Assurances from Trident plant manager not enough

By Colette Kirchhoff guest columnist

I am among the 92 physicians concerned about the draft permit issued by the Montana Department of Environmental Quality (DEQ) to allow Holcim to save money by burning more than 1 million waste tires each year in its Trident cement plant. We believe Holcim's tire burning proposal poses greater human health risks and environmental impacts than have been revealed by Holcim so far. We further believe that, before granting any permit, the DEQ should require a full Environmental Impact Study (EIS) that demonstrates Holcim's tire burning will not adversely affect human health or the natural environment. Scientific data show that burning tires emits pollutants that endanger the health of living things. We believe the burden of proof must be on Holcim to show that, in its quest to save money by burning waste tires, it will cause no harm and instead will benefit the environment and the people of this valley.

Even without burning tires, cement kilns are the third largest emitters of dioxins in our country. A byproduct of combustion, dioxins are the most poisonous manmade organic chemical known. When exposed to dioxins in air, water and food, human beings show increased incidence of birth defects, developmental delay, heart disease, diabetes, low IQ and cancer. The earlier in life one is exposed to dioxins, the more severe are the consequences on one's health. Because dioxins are stored in fat tissue, mothers and children are at highest risk: Dioxins that accumulate in a mother's fatty breast tissue are excreted via breast milk to infants.

Based on Holcim's permit application, DEQ has written an Environmental Assessment (EA) of the proposal. But the EA is not based on a full and accurate study of likely health and environmental effects of its proposal to burn more than 1.3 million waste tires each year. Nor does it address the plant's problems complying with current air quality standards. In short, the EA provides little reason to believe that Holcim will protect local health and environment without being compelled to do so. That's why completing an EIS on the proposal is important: An EIS will yield more accurate pictures of the potential impacts of proposals than the environmental assessment does.

Holcim's own records show that it exceeded the acceptable standards for uncontrolled emissions in 2002, when it reported more than 20 days of uncontrolled pollutant releases. That means Holcim's Trident plant released an untold amount of pollutants into the air -- our air -- pollutants such as dioxins and heavy metals. The tire burning proposal is even more worrisome in light of Holcim's current, documented noncompliance.

Furthermore, Holcim's own 2001 "Enlibra Case Study" showed that negative health effects of tire burning are not restricted to increased dioxin emissions. The study indicated that when tires are burned in a wet kiln (like the one at Trident), dioxin emissions increase by 28 percent. But this increase is exceeded by anticipated increases in lead emissions (380 percent) and PCB emissions (3,100 percent). Both lead and PCBs have been proven to have harmful effects on human health.

In addition, a top toxicologist alleges that Holcim's application greatly underestimates the toxicity of the emissions that will result from burning tires. Dissatisfied with information provided by Holcim, the local citizen group Montanans Against Toxic Burning (MATB) hired Thomas Webster, a toxicologist from Boston University, to study the health risks of Holcim's tire burning proposal. Webster found that Holcim's application underestimated the risk of dioxin ingestion (exposure to dioxins in food) by an incredible 1,000 times!

Internal DEQ documents show that state officials are concerned that Holcim has failed to answer tough questions. In a memo dated Dec. 17, 2002, DEQ Air Quality Supervisor David Klemp stated that, despite "the added expense and effort," Holcim should provide a full EIS. He concluded by saying he and his staff "feel strongly that this is the right thing to do."

The fact is, heavy metals such as mercury and lead contained in waste tires are not destroyed at any temperature. Exposure to lead causes nervous system toxicity, with documented increases in attention deficit disorder, autism, and lowered IQ. The April 17 issue of the New England Journal of Medicine concluded that there is no such thing as a safe amount of exposure to lead. In burning waste tires, heavy metals and dioxins are in fact recycled, as claimed by Holcim's representatives -- but in a negative sense, because these pollutants return by way of the smokestack into the air we breathe, eventually settling into the earth we farm, the water we drink, and the food we eat.

Assurances and editorials from Holcim's Trident plant manager are not enough to guarantee that Gallatin Valley's clean and healthy environment will remain so once tires are burned in the Trident kilns. Please make your concerns known before May 9 by writing to David Klemp, Montana Department of Environmental Quality, P.O. Box 200901, Helena, MT 59620-0901. DEQ is conducting a public hearing on the issue at the Manhattan Elementary School tonight at 7 p.m.

Colette Kirchhoff, M.D., writes on behalf of Montanans Against Toxic Burning.