| Subject: LaFarge |
Author:
Ned Depew
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Date Posted: 12:30:56 05/02/06 Tue
Friends -
below is a copy of a letter I've sent to the Stuyvesant Town Board to ask them to continue to speak out in opposition to the DEC decision on the LaFarge Air Quality Permit modification. I hope others will add their voices in their own localities and on the County level to encourage our elected officials to take action to reverse this damaging decision on the part of the DEC.
Several Town Boards and the Rensselaer County Legislature all raised objections before the fact to the DEC granting this permit without a full review - but the DEC simply ignored them. This gives them - and all of us - even stronger grounds to oppose and overturn the DEC decision.
But we must object and oppose this decision with persistence and determination. I hope everyone who reads this will be inspired to take action to stop this dangerous - potentially lethal for some - and irresponsible action by the DEC.
***************
Valerie Bertram, Supervisor
Stuyvesant Town Board
PO Box 250
Stuyvesant, NY 12173
Dear Ms. Bertram;
As I said I would, I am sending you this letter to request that the Stuyvesant Town Board pass a resolution in the strongest possible terms in objection to the recent DEC decision granting an air permit modification to the LaFarge Building Materials plant in Ravena, NY that would allow them to burn whole tires as fuel in their cement kilns.
Furthermore, I'd like the Board to instruct you, as our representative, to carry a resolution to the County Legislature making the fight against this permit a priority of their commitment to protect our people. The County Legislature needs to take steps to require the DEC to withdraw their "negative declaration" on the need for a full environmental review of the impacts the granting of this permit will have on Columbia County citizens, and to oppose the granting of this permit on the sound scientific grounds that clearly exist, in defense of public health.
There is a great deal of documentation available on the effects of burning waste tires in cement kilns. Careful, professional, scientific studies have been done. The primary relevant finding, for our purposes, is that the burning of whole tires in cement kilns produces an entirely unpredictable emissions stream that may vary widely - by hundreds of percentage points - from day to day, hour to hour, facility to facility.
This uneven incineration - completely different from the controlled and dedicated incineration of tires the EPA says is the least desirable though still 'acceptable" method of tire disposal - presents the constant risk of short-term releases of significant concentrations of some of the most toxic pollutants known, into the air we breathe.
There are a number of complicating factors. Dioxins and furans, for instance, are among the most potent carcinogenic agents yet discovered. They have been shown to have negative health effects in amounts so small - we're talking about a few "parts per million" here - that the EPA has declared that there is "no safe level of exposure" to them. And in these tiny - but potentially lethal - concentrations, they are virtually impossible to monitor at the exhaust stack.
This is also true of some of the most deadly heavy-metal toxins that are released in tire burning - mostly from the "steel belts" in the tires. Mercury, for instance, is so toxic that one teaspoon-full can pollute a 20 acre lake. Again, these elements are released unpredictably, in tiny but deadly amounts, mainly depending on the composition of the tires being burned at a particular time and the conditions under which they are burned, which vary widely within cement kilns.
The DEC is asking us to rely on "computer modeling" to have confidence in what the "average" output - averaged over days, weeks, months or even years - will be, and disregarding the reality that we will be potentially subject to what may be periods of intense concentrations, that will then be statistically averaged with periods of zero emissions - when the kilns are shut down for repair, for instance - to arrive at a figure representing "average" emissions. Meanwhile, we, our families and our neighbors may have been breathing intense concentrations of these poisons - and neither we, nor the company, nor the DEC will have any way of actually knowing.
What we do know is that we will - I use the word "will" because this is a scientifically predictable certainty - as a population, suffer increased incidence of cancers, as has been documented in case after case in populations downwind from dioxin and furan producing industrial installations. In fact the otherwise inexplicable "cancer clusters" that already exist in Greene County are likely (but sadly, not so far demonstrably) attributable to these causes.
The DEC is arguing that since the LaFarge plant is already polluting the air, and they are not (in their 'averaged" computer models, which will be virtually impossible to check against reality) going to exceed their already permitted limits of fouling of the air, the DEC should not subject this change to the full scrutiny of an SEQRA. They issued a "negative declaration" on this project, indicating the lack of need for full scrutiny.
This is simply irresponsible. Increases in emissions of highly toxic pollutants - even within permitted limits that were established at a time when our understanding of the health effects of air-borne pollution was far below what it is now - should indeed be subjected to the strictest oversight. The most advanced technology available should be brought to bear to analyze - and mitigate if possible - the predictable impacts, which should be determined as closely as possible by the most rigorous available scientific methods.
I emphasize once again that we know - and the DEC cannot deny - that there will "likely" be an increase in the "average" number of cancer cases reported downwind from a facility that is emitting dioxins and furans. Although the DEC may argue that this increase will be "small" - if it affects one of us, or our families, it will look very large indeed. There is no reason why we should give - or allow the DEC to give - a corporation the right to increase our risk of cancer simply in order to increase its profits.
There are many other potential negative effects as well, as many of the harmful pollutants emitted from combustion of tires will find their way into our soil and into the food chain on our local farms.
Short term increases in particulate pollution of small particulate matter - releases of which are one of the effects of incomplete tire combustion in cement kilns during incidents known as "upsets" that are common occurrences in the cement-making process - have been clearly demonstrated in conclusive studies in the last five years, to have a direct immediate effect on increases of acute respiratory distress, including death, even in the case of increases of as little as ten percent, for periods of just an hour or two. Such increases would be "averaged" by the computer modeling accepted by the DEC, but not by our lungs, nor those of our children.
The documentation of the facts I have enumerated here is all public record. I'd be happy to make this research available to you and to assist you in any way as you fight to protect the health of your constituents here in Stuyvesant, citizens throughout Columbia County and beyond, as I trust you will.
Thanks for your attention to this matter, which is critical for all of us.
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