BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
April 25, 2002
On behalf of the Board of Directors of Blue Ridge Environmental Defense League and our members in South Carolina, I write to comment on the proposed Title V air permit for Lafarge Building Materials.
First, we have the following concerns regarding the emissions of particulate matter (PM) and air toxics from the Lafarge plant. PM stack tests included in the draft permit are not sufficient to determine compliance with the law. According to experts in compliance testing, the margin of error for PM performance testing is plus or minus 22%. Also, continuous emission monitors mounted on stacks for the kilns are inadequate to determine facility-wide PM emissions from non-stack sources, so fugitive emissions are not adequately calculated. Fugitive emissions for PM and for toxics must be added into the total emission limits to determine compliance with NAAQS.
Second, the fuel to be used during compliance testing is not specified in the permit. Waste fuels and fossil fuels have different characteristics which result in different types of emissions. The type of fuel burned during compliance testing should be the dirtiest type of fuel or combination of fuels in order to ensure compliance with regulations at all times of operation under all fuel burning conditions. This is the minimum measure which the state should require to protect public health at this plant. We recommend that DHEC stipulate the compliance test fuel conditions as outlined above in the permit.
Third, the permit appears to omit an important source of air emissions: a waste tire processing facility. As you know, the Lafarge Building Materials plant is described in the permit as using various waste fuels for combustion process heating. The permit states:
The Draft Permit lists emission sources one though six with corresponding control devices: Quarry-Raw Material Handling Equipment/none, Kiln System Equipment/baghouses, Clinker Handling Equipment/baghouses, Finish Mill Equipment/baghouses, Cement Loadout Equipment/baghouses, and Miscellaneous Sources/none.
According to DHEC records, the Blue Circle Cement Waste Tire Processing Facility (Facility ID No. 183342-5201) is located at the same physical address as Lafarge Building Materials Hwy. 453 &I-26, Harleyville, SC, has the same postal address PO Box 326 Harleyville, SC 29448, and has the same phone number (843) 462-7651. Moreover, on September 19, 2001 DHEC was notified of a facility name change from Blue Circle Cement (Harleyville Plant) to Lafarge Building Materials, Inc. (Harleyville Plant). The co-location of facilities under common control and ownership must have all sources included in the total emissions impact and analysis. Therefore, all the emissions from the waste tire facility must be included in the permit totals for the Lafarge plant.
Fourth, last year Lafarge is reported to have violated air pollution regulations at a Kentucky plant which produces drywall. (See attached article from the Cincinnati Enquirer). The notice of violation issued by the Kentucky Environmental Protection Cabinet states, Lafarge has failed to provide adequate enclosure and/or dust suppression to control emissions from gypsum and recycled wallboard stockpiles. The state cited negligence by the company which failed to control airborne dust and caused the deposition of a white powder in the surrounding neighborhood.
Expansion of Lafarges holdings in the United States and elsewhere may introduce cost-cutting measures which result in marginal compliance or worse. DHEC must use all available means to protect public health in South Carolina. Neighbors of the Lafarge plant in Harleyville report the deposition of a white powder on their homes and automobiles. Before issuing this permit, the state must determine whether Lafarge Building Materials is the cause of these airborne emissions. The deposition of airborne particulates outside of the property line of the permitted industry is plainly a violation of state and federal regulations. The state cannot permit an ongoing violation.
Finally, as BREDL comments have stated heretofore, this Title V permit as written does not meet the requirements for compliance assurance. Periodic monitoring must be clearly defined and required. DHEC must re-write the draft permit and release it for public comment.
Drywall maker Lafarge cited by state as polluter
By Terry Flynn