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---November 21, 1990---
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Since 1984, the U.S. Environmental Protection Agency (EPA) has been aggressively promoting the incineration of hazardous wastes. Some people view this as a positive step--at least the agency is doing something about this problem, they say. But let us not forget that, for more than half its 20-year lifetime, the agency promoted landfills with equal vigor; eventually the public brought forth abundant evidence that landfills were a disaster and only then did EPA, grudgingly, start saying, "We, yes, it is a fact that all landfills leak." Furthermore, despite this official recognition that all landfills leak, EPA has continued to license new landfills on the theory that the agency has an obligation to provide enough waste disposal capacity to keep the cost of waste disposal affordably low for industry. Clearly this attitude puts the agency in a conflict-ofinterest position: they're actively promoting the waste disposal technologies that they also regulate. When the old Atomic Energy Commission (AEC) got itself into this position (promoting nuclear power plants while at the same time regulating them), everyone recognized that this couldn't work--but so far the conflict within EPA over waste disposal has escaped attention.

On the question of EPA promoting incinerators, sooner or later the agency will appear in public, tail between its legs, and say, "Well, yes, incineration is a major source of contamination of the human and natural environments," just as it did with landfills. The scientific literature is now peppered with critical appraisals of incineration technology. Presently, EPA is keeping its finger in the dike, holding back a deluge of criticism that will eventually overwhelm this technology, but even EPA cannot hold back the truth forever.

Why does EPA promote incineration? Because it's a simple (though dirty) fix to a complex problem and because it gives the appearance that the agency knows what it's doing and has things under control and because it minimizes government interference in industrial decision-making. If you don't look into the matter too closely, hazardous waste incineration gives the appearance of solving the hazardous waste problem. In one sense, an incinerator is almost as simple as a landfill. You dig a pit in the ground and throw wastes in; or you build a furnace with a large hole in its face and you throw wastes in. It hardly matters what the wastes contain: one pit, or one furnace, fits all. You don't have enough waste-handling capacity? Just dig another pit, or build another furnace.

Furthermore, incineration has two important advantages over landfilling: once wastes have been put through an incinerator, they cannot be traced back to their original source, so the generator of the waste escapes liability. The second advantage is that an incinerator has many parts so an incinerator can be made to appear too complicated for anyone but engineers to understand. Everyone can see that a landfill is nothing but a bathtub in the ground and that all bathtubs will eventually leak. On the other hand, an incinerator can be presented in a way that makes it seem so complex that only a rocket scientist could comprehend it. This allows government to effectively discourage people from participating in decision-making about incinerators. How do we know Bill Reilly's EPA wants to discourage public discussion? Because, for example, in July, 1990, when 37 grass-roots groups asked EPA to hold a public hearing on its proposed new regulations for hazardous waste incinerators, EPA took a page from Nancy Reagan's book and just said No. Perhaps they were afraid they would become addicted to hearing new ideas from the public.

From industry's viewpoint, a complex technology is far superior to a simple one. The public is screaming that wastes are unregulated? Just issue 500 pages of regulations for pits, or for furnaces; the more complex the better. Lace the regulations with all the latest engineering language: "state of the art," "best available control technology," "four nines destruction," "de minimis risk," "acceptable risk of 10-5" and so on. The public is not educated to understand such language, and this leaves the playing field clear for industry and EPA. Never mind that the complex regulations won't discourage the production of an ever-increasing quantity of wastes and won't protect public health. Under such circumstances, industry makes money the oldfashioned way--by creating massive waste, the costs of which are passed on to community residents and to the taxpaying public. At election time, the President (who, after all, controls EPA) and his friends are rewarded with large cash contributions, and thus the system regulates itself. Balances and checks, don't you know.

The main alternative to incineration has the serious disadvantage of being simple. Waste avoidance, or pollution prevention--in short, not making waste--is a simple idea. Behind the scenes it may be complicated but from an enforcement perspective, it is easy: you require industry to report their annual waste production (about the same as they do now under the federal Community Right to Know law) plus their annual output of products, then you require them to reduce their waste (measured as a percentage of the amount of product produced) by a small amount each year--say, 10% per year. If they don't reduce their waste production, they draw a fine; the fines can help support the governmment's enforcement program which, like the IRS, periodically investigates to see who's been lying to Uncle Sam, with stiff penalties including jail for those who get caught. The chief advantage of such a scheme is that it minimizes government interference in specific industrial processes--Uncle Sam doesn't have to decide what is "best available technology."

The chief disadvantage of such a scheme is that it would require our industrial leaders to get off the dime and do things differently. Pollution prevention calls for initiative, ingenuity, imagination, brainpower, longerterm strategic thinking, managerial skill--all the things that many people say Japan now has but America hasn't. It calls for the recognition that pollution is a visible sign of inefficiency in industrial operations. Pollution is money going up the chimney, down the sewer, or out the door into waste trucks. Pollution is raw material unconverted, or it is products that are not fully recovered. Increased efforts to reduce waste can result in increased profit.

But EPA seems to hold the view that America's industrial leaders are losers and has-beens, incapable of change, so EPA talks a lot about pollution prevention (because every school child can figure out that's what we need), but meanwhile EPA works overtime to help the waste industry build yet more incinerators because incinerators don't require anything of industry--they only require the general public to absorb more pollution. People who occupy the middle ground--those who believe American industry is simply too lethargic and too unimaginative to ever achieve significant pollution prevention, yet are themselves unwilling to let incinerators proliferate across the land like chancre sores-these people are asking, "What are the alternatives to incineration (besides pollution prevention)?"

Even a small technical library contains so many answers to such a question that the problem is one of information overload. There are too many ways to detoxify wastes, besides incineration, for most people to have sufficient time to review them all. (Of course, people who decide to produce toxic wastes have a special obligation to figure out what to do about them; for these people, lack of time is no excuse.)

Still, for those who want to know, here are some books to start with: E. Ellsworth Hackman III, TOXIC ORGANIC CHEMICALS, DESTRUCTION AND WASTE TREATMENT (Park Ridge, NJ: Noyes Data Corporation, 1978); Amir A. Metry, THE HANDBOOK OF HAZARDOUS WASTE MANAGEMENT (Westport, CT: Technomic Publishing Co., 1980 [Technomic is now located in Lancaster, PA]); Edwin J. Martin and James H. Johnson, Jr., editors, HAZARDOUS WASTE MANAGEMENT ENGINEERING (NY: Van Nostrand Reinhold, 1987); D.J. De Renzo, UNIT OPERATIONS FOR TREATMENT OF HAZARDOUS INDUSTRIAL WASTES (Park Ridge, NJ: Noyes Data Corporation, 1978); Gary F. Lindgren, GUIDE TO MANAGING INDUSTRIAL HAZARDOUS WASTE (Woburn, MA: Butterworth Publishers, 1983); Harry Freeman, INNOVATIVE THERMAL PROCESSES FOR TREATING HAZARDOUS WASTES (Lancaster, PA: Technomic Publishing Co., 1986); Harasiddhiprasad G. Bhatt, Robert M. Sykes, and Thomas L. Sweeney, editors, MANAGEMENT OF TOXIC AND HAZARDOUS WASTES (Chelsea, MI: Lewis Publishers, 1983). And this just scratches the surface of available literature on technologies besides incineration for detoxifying wastes.
--Peter Montague, Ph.D.

Descriptor terms: epa; hazardous waste incineration; aec; waste reduction; rtk; alternative treatment technologies;

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