Table 1. 10 Highest Self-Reported Mercury Polluting Cement Kilns

Home , Lafarge (company)

Cementing a Toxic Legacy? Cement Kilns Findings Table 1.10 HighestSelf-ReportedMercuyPolluing Polluting CementKilns, shown in more mercury ascoal-fired power plants. the data set described in Appendix A. bers provided in this chart are based on Mercury Polluting Cement Kilns. listed in Table 1: cement kiln sites across the country are try to TRI, the ten worst mercury emitting collected and data self-reported by indus as airemissions. mercury released into theenvironment Inventory in2006 industry reported to theToxics Release is nearlydoublewhattheentire cement pounds ofmercury eachyear. kilns intheUnitedStates emitalmost23,000 According to EPA’s current estimate, cement pounds ofmercury annually. TRI, several ofthesekilnsemitover 250 tests andindustry’s ownestimatesto Rank 10 9 6 4 8 2 7 3 5 1 Some cementkilnsrelease asmuchor Based on the source test data that EPA Note thatatthefollowing locations, data provided inthistable cover multiple kilnsatonesite: Ravena, kilns. New kilns, York Victorville, California—2 –2kilns, Alpena, Michigan—5 Facility Owner Lehigh Ash Grove Essroc CEMEX Lehigh Company Alabama National Cement CEMEX Lafarge Lafarge Cement Hanson Permanente 10 HighestSelf-Reported Mercury 10 10 Highest Self-Reported — 11,995 poundsof basedonsource Location Nazareth, Pennsylvania Davenport, California Mason City, Iowa Ragland, Alabama Victorville, California Alpena, Michigan Ravena, NewYork Cupertino, California Tehachapi, California Durkee, Oregon This number The num 9 As - -  

The Ash Grove Cement Plant in in Plant Cement Grove Ash The Lafarge North America, Inc., shows up kilns on the Top the on 10 kilns list. the of capacity production smallest third the has it polluter), worst next the of amount the double than (more mercury of amount greatest the emits it although year. that a Note pounds 3,788 as much as be may emissions however,EPA to 2007, actual in submitted Grove Ash information on Based mercury. of pounds 2,582 emitted it that Inventory Release EPA’s the to reported Grove Toxic Ash 2006 incinerator. In waste hazardous or mill steel plant, power any than air the into mercury more emitting country, the in kind any of polluter mercury worst the being of tinction dis dubious the has Oregon Durkee, gan. ByLafarge’s own calculationsthe with itsplantsinNew York andMichi list twice, atrank four andrank five on theTop 10 Polluting CementKiln Mercury (lbs/yr) 3788 400 494 208 360 586 184 163 172 271

Annual Mercury Source Test Source Test Source Test Estimate Basis for TRI TRI TRI TRI TRI TRI TRI Production C 11 tons ofclinker/yr) (thousand metric

1280 2265 1497 1695 2717 907 894 958 823 731 apacity - - Cementing a Toxic Legacy? 35 12 78 36 586 - Mercury released to - TRI Reported the air (lbs/yr) nion nion U None of the kilns of the kilns None 2 use in Table or scrubbers pollution control devices designed their control to emissions. mercury (lbs/yr) Unknown Unknown Unknown Unknown Unknown to Disposal TRI Reported Mercury sent - et, for the facilities listed in in listed facilities the for et, (lbs/yr) Y Unknown Unknown Unknown Unknown Unknown to Treatment to Treatment ehigh cement kiln at at kiln cement ehigh TRI Reported Mercury sent L The The Tehachapi reported numbers to TRI to numbers reported Tehachapi less be grossly in 2006 that appear to and clearly inputs than their mercury gap problem. the data illustrate emitting 2006 in TRI to reported Bridge pollution; mercury of pounds 35 only on based calculated number the but emit be could kiln the shows data EPA unusually an pounds, 1539 to up ting lehigh kilns at Union Bridge and 52

