BREDL Comments on Clean Air Act Title V
permit for Lafarge Building Materials, Inc. near
Harleyville, SC
BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ Email: BREDL@skybest.com
April 25, 2002
James A. Joy III, Bureau Chief Bureau of Air
Quality
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
Re: Part 70 Air Quality Permit No.
TV-0900-0004 Lafarge Building Materials, Inc.,
Harleyville Plant
Dear Mr. Joy:
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:
| Lafarge Building
Materials, Inc. (Harleyville Plant)
operates a dry process cement plant near
Harleyville, SC. This process consists of
a preheater/percalciner kiln with
associated process equipment. Portland
and masonry cements are produced and
shipped in both bulk and bagged forms
from this plant. The primary raw
materials used to manufacture cement
consist of earthen materials, marl and
clay. Marl is mined from a surface mine
located behind the plant. Clay is trucked
to this facility from other nearby
surface mines. Other raw materials are
combined with the clay and marl to
produce a kiln feed with the appropriate
calcium, silica, alumnia and iron
composition required for cement
manufacture. The kiln feed is
progressively heated to approximately
2800oF using a
preheater/precalciner and rotary kiln to
produce clinker. The clinker is then
cooled and ground with a small amount of
gypsum to produce portland cement.
Masonry cement is produced by combining
portland cement with portions of ground
marl. Coal is the primary fuel used to
heat the kiln. Whole tires, natural gas,
fuel oil and various non-regulated wastes
serve as secondary fuels. |
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 Lafarge’s 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.
Respectfully submitted,
Louis Zeller
CC: Donna Moye
Valeria Willing
Kirk Schneider
Virginia Townsend
John Runkle, Esq.
Attachment
Drywall maker
Lafarge cited by state as polluter
http://enquirer.com/editions/2001/08/17/loc_drywall_maker.html
By Terry Flynn
The Cincinnati
Enquirer
Friday, August 17, 2001
Title V Fact
Sheet
BREDL
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