=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #283
—April 29, 1992—
News and resources for environmental justice.
——
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org
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WASTE WARS: THE ARMY OPENS A NEW FRONT
Here’s the emerging picture of hazardous waste disposal in the
U.S.:
Citizens have blocked construction of all new hazardous waste
dumps. There are no new dumps on the drawing boards. EPA [U.S.
Environmental Protection Agency] is aggressively promoting
hazardous waste incinerators because the alternative–waste
avoidance and pollution prevention–would inconvenience the
generators of hazardous waste. Rather than inconvenience anyone
with power and connections, EPA is promoting incinerators. It’s
really that simple.
Industry likes incinerators because liability for toxic waste
disappears when the waste enters the incinerator. From the
Superfund dump-cleanup program where they’re spending billions
defending themselves against lawsuits, industry knows the
liability problem is serious. Incinerators solve this problem
because after chemicals pass through an incinerator, there are no
labels left on the barrels to identify responsible parties. Most
of the waste goes up the smoke stack and can’t be traced. The
incinerator company–not the original waste generator–bears
responsibility for the toxic ash, but in the scheme of things
incinerator companies are relatively small and can declare
bankruptcy when their ash dumps begin to leak, a few decades from
now. EPA will then put the ash dumps on the Superfund list, and
the taxpayer will bear all the costs. It’s a practical system and
it should work.
The only hitch is that citizens are blocking the siting of new
incinerators. So EPA is cooperating with the U.S. Army and the
Department of Energy (DOE) to solve this problem. The Department
of Energy has announced plans to site a huge, privately-owned
incinerator on the Hanford Reservation in Washington state. DOE
has produced plutonium for A-bombs at Hanford for 40 years. DOE
will deflect public outrage about siting the privately-owned
incinerator, and Chem Waste will run it, despite Chem Waste’s
embarrassing record of failure running incinerators (see RHWN #280 and #281). For its part, the Army has announced plans to
site eight huge chemical-waste incinerators at Aberdeen,
Maryland; Richmond, Kentucky; Anniston, Alabama; Pine Bluff,
Arkansas; Pueblo, Colo.; Newport, Indiana; Tooele, Utah; and
Umatilla, Oregon. The Army’s stated goal is to burn up old
chemical warfare weapons that now aren’t needed. At a public
hearing at Aberdeen three weeks ago, the Army said with a
straight face it will spend $500 million building the
incinerator, use it for 14 months to destroy mustard gas and then
dismantle it, never burning any other defense wastes or civilian
wastes. Local people don’t believe it, and they fear military
incinerators would be as dangerous as civilian incinerators.
But let’s be fair. Maybe the private incinerator companies have
bungled the job merely because they are careless and cut corners
to increase profits. The army would have no such motives and
could perhaps be relied upon to do a better job. What do we know
about Army experience running incinerators?
The military has already built and operated a modern,
state-of-the-art incinerator specifically designed to destroy
left-over chemical warfare weapons. To avoid a hassle with local
citizens, they built the incinerator on an island in the South
Pacific–Johnston Atoll. Environmentalists and local native
people opposed the facility but that did not deter the Army.
During the period July 16, 1990 through February 27, 1991, the
Army fed 7490 M55 rockets containing 75,000 pounds of the nerve
agent GB (also known as Sarin), into the Johnston Atoll Chemical
Disposal System (JACADS). GB is among the most powerful nerve
poisons ever developed.
The operation of the JACADS incinerator was evaluated by MITRE
Corporation (McLean, Virginia) under contract to the Army. The
MITRE report has been scrutinized by chemist Pat Costner,
research director for Greenpeace. Her paper, “Chemical Weapons
Demilitarization and Disposal: The Army’s Experience at Johnston
Atoll Chemical Disposal System,” contains valuable data and
insights into what we can expect from the Army’s path-breaking
chemical-weapons incineration program.[1]
Here are facts Costner gleaned from the book-length MITRE report:
** During the period of operation, the JACADS incinerator
functioned for 500 hours but during the same period it
experienced 929 hours of down-time because of malfunctions. The
“mean (average) time between failures” throughout the period was
5.6 hours.
** During the 500-hour operating period when agent GB was being
burned, the network of monitors for detecting GB releases
triggered 776 major process alarms, an average of 22 per day.
Major process alarms are “those that are so important that agent
or spent decon[tamination] processing is stopped,” according to
the MITRE report.
A high level of carbon monoxide (CO) in smoke-stack gases is an
indication of poor burning. Of the 776 major process alarms that
occurred, “the majority” were for high carbon monoxide in the
stack gas–a dead give away that the incinerator was experiencing
“upsets.”
During upset conditions, an incinerator emits large quantities of
pollutants into the environment. The EPA Science Advisory Board
says, “Even relatively short-term operation of incinerators in
upset conditions can greatly increase the total
incinerator-emitted loadings [pollution emissions] to the
environment.”
According to the MITRE report, the JACADS incinerator suffered 90
burner lockouts and 40 fuel flow shutdowns during the GB-burning
campaign, further evidence of upsets. As Costner said in her
report, “In other words, the [incinerator] operated in a
continuous upset condition during the GB campaign.”
