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---November 7, 1990---
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As we saw last week, there are really only two workable options for dealing with the bulk of toxic wastes: make them go "away" by burning them in an incinerator, or don't create them in the first place. All other options (chemically detoxify them, recycle them, dispose of them on land) suffer from serious problems that will probably prevent the growth of these alternatives. Chemical detoxification is complicated and expensive; recycling doesn't usually work because most wastes aren't pure enough to be serve as a raw material for a new industrial process; and land disposal exposes everyone involved to major liability-polluted water, sick children, lawsuits and TV cameras.

The "pollution prevention" option requires thought, skill, planning, new technologies, major capital investment, a commitment to a long-term future and to social values that reach beyond the next quarterly profit-and-loss statement. The "burn it up" option requires only an incinerator and a government agency willing to overlook serious health hazards created by hazardous waste incineration. William Reilly's EPA (U.S. Environmental Protection Agency) has shown itself to be just such an agency. Bill talks a good game about pollution prevention but in actual fact his staff is working overtime to promote incinerators. Bill favors burners, beyond a doubt.

In truth, incineration has four things going for it: (a) a single process treats all wastes--just about anything can be burned even though burning it may not detoxify it (such as metals); in this regard, an incinerator is as useful as a landfill, which is one reason why people call an incinerator a "landfill in the sky." (b) Burning wastes is relatively cheap compared to many of the alternatives. (c) An incinerator causes the bulk of the waste to "go away" as if by magic--it "disappears" into thin air. (d) The producer of the waste escapes liability--once the waste is burned, any resulting problems belong to the incinerator, not to the original producer of the waste (unlike a land disposal site where liability may come back to haunt the original producers of the waste years later).

Therefore, for the most part the future of hazardous waste "management" throughout the early '90s will consist of a major struggle: pollution prevention vs. incineration. So far, it's a stand off.

Each year a company called McCoy and Associates in Lakewood, Colorado, assesses the status of the hazardous waste processing industry. McCoy's 1990 assessment [1] had this to say about incineration:

"The incineration boom is heating up again. This year we have identified 16 new hazardous waste incineration projects--twice as many as were reported last year (1989), but still down from the peak of 29 new projects that we reported two years ago....

McCoy goes on: "[However,] very little new waste management capacity is actually coming onstream. Stringent RCRA permitting requirements, restrictive state citing criteria, public opposition, and lawsuits often cause long delays or cancellation of new projects....

"Although new proposals abound, progress in siting, permitting and constructing those facilities is slow.

"Most of the new projects that we've identified in the past few years haven't made significant progress. We count 60 projects that are still 'under review' or that were otherwise set back, delayed or canceled during the past year.

"Although [19 projects...] made headway last year, many more experienced setbacks or delays. Therefore, the amount of new waste management capacity that actually became available was relatively small.... Thus net waste management capacity appears to have remained relatively constant last year.

"As in past years, public opposition has played a major role in slowing progress on new hazardous waste management facilities."

In sum, the McCoy report indicates that there is a war going on now between government-and-industry on the one hand, and citizens on the other--and during 1990, they fought to a stalemate.

We predict that citizen victories will soon begin to overwhelm the industry. Much new technical information is coming available to help citizens fight hazardous waste incinerators. For example, Pat Costner and Joe Thornton of Greenpeace on June 22, 1990, issued 46 pages of comments that add up to a devastating critique of the EPA's proposed hazardous waste regulations.[2] EPA issued the regulations April 17, 1990 (FEDERAL REGISTER, pgs. 17862-17921). [Natural Resources Defense Council (NRDC) and Environmental Defense Fund (EDF) may have commented on these regulations as well, but they did not return phone calls before our deadline.] Sanford Lewis and Marco Kaltofen of the National Toxics Campaign (NTC) have focused recently on the infamous Jacksonville, Arkansas, proposal to incinerate chemical-biological warfare agents in a residential community; Lewis and Kaltofen stress available alternatives to incineration.[3] Stephen Lester and Brian Lipsett of the Citizens Clearinghouse for Hazardous Waste (CCHW) in late 1988 issued INCINERATION: THE BURNING ISSUE--A MANUAL ON THE SCIENCE AND POLITICS OF HAZARDOUS WASTE INCINERATION; in 1989 they updated it with TRACK RECORD OF THE HAZARDOUS WASTE INCINERATION INDUSTRY,[4] a 12-page summary of accidents, failures, breakdowns and health or environmental threats from specific incinerators--an overview of the types of problems that can occur. Ed Kleppinger of EWK Consultants in September, 1990, issued CEMENT KILN INCINERATION OF HAZARDOUS WASTE: A CRITIQUE.[5] Thus the armament that citizens can bring to bear against any particular hazardous waste incinerator (or cement kiln) is growing daily. Even an industry that has the enthusiastic support of its regulatory partners at EPA cannot long withstand a technically-overwhelming attack from the citizenry.
--Peter Montague, Ph.D.

[1] See the March/April, 1990, issue of the HAZARDOUS WASTE CONSULTANT, Vol. 8, Issue 2, pgs. 4-1 through 4-53. A state-by-state rundown on all treatment and disposal facilities operating and proposed. An annual subscription to the Consultant costs $490 for six issues, but this special feature is available as a separate publication for $40 from: Mccoy Associates, 13701 West Jewell Ave., Suite 252, Lakewood, Co 80228; phone (303) 987-0333.

[2] Greenpeace comments on EPA's April 17, 1990, proposed hazardous waste incinerator regulations are available from: Joe Thornton, Greenpeace, 1017 West Jackson Boulevard, Chicago, Il 60607; (312) 666-3305.

[3] Lewis and Kaltofen, "A White Paper on the Feasibility of Alternatives to Incineration of Wastes at the Vertac Site in Jacksonville, Arkansas," dated October 27, 1990; available from Sanford Lewis, 42 Davis Rd., Suite 3b, Acton, Ma 01720; (508) 264-4060. Price unknown.

[4] INCINERATION--THE BURNING ISSUE... and TRACK RECORD... are both available from Citizen's Clearinghouse for Hazardous Waste, P.O. Box 926, Arlington, Va 22201; (703) 276-7070. Prices unknown.

[5] CEMENT KILN INCINERATION OF HAZARDOUS WASTE: A CRITIQUE, and a less formal compilation of photocopied information titled, "Cement Kiln Incineration of Hazardous Waste, Some Thoughts and Information" are both available from EWK Consultants, 407 N St., NW, Washington, DC 20024; (202) 488-1015. Prices unknown.

Descriptor terms: waste treatment technologies; chemical detoxification; pollution prevention; waste reduction; william reilly; epa; mccoy and associates; greenpeace; nrdc; edf; ntc; ed kleppinger; ewk associates;

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