The cement industry is trying to rebut Environmental Protection Agency’s (EPA) claims that proposed air rules for the sector will boost the agency’s environmental justice goals by cutting air emissions, with the industry claiming a related EPA waste definition rule would increase health hazards by diverting more waste tyres to landfills.
The Cement Kiln Recycling Coalition (CKRC), a trade association representing all US cement manufacturers that recycle wastes in kilns, says in recent comments filed with EPA that the air and waste rules combined "will not provide environmental justice benefits when applied to the cement industry. To the contrary, they will significantly increase the environmental burden on minority communities." CKRC filed its comments in response to a major EPA package of air and waste rules.
In April, the EPA proposed a maximum achievable control technology (MACT) air standard for boilers and a separate new source performance standard (NSPS) for commercial and industrial solid waste incinerators (CISWI). The EPA also proposed a Resource Conservation & Recovery Act (RCRA) solid waste identification (SWI) rule to clarify which non-hazardous secondary materials are solid wastes when burned in combustion units. CKRC is seeking a meeting with EPA to discuss its comments but no meeting has been scheduled. The RCRA proposal will determine whether materials are fuel and can be burned in kilns subject to the MACT, or whether they are solid waste subject to the more stringent NSPS for CISWI units.
Industry’s equity concerns with the SWI proposal come as the industry is fighting EPA’s claim that it faces a tight legal deadline to finalise both the NSPS and MACT rules. The EPA recently won a court-approved extension to complete the air rules next January, but still plans to finalise the SWI rule by 16 December.
CKRC in its comments on the rule-making package says that the ability of industry to burn millions of scrap tyres rather than divert them to landfills is a "compelling" reason to exempt cement kilns from the CISWI rule. The group also argues that despite EPA Administrator Lisa Jackson’s stated desire to boost the agency’s focus on environmental justice communities, the rules would increase pollution from landfills near such communities.
CKRC also faults EPA for looking at the equity impacts of the rules broadly, across all sources, rather than a more narrow industry-specific look, such as at cement kilns.
The cement industry is clearly keen to continue providing a valuable service of safely disposing of waste tyres in cement kilns. GCC Energy, for example, plans to begin shredding tyres at El Paso County dump by December, eventually using the tyre chips as fuel for the company’s Pueblo facility. The Colorado Department of Public Health and Environment has approved the permit request for the company to recycle tyres, now it awaits EL Paso County commissioners’ decision whether to issue a permit. GCC estimate that the stored tyres could provide fuel for the cement plant for the next 10 years.