Major Misrepresentations of "Myth/Fact" Documents

Opponents of energy recovery in cement kilns have circulated "Myths/Facts" documents about cement kiln recycling technology that misinform the public. Most of these documents, or excerpts from them, have their roots in an outdated publication by the National Citizens Alliance (NCA). NCA conducted a public relations campaign against energy recovery from hazardous waste in cement kilns. A significant portion of NCA's funding at the time "Myths/Facts" was published was secretly funneled to the organization by members of the Association for Responsible Thermal Treatment (ARTT), a defunct group that fronted for several commercial hazardous waste incineration companies, most of which no longer exist, who regarded cement kilns as a competitive threat. ARTT was formed as a vehicle for publicly discrediting energy recovery in cement kilns by any available means. The Cement Kiln Recycling Coalition (CKRC) developed the following document to correct the misrepresentations that emanated from ARTT's and NCA's dishonest practices and false claims.

NCA has Incorrectly Alleged that Energy Recovery in Cement Kilns Does Not Conserve Natural Resources

• Since 1991, cement kilns have recovered energy from approximately 1 million tons per year of hazardous waste. Cement kilns also recover energy from other energy-bearing wastes such as scrap tires. About 50 million tires per year are consumed as fuel in US cement kilns. The cement industry eliminates from the environment millions of tons of waste per year by burning it as fuel in its kilns that operate at over 3000 degrees F---almost one-third the temperature of the surface of the sun.
   
• Hazardous waste used as fuel in cement kilns is a one-for-one replacement for coal, the primary fossil fuel used in kilns. Burning 1 million tons of waste per year in cement kilns conserves 1 million tons per year of non-renewable fossil fuels.

NCA Incorrectly Alleges that Cement Kilns Emit Higher Levels of Metals and Chlorine than Incinerators

• The fuel-quality hazardous wastes burned for energy recovery in cement kilns have significantly lower levels of metals and chlorine than the wastes that are burned for destruction in incinerators. In addition, the Environmental Protection Agency (EPA) stringently regulates emissions of hazardous air pollutants from hazardous waste-combustors. EPA has developed limits to control emissions at protective levels representing the performance of the best control technologies in the industry. These Maximum Achievable Control Technology (MACT) standards regulate emissions of many hazardous air pollutants, including metals and chlorine.

NCA Incorrectly Alleges that Cement Kilns are a Major Source of Dioxin

• The cement industry has been very successful in reducing its emissions of dioxins/furans. The industry invested aggressively in research to understand the nature of dioxin formation in combustion emissions and succeeded in learning how to control and reduce those emissions. As a result, since 1990, dioxin emissions from kilns that recover energy from hazardous waste have been reduced by 97%. The industry's research, which was corroborated by EPA research, also revealed that the formation of dioxins is a post-combustion reaction that is unrelated to whether a kiln uses hazardous waste as fuel. (For more information on the significant dioxin reductions achieved by cement kilns, click here).

NCA Incorrectly Alleges that Cement Kilns are not Regulated as Stringently as Incinerators or Other Industries

• The combustion of hazardous waste in cement kilns has been regulated by USEPA since 1991. No other form of combustion is regulated more stringently than the use of hazardous waste as fuel in cement kilns.
   
• In September 1999, under the Clean Air Act, EPA published new, more stringent regulations governing hazardous waste combustion. These rules, called Maximum Available Control Technology (MACT) standards, were developed by EPA over a 6-year period. They contain strict technology-based limits on emissions of particulate matter and also of hazardous air pollutants, including metals, dioxins, chlorine, hydrochloric acid, carbon monoxide and hydrocarbons. EPA updated those standards in a revised MACT rule finalized in 2005.

NCA Incorrectly Alleges that Cement Product is Affected by Recovering Energy from Waste Quality Fuel.

• The quality of cement product and the environmental properties of cement kiln dust by-product are unaffected by the type of fuel used to fire the kiln. EPA considered the question of cement product quality in 1995 and concluded that "It is not substantiated that burning WDF increases risks posed to end users of cement" [EPA response to TSCA petition in Fed. Reg. Doc July 24, 1995]. EPA also extensively investigated cement kiln dust and concluded in 1993 that cement kiln dust is a high volume/low toxicity material that is not significantly affected by the use of hazardous waste as fuel. (Report to congress on Cement Kiln Dust, Vol. 1 December 1993) The Rutgers study cited in the Myths/Facts document was funded by ARTT and has been technically discredited by CKRC and its conclusions were rejected by EPA.

NCA Incorrectly Alleges that Energy Recovery from Waste Increases Risks to the Environment.

• Owners of cement kilns that use hazardous waste as fuel and government agencies have conducted numerous risk assessments nationwide that have examined and evaluated every conceivable direct and indirect human exposure pathway to emissions from kilns. At least one of these risk assessments also factored-in the aggregate effects of multiple cement plants and other industries operating in a single geographic region. The results of every risk assessment have shown that the use of hazardous waste as fuel in cement kilns poses no increased risk to human health and the environment. (See Screening Risk Analysis for the TXI Facility In Midlothian, Texas) Additionally, before promulgating its latest MACT standards, EPA conducted extensive risk analysis to evaluate the protectiveness of those standards as well as current emissions levels. EPA concluded that current operations pose no unacceptable risk to human health and that future operations under the new regulations also will pose no unacceptable risk. (HWC MACT Final Rule - September 30, 1999: 52828 Federal Register Vol. 64 No. 189)