Table of Contents: Cemex
Corporation EIS
CHAPTER 1 INTRODUCTION....................................................................... 3
General Assumptions:................................................................. 3
General Methods:....................................................................... 4
1.2 Purpose and Need for Proposed Action............................................. 4
Issues and Concerns:.................................................................. 4
1.3 Project History............................................................................... 5
1.4 Consultation and Coordination......................................................... 6
Public consulted:........................................................................ 6
Meetings and Consultation:......................................................... 6
1.5 Existing Laws................................................................................. 6
Summary of Resource Conservation and Recovery Act.................... 7
Permit summary:....................................................................... 7
1.6 Environmental Impact Assessment of Waste Incineration.................... 8
1.7 Alternatives for Tire Disposal......................................................... 10
Chapter 2 Affected Environment.................................................. 11
2.1 Summary..................................................................................... 11
2.2 Workings of the plant.................................................................... 11
2.3 The Kiln....................................................................................... 11
Chapter 3 Descriptions of
Alternatives...................................... 12
Summary.......................................................................................... 12
3.0 Comparative Table........................................................................ 12
3.1 Alternative A: No Action................................................................ 12
3.2 Alternative B: Reversal of Current Permit......................................... 12
3.3 Alternative C: Implementation of De-wired and Shredded
Tires. (Preferred Alternative) 12
3.4 Alternative D: 10% Tire Use.......................................................... 13
3.5 Alternative E: 100% Tired Derived Fuel........................................... 13
Chapter 4: Environmental
Consequences: Air Quality............... 14
Summary.......................................................................................... 14
4.0: Air Quality Assumptions and Methods............................................ 14
Assumptions............................................................................ 14
Methods:................................................................................. 15
4.1 Alternative A Impacts.................................................................... 15
4.2 Alternative B Impacts.................................................................... 16
4.3 Alternative C Impacts.................................................................... 16
4.4 Alternative D Impacts.................................................................... 17
4.5 Alternative E Impacts.................................................................... 17
Chapter 5 Health Risk
Assessment................................................. 18
Summary.......................................................................................... 18
Chemical Compounds Emitted from Tire and/or Coal
Combustion. 18
Assumptions............................................................................ 20
Methods.................................................................................. 20
5.1 Alternative A Impacts.................................................................... 20
5.2 Alternative B Impacts.................................................................... 21
5.3 Alternative C Impacts.................................................................... 21
5.4 Alternative D Impacts.................................................................... 21
5.5 Alternative E Impacts.................................................................... 21
Chapter 6 Economic Impacts........................................................... 23
Summary.......................................................................................... 23
Assumptions:..................................................................................... 23
6.1 Alternative A Impacts: No Action.................................................... 24
6.2 Alternative B Impacts: Reversal of Current Permit............................. 25
6.4 Alternative D Impacts: 10% Tire Use.............................................. 25
6.5 Alternative E Impacts: 100% Tire Derived Fuel................................ 26
6.6 Analysis of Preferred Alternative...................................... 26
Works Cited and Referenced.......................................................... 28
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.
General Assumptions:
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
“watchdogs” 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 “recycled” 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 “recycled” 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 summary:
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
specified”. 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).” 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 polarity” (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 polarity” (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).” 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.”
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.
1)
Coal:
Therefore,
500 pounds of coal will produce 1 ton of cement.
2)
Tires:
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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