 cant gaps between what is coming into into coming is what between gaps cant what and plant the report are companies exiting as EPA to ing Companies plant. the that TRI to data report the only not includes a from emissions air also but kiln, cement be may that mercury or of, disposed treated, than rather recycled a through emitted smokestack. reported consistently companies 2, Table it making categories, other these for “n/a” where know to public the for impossible going. is mercury the numbers to TRI, there are often signifi often are there TRI, to numbers 258 206 1539 1748 from Inputs - Mercury Content Mercury Content (fuel and feedstock combined in lbs/yr) - - 675 958 978 1467 1996 , employ Capacity Production ork emits 400 ork emits (thousand metric tons of clinker/yr) Absent emission moni Tehachapi, Union Bridge, Calera, Harleyville, South Seattle, Carolina Washington California Maryland Alabama Location

When the actual mercury-content mercury-content actual the When emissions at these facilities could be facilities emissions at these much higher. amounts that large sampling shows EPA omitted from EPA’s 2007 data requests. requests. data 2007 EPA’s omitted from emissions included in Their mercury the Tox from came directly this report which for data Inventory, ic Release the cement by reported is voluntarily It is possible that mercury companies. kiln in Ravena, New Y New kiln in Ravena, per year. mercury pounds of wholly Alabama were and Ragland, Cement kilns in Cupertino, California California in Cupertino, Cement kilns Mercury Accounting Gaps Accounting Mercury able 2. Mercury Accounting Gaps

Grove Lehigh Lehigh Lafarge Lafarge Facility Facility Owner Ash

T for the kiln inputs (i.e., fuel and feed and fuel (i.e., inputs kiln the for self-reported the to compared are stock) a co-benefit of sulfur dioxide controls. controls. a co-benefit of sulfur dioxide none of the kilns listed in Table However, 2: devices or pollution control scrubbers emissions. mercury control designed to high amounts. high amounts. most of and emission controls, toring the into will be released that mercury installed have Some plants environment. and sulfur dioxide, control to scrubbers decline as emissions should mercury of mercury pass through cement kilns, cement kilns, pass through of mercury astonishingly with some kilns reporting  Cementing a Toxic Legacy? v R I E W g A I N I s t v R I g A I N I T

Titan America,LLC Company St. Mary’sCement, Inc. Phoenix Cement Corporation Hanson PermanenteCement Mitsubishi Cement Corporation Titan America,LLC able 3.MajorKilnsIgnoredbyEPA to the rest of the mercury? the of rest tothe happened has what out, come pounds 35 only and plant the into go mercury of pounds 1,539 If ingredients. and fuel in mercury of pounds 1,539 of feedstock, and fuel the of content meaning mercury, of in” “mass of L 2007 in (3) waste; mercury off-site or on of reports were no there sions; emis were air emissions mercury TRI of all (2) TRI; toEPA’s emissions mercury of 2006 (1) is: know wedo range. large What a such is pared to the entire data set. large discrepancy, especially as com ehigh reported an estimated amount amount estimated an reported ehigh It is not entirely clear why there there why clear entirely not is It Bridge Union  R A M L

ehigh reported 35 lbs lbs 35 reported ehigh

L y

D N A L

ehigh’s reported 2006 2006 reported ehigh’s h e

C s

y B a Cloverdale, Virginia Charlevoix, Michigan Clarkdale, Arizona Cupertino, California Lucerne Valley, California Medley, Florida Kiln Location E R A W A L E D - - lehigh’s UnionBridge, Maryland,  will alsoincrease. ry emissions, ifunchecked byregulation, capacity increases, theamountofmercu 2006 and2010. million metrictons are expected between Production capacitygainsofnearly2.5 The cementindustryisrapidly expanding.

