At Cement America's International Cement 1998 conference in Salt Lake City, Dr. Kathryn Kelly of Delta Toxicology gave a presentation on the status of final Resource Conservation and Recovery Act (RCRA) Part B permits, entitled "Five Years, One Permit."

In the approximately five years since the U.S. Environmental Protection Agency (EPA) announced its intention to "fast-track" worthy permittees, only one Boilers and Industrial Furnaces (BIF) facility (Ash Grove Cement's Chanute, Kan. plant) had been awarded a final permit to burn waste fuels.

"This has been a better year," Kelly reported recently, as we approach the next presidential election. "In addition to the Chanute facility, Ash Grove's Foreman, Ark. plant; TXI's Midlothian, Texas operation; and Lone Star's Cape Girardeau, Mo. plant all received final permits. In addition, Chanute announced plans to expand its facility, requiring a permit modification that is expected in the spring."

According to Don Davis of the Cement Kiln Recycling Coalition, this leaves 13 additional facilities seeking final permits, down from an original 32 applicants originally filing Part A applications in 1991.

Kelly, who worked on the risk assessments for all four permitted facilities, cites some common elements among them. "First, all had very dedicated senior-level management involvement," Kelly explained. "Second, there was an unusual breadth and depth of staff expertise at each of the permitting agencies [in EPA Region 7, Texas, and Arkansas].

"Strong agency expertise in the impacts of cement kilns burning hazardous waste allows the permit writers greater confidence in answering questions at public hearings and in signing off on the final permit. Finally, none of the risk assessments followed what is known as the EPA Region 6 guidance."

Kelly also noted that other EPA regions have determined that this draft guidance substantially increases the workload, and therefore the costs and delays associated with preparing the risk assessment, without increasing the accuracy of the results.

Her colleague, Stephen Minter of Scientific Resources, noted, "More importantly, the guidance does not address any of the issues that led EPA's Science Advisory Board to declare the original guidance 'not ready for prime time' in 1995. We don't use it, nor do we recommend that any company expend the additional funds necessary to complete it or that any permitting agency expend the resources necessary to review it. Instead, each facility risk assessment was completed with a combination of methodologies agreed to between the facility and the permitting agency, generally some combination of the EPA 1994 guidance and that of North Carolina."

Kelly, however, is more optimistic about the future. "The more the cement plants are studied, the clearer it becomes that these facilities are environmentally the best alternative we have for managing many types of hazardous waste," she said. "Now that this is becoming more widely understood and the facilities continue to show an excellent record of performance, I can see a day where cement kilns will be fast-tracked for permits instead of taking five or six years and hundreds of thousands of dollars to go through the permitting process."

Kelly also sees help from the outside. "Greenpeace has announced a campaign to curb use of fossil fuels. The National Academy of Sciences just published a report encouraging the use of life-cycle analysis in analyzing total product impacts, which follows a product from mining of the raw materials through final disposal. Organizations as divergent as these are advocating approaches that would encourage the increased use of waste fuels in cement kilns. This reinforces why the use of waste fuels is becoming increasingly understood to be an environmentally good story, relative to our other options for managing these wastes."

As part of its mission for the 21st century, the Cement Industry Environmental Consortium (CIEC) has embarked on a mission to reduce nitrogen oxide (NOx) emissions from the typical precalciner kiln to 2 lb per ton of cement clinker produced.

The organization's vision is to develop innovative and cost-effective technologies and processes that assist in the mitigation of environmental impacts from industrial operations, such as cement manufacturing.

Since its inception in 1992, CIEC has successfully implemented such technology through the development of its Biosolids Injection (BSI) program. This patented technology uses the naturally occurring ammonia present in treated municipal sludge, which, when introduced into specific point in the cement manufacturing process, significantly reduces NOx emissions from the pyroprocess system.

To publicize its objective of 2 lb per ton of clinker, CIEC has incorporated its 2-lb goal into its new logo, in the form of "010100>2#/t".

CIEC is a public-private partnership whose stakeholders include Southdown's Victorville, Calif. plant; Mitsubishi Cement Corp.'s Lucerne Valley operation; TXI Riverside Cement Co.'s Crestmore and Oro Grande plants; the Mojave Desert Air Quality Management District in Victorville; and the California Trade & Commerce Agency.

The deadline for the Portland Cement Association's (PCA's) 1999 Best Safe Practices photography contest is Nov. 30.

The goals of the contest are to honor innovative practices, programs, and projects throughout the industry; communicate these ideas to others in the North American cement industry; and raise the profile and importance of the safety programs both inside and outside the industry.

To be eligible for the 1999 contest, safety projects or programs must have been completed between January 1998 and October 1999. Full-production cement plants, grinding-only facilities, slag operations, and distribution terminals are eligible. Vendors to member companies also may submit entries. More than one project may be submitted by the same firm, and multiple entries are encouraged.

Entries will be judged in five categories by members of the American Portland Cement Alliance's Occupational Health and Safety Committee: quarry; milling/grinding; pyroprocessing; distribution; and general facility (maintenance, training programs, awareness campaigns). Winning entries in each category will receive a video camera.

Entry forms and additional information on the contest can be obtained from Donna Wortman at PCA: (+1) 847-966-6200, ext. 358; fax: (+1) 847-966-5272.