On 32 occasions the JACADS incinerator released GB nerve agent
into corridors frequented by workers. Furthermore, during 500
hours of incineration, the JACADS workforce accumulated 1944
hours of lost-time accidents. In other words, every hour of
operation was accompanied by 3.9 hours of injury-related
lost-time among the workers. Costner documents other serious
problems with the Army’s JACADS incinerator as well.
This is not good news. It means the Army’s 8 proposed state-side
incinerators will do no better–perhaps considerably worse–than
civilian hazardous waste incinerators, which are poor indeed.
Inside their furnaces, incinerators destroy some chemicals, but
in the process they create many new toxic by-products that did
not exist before, all of which they emit into the environment
partly via the smoke stack and partly via the ash, which is
buried temporarily in a landfill until it leaks out. Among the
most toxic of those chemicals are dioxins and furans. On January
27, 1992, EPA staff presented their latest findings about dioxins
and furans to EPA chief William Reilly. RHWN has obtained a set
of 24 acetate transparencies prepared by EPA staff for chief
Reilly. They contain important new information about dioxin:
EPA’s transparency 17 says:
RECENT SCIENTIFIC RESULTS AND CONCLUSIONS:
* DIOXIN DOES CAUSE CANCER IN HUMANS.
* CANCER MAY NOT BE THE MOST SENSITIVE TOXIC RESPONSE RESULTING
FROM DIOXIN EXPOSURE. IMMUNOTOXICITY AND REPRODUCTIVE EFFECTS
APPEAR TO OCCUR AT BODY BURDENS THAT ARE APPROXIMATELY 100 TIMES
LOWER THAN THOSE ASSOCIATED WITH CANCER.
* RECENT DATA INDICATE THAT THERE MAY NOT BE A THRESHOLD FOR
CERTAIN RESPONSES TO DIOXIN. HOWEVER, THE IMPLICATIONS FOR
SPECIFIC RISK ASSESSMENTS, SUCH AS FOR CANCER, ARE NOT YET CLEAR.
* RECENT EVIDENCE HAS STRENGTHENED THE CONCLUSION THAT THE
SENSITIVITY OF HUMANS IS SIMILAR TO THAT OF EXPERIMENTAL ANIMALS
(CANCER, IMMUNOTOXICITY, AH RECEPTOR BINDING, ETC.).
EPA’s transparency 18 says:
NEW SCIENCE AND CONCLUSIONS……CONTINUED.
* CURRENT EXPOSURE LEVELS TO DIOXIN AND RELATED COMPOUNDS APPEAR
TO PLACE PEOPLE AT OR NEAR THE BODY BURDEN WHEN SENSITIVE
RESPONSES MAY OCCUR, ESPECIALLY FOR SUBPOPULATIONS AT HIGH-END
EXPOSURE, E.G., NURSING INFANTS, RECREATIONAL AND SUBSISTENCE
ANGLERS.
* CONTINUING RESEARCH INTO THE RISK FROM DIOXIN EXPOSURE SHOULD
RESULT IN A CONTINUING PROCESS OF REASSESSMENT AS NEW DATA BECOME
AVAILABLE AND ARE INCORPORATED INTO A NEW, MORE FLEXIBLE MODEL.
* ORD [EPA’s Office of Research and Development] SCIENTISTS HAVE
REACHED THE TENTATIVE CONCLUSION THAT DIOXIN EXPOSURE MAY HAVE
BEEN RESPONSIBLE FOR THE DECLINE OF LAKE TROUT IN LAKE ONTARIO AS
A RESULT OF THE REPRODUCTIVE TOXICITY OF DIOXIN.
Let’s review briefly what EPA has said here:
One. Dioxin causes cancer in humans, but cancer is not the most
sensitive indicator of damage from dioxin; damage to the immune
system, and reproductive damage, are the most sensitive
indicators.
Two. Animals and humans are about equally sensitive to damage
from dioxin.
Three. The amount of dioxin presently in our food (“current
exposure levels,” EPA calls it) puts humans at or near the
body-burden of dioxin at which “sensitive responses” [immune
system damage, and damage to the reproductive system] may occur.
Those at greatest risk are infants who drink their mother’s
breast milk, or people who eat more-than-average amounts of fish
because fish accumulate these poisons in their tissues.
Four. In fact, it appears that because fish accumulate these
poisons in the fat tissues of their bodies, and because fish eggs
have a high fat content and therefore a high dioxin content, Lake
Trout in the Great Lakes are not able to thrive. Evidently humans
are not the only species endangered by dioxin.
The logical conclusion from EPA’s data is that Americans cannot
afford to increase the amount of dioxins and furans in their
bodies–they are already at or near the levels where immune
system damage and reproductive system damage occurs, especially
babies. Thus all plans to build new incinerators in the U.S.
stand in direct conflict with public health priorities. New
incinerators (and uses of chlorine) should be banned, old ones
phased out.
–Peter Montague, Ph.D.
Descriptor terms: epa; doe; army; mitre; pat costner; nerve gas;
johnston atoll; dioxin; cwmi; cbw; incineration; jacads;