Background - Neil Carman (Oct 2000)I served as a State of Texas air pollution control inspector of industrial plants with the Texas Air Control Board's Odessa Regional office for 12 years (1980-92). Technical experience emphasized compliance investigations of industrial plants and their emissions; these large plants were also industrial waste generators of liquid fuels. As a state government official, my duty included conducting state air pollution inspections at several hundred facilities including Portland cement kilns.
During my tenure with the state air pollution control agency, I inspected a large cement manufacturing facility with two large kilns that produced Portland cement, and based on my state experience and knowledge of these facilities, I offer technical grounds to oppose the incineration of industrial and other industrial wastes such as Cemfuel in cement kilns.
It is a generally recognized regulatory fact that high levels of particulate matter emissions are authorized from permitted cement kilns due to the inherently dusty nature of the manufacturing process in addition to the economic cost of controlling such emissions, and particulate emission rates and annual volumes tend to be significantly higher from cement kilns as a result than that allowed from any type of commercial incinerator facility. I base this on direct experience and observations in the field in addition to regulatory knowledge over the past 20 years.
In addition to other state enforcement cases, my work involved legal actions against several waste incineration facilities that included lawsuits brought by the State of Texas' Attorney General Office Environmental Protection Division. Since 1992, my capacity with Sierra Club has involved preparing technical evaluations of commercial waste incineration plants in a broad variety of facilities including medical waste incinerators, municipal waste incinerators, hazardous waste incinerators, hazardous waste burning cement kilns, waste burning light-weight aggregate kilns and industrial waste incinerators operating in Texas and more than a dozen states in the USA. Based on this extensive experience and knowledge of significant non-compliance issues, I maintain a professional skepticism over the ability of these facilities to operate in continuous compliance during industrial toxic waste treatment operations and have serious concerns about the public health impacts that these toxic air emissions have had on communities living downwind of these plants.
Since 1992, I have worked with many communities across the USA to oppose the incineration of industrial wastes similar to the cemfuel and other toxic waste that Castle Cement is seeking to burn in its new kiln. Cement kilns in the USA call waste incineration "recycling" but citizens prefer to term it "sham recycling" since it turns the cement companies into sham incinerator operators in essence.
NEIL J. CARMAN, PH.D.