My name is William Freese and I am the director ofthe Huron Environmental ActivistLeague. I live in Alpena, Michigan. For over 76 years I have lived, except for time in the military in the early 50s , from 1 to 5 miles away from the largest 100 plus year old cementplantin North America. Since 1991 we have been fighting to end the pollution from this plant.

Not only is it one the largest but, according to at recent USEPA Toxic Release Inventory, itis the dirtiest such facility, bypoint source pollution, in North America. A FOIA thatwe obtained compared the City ofAlpena to the City ofDetroit for criteriapollutants. For3 out of4, nitrous oxide, sulphur dioxide, PM 2.5 and VOCs the City ofAlpena had higher levels ofthe first three than the City ofDetroit.

Cementplants were built to crush rock and make cement and notto be an incinerator. We have lived with the pollution you could see, fugitive dust, to what we have now which is extremely toxic air pollution. We
now know whatyou can't see, can hurt you more.
The former owner, National Gypsum, was taken over in
a leveraged buyout in late 1985 by the French conglomerateLafarge Coppee. The plantwas shut down in 1986. It reopened in 1988 with the goal to become the largest hazardous waste burning facility in North America. Lafarge had a permitto burn 17 million gallons ofhazardous waste per year in 3 oftheir5 kilns butwanted a permit to increase that to 21 million gallons per year to burn itin all 5 kilns.

The hazardous waste came from everywhere and as far away as Alaska. Our group's persistence and testimony kept that from happening and Lafarge stopped burning liquid hazardous waste in late 2001.

The air pollution did not end. Lafarge found other wastes to add to their toxic soup. A limited amount of chlorine free non halogenated plastic is now unlimited. Itwas supposed to be stripping ofplastic coating from milk andjuice cartons. It now comes from a recycling concepts company. Ifit is plastic from injection molding then the release used is enough to contaminate that plastic. Even though we have requested theMDNR& E and USEPA to testthe plastic and the contents ofthe tankers we have no reason to believe that it has been done.

Then there is the so called safe pesticide brothfrom Dow Agra. Thousands ofgallons have been brought to Lafarge to inject in their kilns. Ifthey need water they pump 3 million gallons ofwater per day backinto the lake. Dow's incinerator is over 100 miles closer than bringing it to Lafarge. Whybringit to Alpena? We had
an anonymous phone call and the caller said Dow was afraid ofwhateverwas in some ofthose tankers would show up in their stack emissions and they were being diverted her because our enforcementwas lax.The latestliquid now being broughthere to inject in the kilns is ammonia. Wewere concerned when the storage tanks for liquid hazardous wastes were not removed and the lack ofoversight and enforcement do not help.

Ofmost concern is the 450,000 tons per year oftoxic Canadian coal fly ash which is another form of Canadian garbage coming to Michigan. The ash is responsible for over 50°/o ofthe mercury emissions from Lafarge and 96°/o ofthat mercury is the most toxic form thatwill be found in combustion stacks

... the oxidized, divalent and ionic form ofmercury. Itis responsible for Lafarge being one ofthe highest mercury emitters in the state and places the Lafarge cementplantin the top five mercury emitting facilities in the nation.

The Portland CementAssociation that represents the cement companies states that forcing the cementplants to comply with The Clean AirAct rules is too costly and will force many ofthe plants to close and open the way for foreign competition. As for foreign competition, who would thatbe? In the early 1990s an article in The Nation, The Sultans ofCement, stated four foreign members ofcement cartel already controlled 75 percent ofall the cementproductionin North America. They
are even more powerful today. Sorry,but wrapping themselves in an American flag and asking us to protect themselves from each other does not cutit.

We have in ourfiles copies ofover 500 environmental violations or notices ofviolation by Lafarge. These areonly the tip ofthe iceberg as for every one thatwas issued at leastten was missed. An enforcement confidential document that we obtained had penalties for the dumping ofCKD atover 21 million end up at less than 1 million after Lafarge got $750,000 as an environmental improvementto build a storage dome for that Canadian coal ash. Mostviolation fines ended up as a tap on their fingernail.

A Rutgers University study ofblood in of 18 of24 Alpena residents living near the Lafarge cementkilns. Lead in their blood could be traced 75 Percent ofthe time back to the Lafarge cement kiln dust. Core soil testing by a team ofscientists found thatthe heavy metals were in the top 2 centimeters ofthe soil and were not naturally occurringbutwere from airborne from cement plant emissions and fugitive dust. The dioxin 2378 TCDD or Agent Orange Dioxin was found in some ofthese samples. That could be the reason for the large number ofdiabetics in Alpena. The lead scientist stated that ifhe lived here he would not east anything grown in our soil.

Hazardous wastes containing chlorinated compounds when burnt are a precursor ofdioxin. Dioxin was also found in the waste cementkiln dust thatwas dumped by open trucks into the active Lafarge quarry and blown every direction thatthe wind blew. In an air monitor at a school nearest to Lafarge 14 dioxins and furans were found including 2378 TCDD, the Agent Orange dioxin, way above the then safe limit. There isnow no safe limit for dioxin. 43 o/o ofVietnam veterans exposed to Agent Orange are diabetic. We average near one personper day here being diagnosed with diabetes here in Alpena. What does the future hold for those children attending the school near that monitor.

We have more than our share ofauto immune diseases, but our biggest heath problem is cancer. We have our own 3 million dollar cancer center. It opened in 2001. In 2002 it had 3,000 visits. In 2008 the visits have increased to 11,500. We are only a county ofabout 30,000 residents butwe have heard that our cancer ratio is 1 of every 5 to 1 ofevery 8.

Thereis an old saying that man is only here for one reason and that is to die. We do not need help to make it happen sooner than we want. Our health and welfare should notbe sacrificed in backroom deals. You, the USEP A, have been orderedby the courts to enforce the standards ofthe Clean Air Act and we are still waiting.

William Freese, Director 

### Huron EnvironmentalActivistLeague