As indicatedinTable 2: from about978,000tons peryearnow current clinker production capacity is preparing to more thandoubleits to theFrancis Marion National Forest, annual basis. Thisplant,sitedclose over 200poundsofmercury onan but reported mercury inputsofjust pounds ofmercury to TRIin2006, South Carolina plantreported 78 counting Gaps proximity to theChesapeake Bay. ticularly significantgiven theplant’s tons ofclinker annually.Thisispar States, ableto produce nearly2million fifth largest cementkilnintheUnited miles northwest ofBaltimore. Itisthe plant islocatedapproximately 75 mental Control. Department ofHealthandEnviron to advisoriesfrom theSouthCarolina making themunsafeto eat,according already contaminated withmercury of SouthCarolina’s water bodiesare by 2010. Thefishinlarge sections to over 2.238milliontons peryear Clinker Capacity perY 1,497 tons 1,634 tons 1,477 tons 1,234 tons 1,543 tons 1,138 tons 13 Asthecementindustry’s , theLafarge Harleyville, 12 ear

Clinker Capacity Rank Mercury Ac 24th 13th 21st 11th 9th 8th - - -

- Cementing a Toxic Legacy? - -

- exas

Midlothian, T 16 —Becky Bornhorst, —Becky Bornhorst, ernment agencies would ernment agencies would believed that we could that we believed and gov band together ranchers, farmers, re farmers, ranchers, tired engineers. We are are We engineers. tired roots grass are ica. We listen to our concerns. our concerns. listen to volunteers. We naively naively We volunteers. a cross section of Amer section a cross We were wrong.” were We “We are soccer moms, soccer moms, are “We

19 - - - This kiln is located 18 Permanente kiln Permanente emit reported ting a staggering 494 pounds of pol mercury lution in 2006 the EPA’s to 200 pounds of mercury on an annual on 200 pounds of mercury of other and thousands of tons basis, air pollutants. toxic dangerous and the kilns at Davenport California, concern. of particular Cupertino are Hanson Permanente In the Bay Area, Cupertino, a kiln in Cement operates California. in close area within a major residential to proximity Cuper several tino schools. It is also located within miles of the five San Francisco Bay, which is currently contaminated with mercury. The Hanson these plants may emit just under Although there are other sites in are Although there

 Homes, schools and nearby farms are located right beside a cement plant are schools and nearby farms Homes, CA in Davenport, - - -

- EPA EPA 15 14 , EPA failed , EPA Even a small Even

zens of Midlothian are burdened by 5 burdened of Midlothian are zens by Holcim, Ash Grove plants operated a 6.5 all within Industries, and Texas Combined, of each other. mile radius manufacturing in the entire country is in the entire manufacturing Worth just outside of the Dallas/Fort Citi in Midlothian, Texas. metroplex of clinker. of clinker. bearing the communities are Certain of the country’s largest individual cement kilns. As shown3: in Table Major Kilns Ignored by EPA to request information from numer ous companies with cement kilns that rank in the top 25 for production large, is expanding. It acquired Rinker Rinker It acquired expanding. is large, to and is expected Materials in 2007 on-line in new plant bring a massive in 2009. Texas Braunfels, New to the public. CEMEX made blanket CEMEX made blanket the public. to regarding claims of confidentiality emissions of mercury measurements other No its kilns nation-wide. from claims company made such blanket the industry at CEMEX, like EPA. to requested information from CEMEX in from information requested but no requests, information its 2007 the content of on mercury information stack of mercury kiln feed or results by EPA been turned over tests have The cement industry continues to avoid avoid to industry continues The cement The largest concentration of cement concentration The largest EPA’s 2007 data request omittedEPA’s some CEMEX is the largest producer of producer CEMEX is the largest cement in the United States.

 There are several kilns throughout the kilns throughout several are There their due to noteworthy country that are other kilns and populated to proximity failure EPA’s In these communities, areas. emissions is espe mercury control to cially alarming. brunt of EPA’s inaction. brunt of EPA’s en adverse can have amount of mercury and public health impacts. vironmental  public scrutiny as a result of inaction on the of as a result public scrutiny U.S. EPA. part of the  10 Cementing a Toxic Legacy? mercury emissionswas undertaken. Data extensive review ofavailable data on For theanalysisinthisreport, an Data Sources 

