Seven million tires would be required to fulfill 100% the plant╠s annual energy needs (based on 20%TDF estimates, see Alternative A). Cemex will be paid a disposal fee of $.50 per tire. Authorization to supplement energy needs with 100% tire derived fuel will result in disposal of seven million tires per year.
Economic benefit: $3.5 million
Additional economic savings: $30 million (eliminating coal expenditures).
Gross economic gain: $33.5 million
Additional Cost: $400,000 (whole tire feed system)
Total net gain: $31,350,000
(Note: 100% TDF is problematic because of excessively high incineration temperatures, however, this report recommends further research and development be employed to increase tire ratio, without environmental compromise)
Analysis of air quality, heath, and economic impacts, this EIS recommends selection of Alternative C. The preferred action incorporates 1.4 million tires per year into the incineration process, replacing 20% of Cemex╠s energy needs. Mitigations included in this process are the use of shredded or shredded/dewired tires in addition to an electrostatic precipitator (ESP).
The use of Tire Derived Fuel does not have any significant affects on air quality, although minor increases are evident in zinc and particulates. The health effects of zinc are not considered significant enough to warrant the exclusion of Tire Derived Fuel. Detrimental effects due to the minor increases in particulates will be minimized through the implementation of an ESP.
Economic benefits dramatically increase with the use of Tire Derived Fuel. High prices of coal coupled with the monetary benefits of accepting tires encourage Cemex to implement this alternative source of fuel. Although the cost of electrostatic precipitators is high, the economic benefit of using tires will make up for the cost of implementing this control after a few years.
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