How Was Baseline Calculated? Whats in the baseline? Coal (what type of coal) natural gas, coke, slag? How much of each? No similar sources used-based on other kilns that arent wet process, whole tire, slag burning Company is relying on baseline testing to verify its findings but DEQ doesnt have the baseline testing.
Wheres the Slag? The risk assessment evaluated risks to human health and the environment associated with currently permitted operations (the baseline condition) and with proposed operation alterations (the cumulative condition) at the facility. Both conditions included emissions from smelter slag used as an iron source.
Dioxin Magically at 1x10-6 Chlorine content goes up by 1,083 lbs but miraculously dioxin remains the same Based on an EPA standard. Baseline emission is the same as cumulative exposure. Testing every two and a half years EPA report: wet kilns burning coal and coke produce about.4 nanograms of dioxin per dry standard cubic meter. Another kiln burning coal, coke and tires produced 1.2 nanograms of dioxin per dry standard cubic meter.
Risks arent added together Eat Fish from local ponds 6 x 10-6 Live in the area 1x10-5 Drink local dairy products - below the limit Hunter risk - below the limit But if you are a hunter who fishes from local ponds, who drinks local dairy, and you live in the area we dont know what your risk is.
What is not in the document… Risk assessment: Figures & Tables Air Emission Calculations Human Health Risk Assessment Calculations - Baseline Conditions & Cumulative Conditions Water Concentration Calculations Food and Forage Calculations In total 24 attachments are not attached!
Whole v. Shredded Tires Why does it matter? Its about surface area. Crumb and shredded tires are inserted at the hot end of the kiln in a steady stream. 1000 degrees hotter than middle of the kiln. No new opening. No design specification on insertion of whole tires and the potential impacts on temperature and emissions