The include HansonPermanente Cement Toxic Release Inventory. EPA failed to to residential areas of Alpena. of lar concern because it sits on the banks The Alpena cement plant is of particu ting 360 pounds of mercury in 2006. These kilns collectively reported emit the nation’s third largest cement plant. is a five-kiln plant, and in 2006 was gathered in2007. for whichEPA refuses to release data The Davenport kilnisoneofthose the Toxic Release Inventory in2006. 172 poundsofmercury pollutionto Bay Sanctuary,reported emitting only 40milesnorthoftheMonterey farms alongCalifornia’s coastlineand kiln, locatedrightbesidehomesand California isofsimilarconcern.That worse. TheCEMEXkilninDavenport, mercury emissionscouldbeeven leaving openthepossibilitythatits in anyofitsinformation requests, L ake Huron and is in close proximity L afarge site in Alpena, Michigan - - following sources: were assembledandanalyzed from the      

EPA listofhazardous waste burn Portland CementAssociation, Mercury Emissions(July2008). EPA, SummaryofCementKiln EPA-obtained data from several large permits for various cementkilns. Clean AirAct TitleVoperating submitted to EPA asapartofthe Data onmercury airemissions cement companies in response to a albeit inadequately. waste burningkilnsare regulated, mercury emissionsfrom hazardous excluded from theanalysisbecause ing kilns(2005).Thesewere 31, 2006). Plant Information Summary Canadian Portland CementIndustry reporting. 2006 Toxic Release Inventory (TRI) approximate 30-day period in 2007. content in input (raw materials) for an mercury tests and (2) data on mercury quest. This data generally includes: (1) 2007 EPA information collection re (December U.S. and - - 11 Cementing a Toxic Legacy? Sand Water Air Portland Cement Stone Gravel or Crushed

24 - 11% 41% 6% 16% 26% emitted by a cement manufacturing kiln emitted by a cement manufacturing the amount of mercury to is proportional the in the fuel and feed materials due to at the tem mercury of nature volatile in a cement kiln. encountered peratures Figure 1. Concrete Composition - - from Cement Kilns from Cement In 2002, the 22 Concrete Compo Concrete

23 nited States is the is States United Thirty-nine companies 21 See Figure 1, See Figure

20 ement kilns produce cement, the cement, ement kilns produce The in concrete. main ingredient are terms cement and concrete Ignored: Mercury Pollution Pollution Mercury Ignored: World-wide, the World-wide,

nited States, cement in the United States, produce limestone, clay, shale, fly ash and sand, clay, shale, limestone, coal, fuels (e.g., and fossil among others) the amount of mercury oil). In general, Where do the mercury emissions come from? cement kilns emissions from Mercury the feed materials (e.g., originate from and the top five companies produce over over companies produce five and the top one-half of all U.S. cement. of cement. metric tons and concrete are quite different. Cement quite different. are and concrete of any con percent 10 up just over makes mix. crete sition. of cement, behind producer largest third China and India. million consumed 103.8 United States C but cement often used interchangeably, 12 Cementing a Toxic Legacy? All illustrationsbyMattLau mercury andarangeofotherpollutants into chemical reactionsgeneratedbythisheat turn therawmaterials temperatures about25%ashotthesun’s surface. The the flameatoppositeend,theyultimately encounter cylinder calleda Blended rawmaterialsarefedintoalargerotating 3. All FiredUp Figure 2.MercuryEmissionsfromCementProdction sources ofmercury common additivethatisthesolidwasteleftafterburningcoal,are ingredients like open-pit mines,crushedtothesizeofgravel,andblendedwithother Limestone 2. You’ve Got A DirtyMine clinker , theprimaryingredientincement,istakenfromlarge , theimmediateprecursorofcommercialcement, sending clay, sand,andflyash rotary kiln . . As thematerialsapproach levels of pollutants. Though somearetepidlyregulatedbytheEnvironmentalProtection Agency, theemitted Concealed inplumesofwhitesmokerisingfromcementkilnsmokestacksisanarraydangerous 1. TheEmissions facturing process, see, Figure 2: For adescriptionofthecementmanu  es at cement kilns, EPA recognizes that:   nizes that: Emission from CementProduction. . Bothlimestoneandflyash,a straight upthesmokestack limestone’s mercury contentvaries A significantportionofkilns’ A significantportionofkilns’mercury fuel theyuse; mercury emissionscomefrom the Similarly, with regard to the fuel sourc with location. emissions comefrom limestone; and With regard to limestone, EPA recog mercury , apotentneurotoxin,havebeenunaddressed...andunderestimated. . Mercury bagged andoftenshippedtocustomersaround thecountryinbulk. gypsum, whichkeepsthecementfromhardening tooquickly. The finalproductis After passingthroughtherotarykiln,clinker iscooled,ground,andblendedwith 5. Transportation -

