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---November 28, 1988---
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Across the country, citizen groups are fighting the introduction of hazardous waste incinerators into their neighborhoods. Are there good reasons to oppose such an incinerator near your home? Review of available literature reveals the following problems with these incinerators:

1. Monitoring of smokestack emissions is very crude. Hazardous chemicals coming from the smokestack are not monitored. Instead, benign chemicals (such as oxygen and carbon dioxide) are monitored, and based on these readings, estimates of toxic emissions are developed. When the oxygen or carbon dioxide levels show something is wrong, it is guaranteed that toxic emissions are occurring, but there is no reliable way to estimate the quantity of toxic chemicals being released into the local air.

The emission of particulate matter (ash, soot) is especially difficult to control, is especially hazardous to human health, and is subject only to the crudest of regulations. We will discuss this subject at length in a future newsletter.

2. A single trial burn provides the basis for establishing that the machine emits tolerable quantities of toxic pollutants, and on the basis of the single trial burn, the machine is licensed to operate for up to 10 years. Unfortunately, the wastes burned during the trial burn are very likely not the wastes that will be burned during the active life of the machine, and the carefully-controlled conditions during the trial burn are unlikely to mimic the reallife conditions under which the machine will operate day after day, so the information gathered during the trial burn may be irrelevant and misleading.

Since the chemicals used by industry change frequently, it is impossible to predict today what will be contained in tomorrow's wastes. This means the operators of hazardous waste incinerators are often out on a frontier, dealing to some extent with the unknown. Furthermore, the wastes coming into an incinerator are usually not carefully sampled to see what they contain. For example, a drum may be opened and visually inspected, or a sample may be drawn from the top of the drum, but heavier chemicals may have settled into the bottom of the drum and may not be sampled at all.

3. All incinerators undergo frequent periods of "upset" during which the machine is not operating under ideal (or even tolerable) conditions. During upsets, the emission of toxic chemicals can reach very high levels. Puffs of heavily contaminated smoke are emitted into the neighborhood. Upsets may occur many times each day.

4. Products of incomplete combustion (PICs) are chemical compounds created inside the combustion chamber where different wastes mix together in the presence of high heat. If conditions in the combustion chamber are not ideal for destroying the chemicals, new chemical compounds--some of them more toxic than the hazardous wastes from which they are derived--are created and then released from the smokestack. PICs may be formed during upsets, they may be formed when the incinerator is started up or shut down, and they may be formed when a new type of waste is introduced into the combustion chamber. Many different malfunctions of the machine may also give rise to PICs from time to time.

5. Fugitive emissions. These are unplanned and unintentional releases that occur through spills, leaky valves, cracks, damaged drums, and so forth. Fugitive emissions may exceed the amount of toxic chemicals released intentionally from the smoke stack each year.

6. Explosions. It does not happen often, but hazardous waste incinerators can explode, spewing chemicals into the local environment. Naturally, it is impossible to accurately monitor emissions from an explosion.

7. Federal regulations require the destruction of 99.99% ("four nines") of the waste entering an incinerator. However, a typical incinerator will process more than 36 million pounds of hazardous wastes each year. With no unexpected releases, no upsets, no fugitive emissions, and no accidents, such an incinerator would still emit 3,600 pounds (nearly two tons) of hazardous chemicals into the local environment each year. Thus "four nines" destruction and removal efficiency (DRE) may sound very good, yet it still allows release of large quantities of chemicals which may pollute the neighborhood severely.

8. Large quantities of hazardous fly ash and bottom ash are produced by such an incinerator and must be landfilled somewhere.

9. State and federal oversight of such facilities is generally lax. Almost everywhere, governments have a poor record of enforcing existing laws and regulations. It's as if they are afraid to admit they created intractable problems when they issued the original permit, so they close their eyes and pretend that all is well.

10. Hazardous waste incinerators give the illusion of providing a technical fix to the hazardous waste problem. They lull the public into thinking such problems are solved when, in fact, they will not be solved until pollution prevention comes into wide practice and industries reduce their use of hazardous chemicals.

For further information:

Joseph Santoleri and others. "Design and Operating Problems of Hazardous Waste Incinerators." ENVIRONMENTAL PROGRESS Vol. 4 (Nov., 1985), pgs. 246-251.

William P. Linak, and others. "On the Occurrence of Transient Puffs in a Rotary Kiln Incinerator Simulator." JOURNAL OF THE AIR POLLUTION CONTROL ASSOCIATION [JAPCA] Vol. 37 (January, 1987), pgs. 54-65.

Andrew Trenholm and others. TOTAL MASS EMISSIONS FROM A HAZARDOUS WASTE INCINERATOR [EPA/600/S2-87/064]. Springfield, VA: National Technical Information Service [NTIS], Nov., 1987. Available for $24.95 from NTIS, 5285 Port Royal Rd., Springfield, VA 22161; phone (703) 487-4650.
--Peter Montague, Ph.D.

Descriptor terms: incineration; hazardous waste incinerators; fine particles; air pollution; pics; products of incomplete combustion; landfilling;

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