Hazardous Waste

It was inevitable. Like chocolate and peanut butter. Like rats and the plague.

Two notoriously polluting industries find solace in each other's ability to scratch each other's dirty, irritating itches.

Cement plants are always looking for ways to get paid to burn other people's garbage. It takes a lot of energy to fire a 20-foot flame at 2000 degrees 24/7 in order to cook rock. It also takes a lot of "additives". That's why cement plants started burning other companies' hazardous wastes in the 70's and 80's. Because of a loophole in federal law, 50-year old cement plants with no modern pollution controls were allowed to charge for burning highly toxic wastes from refineries and chemical plants that were otherwise supposed to be going to fully-regulated hazardous waste disposal sites.

But those official sites cost more to use, and the cement plants cost so little. That's right, cement plants charged these polluters to dispose of their wastes, but not more than the incinerators or landfills with all the bells and whistles of "regulation." In this way, cement plant operators double dip – they don't have to shell out as much for fuel they'd have to buy, and they get paid a profit to be a Dispos-All for industry. And by the way, industry calls this "recycling."

Because of the persistence of Downwinders at Risk and other citizens' groups, this loophole has been slowly but surely closing, meaning less and less hazardous waste is being burned in US cement kilns. From a peak of almost 30 kilns burning toxics in the in the 1990's, we're now down to less than a dozen. But to take the place of this lucrative lost market, cement plants across the country are turning to "non-hazardous" waste to burn. Tires, but also municipal garbage, plastic wastes, used oils, shingles, car parts and other kinds of wastes. TXI's new permit allows the burning of a dozen different kinds of industrial wastes at its huge kiln in Midlothian. 

While these wastes are classified as "non-hazardous," when they come in the front gate of a kiln, it turns out they can release a lot of toxic pollution when they're incinerated. Metals like lead and cadmium and arsenic that don't burn (consult your High School physics textbook) are present. So are PCB's that have Dioxin. But burning plastic or chlorinated wastes means you can generate Dioxins even without having them present in the wastes to begin with. There's also Mercury in some of the wastes from cars that TXI and other kilns wants to burn.

So you have the release of exactly the same kinds toxic pollution you were concerned about with the burning of officially-classified hazardous wastes. But now, it's taking place "legally," – or at least it is until the law hasn't catches-up with the consequences of this kind of low-rent disposal operation. Have a waste you want to get rid of? Send it to your local neighborhood cement plant. They'll burn anything.

Enter the Natural Gas industry. They've been getting a lot of bad PR lately about their own waste problems. They have billions of gallons of what they like to call "fracking fluid,"  and what the rest of us would call "hazardous wastes" that's so toxic it must be disposed of in a deep underground injection well after only being used once, isolated from the rest of the earth's environment forever.  But because of some well-placed loopholes, this "fracking fluid" is not considered "official" hazardous waste under federal rules. It will just unofficially injure you with its toxins.

As it turns out, injecting billions of gallons of "non-hazardous" toxic liquid under extremely high pressure near deep underground faults is a sure way to generate earthquakes. And that's what's been happening. Not only in North Texas, but other places where there are lots of injection wells. There was another small one last night in Midlothian, right down the highway from a large deep injection well near Venus. Along with the fact that most fracking fluid cannot be or is not "recycled" now and can  only be used once before disposal, the fracking fluid generated by the gas industry has turned into an embarrassing sore point.

If only there was some other way the gas industry could dispose of their drilling wastes. If only they could appear to be more environmentally-friendly and save money at the same time……

And there you have the genesis of a happy marriage made in polluter heaven. I have a facility that needs stuff to burn and mix, and I'm not that particular about what the stuff has in it. You have lots of stuff that needs to be burned, er, "recycled" and you spend less when you send it to a facility like mine not specifically built to do that job. Everybody wins!

"The use of drilling wastes and muds is most preferable in cement kilns, as a cement kiln can be an attractive, less expensive alternative to a rotary kiln. In cement kilns, drilling wastes with oily components can be used in a fuel-blending program to substitute for fuel that would otherwise be needed to fire the kiln.

Cement kiln temperatures (1,400 to 1,500 degrees C) and residence times are sufficient to achieve thermal destruction of organics. Cement kilns may also have pollution control devices to minimize emissions. The ash resulting from waste combustion becomes incorporated into the cement matrix, providing aluminum, silica, clay, and other minerals typically added in the cement raw material feed stream.

Recent studies have shown that it is feasible to use such drilling waste as substitute fuel in a cement plant. The drilling mud can be processed by a centrifuge to separate remaining water, compressed by a screw into a solid pump and conveyed.

The cement companies can contribute to sustainability also by improving their own internal practices such as improving energy efficiency and implementing recycling programs. Businesses can show commitments to sustainability through voluntary adopting the concepts of social and environmental responsibilities, implementing cleaner production practices, and accepting extended responsibilities for their products."

For veterans of The Cement Wars of the 1990's this rhetoric is certainly recycled. Cement Plants are Long, Hot and Good for America! Cement plants are the best disposal devices ever. They just make everything go "poof." That's why they were built specifically to dispose of wastes of all kinds  – oh wait. nope. They were built to make cement. But how great is it that they can make an entire sideline business out of dealing with, and spewing toxic chemicals into the environment?

Even though the specific article deals with the Middle East, is there any question that a cement plant in Texas or Pennsylvania, or Ohio won't try to make the case for accepting drilling wastes, if they haven't already? The permit modification TXI received to burn plastics and car wastes from the State of Texas required no public notice at all. Citizens only found out after the fact. There are only about a dozen players left in the international cement market. If they're discussing this in Egypt and Saudi Arabia, chances are they're talking about it in Zurich, Heidelberg, and Midlothian too.

Developments like this are why its important to tell the EPA it's making a big mistake to delay and change its cement plant toxic emission rules. The industry's "inputs" are changing rapidly. Two years is too long. We need the protection of those new rules now.  If you haven't already clicked and sent EPA an e-mail saying you oppose this delay, the "official" comment period is over, but it couldn't hurt for the folks in DC to see your "unofficial" opposition.

It's also a lesson in why "everything is connected." Don't live near a gas well? If you live in DFW, chances are you live downwind of a kiln that could be burning the wastes of gas wells.