- - cement kilns. is responsibleformuchofthemercurypollutioncomingfrom their kilns.Coalisanotoriously Many cementplantsburncoal 4. FuelingTheFire wet kilns),andvarious typesofcontrol kiln design(e.g., drykilnsasopposedto limestone withlow-mercury content), content), cleanerraw materials(e.g., natural gasorcoalwithlow-mercury use offuelscontaining lessmercury (e.g., cement kiln.Thesefactors includethe tity ofmercury emissionsproduced ata  

These fuelshave significantlydiffer Individual kilnsusewidelydifferent Many factors candecrease thequan types ofcoal. ent mercury contents, asdodifferent and natural gas;and, petroleum coke, scrap tires, fueloil fuels, includingdifferent typesofcoal, 25 to generateextremeheatinside dirty energysource and - - 13 Cementing a Toxic Legacy? -

et, EPA has failed to to has failed et, EPA Not only do some only do some Not 26 by using additives. by using cleaner inputs consistently kilns have deploying are but some kilns than others, equipment that reduces control pollution Y emissions. mercury at other plants. similar reductions require EPA, Cost and Impacts of Wasting Cement Kiln Dust or Replacing Fly Ash to Reduce Mercury Mercury Reduce Fly Ash to Cement Kiln Dust or Replacing Cost and Impacts of Wasting EPA, 2006. December, Emissions, As power plants begin to control their This problem may grow worse in the future. and have to million tons of fly ash each year, Power plants generate approximately 71 Some kilns have already reduced their their reduced already have Some kilns 250 pounds of mercury each year emissions and, as a result, emits an additional — undermining pollution control efforts by — about 60 percent of its total emissions and the plant and further contaminating the Great Lakes that Canada the Canadian United States share. sions by more than 2,800 pounds that year. their fly ash will increase and so will mercury mercury emissions, the mercury levels in example, the Lafarge plant in Alpena, For pollution from cement kilns using ash. * Fly Ash fly ash from source of mercury emissions is mercury-laced One potentially significant gets trapped in power Fly ash is essentially fine coal ash that coal-fired power plants. some fly ash is contaminated Because coal contains mercury, plants’ pollution controls. with mercury as well. option is to pay cement plants to dispose of it find ways to dispose of this waste. One and can replace other raw materials such in their kilns, where it mixes with the cement in the fly ash gets vaporized in the cement kiln and mercury as shale. Unfortunately, 39 cement plants were accepting over three emitted as air pollution. According to EPA that increased the industry’s mercury emis million tons of fly ash in 2005 — a practice power plant that controls its mercury Michigan, accepts mercury from an Ontario to either their raw materials or fuels or materials or fuels their raw either to technology (e.g., particulate matter particulate (e.g., technology and such as baghouses devices, control carbon injection). activated emissions by making changes mercury

15 Cementing a Toxic Legacy? Matter of Mercury Figure 3. Bioaccumulation , - - - Why Mercury Emissions Emissions Mercury Why

Once released Once released eople are exposed exposed eople are unhealthy levels to when of mercury elemental, gas- elemental, 27

— Three forms of inor forms Three ganic mercury into organic organic into ganic mercury all mercury emitted are emitted are all mercury deposit locally to believed the around and regionally source. the environment, into this inor bacteria convert ganic mercury are emitted are ganic mercury the air by cement into kilns phase and particle-bound The latter two, mercury. of comprising 50 percent they eat mercury-con 3: fish. Figure taminated Bioaccumulation of Mercury can depicts of how mercury supply. end up in our food P