=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #237
—June 12, 1991—
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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STUDY OF HAZARDOUS WASTE INCINERATORS
REVEALS ‘WIDESPREAD DEFICIENCIES’–EPA.
In 1990, 700,000 U.S. companies created 380 million tons of
legally-hazardous waste. Of this, 285 million tons (75 percent)
was land-disposed, 28.6 million tons (7.5 percent) was
incinerated, 13 percent was treated physically or chemically to
detoxify it, and 7.2 percent was recycled.[1] Of these
technologies, recycling is limited because there just aren’t many
wastes that are suitable as a raw material for some other
industrial process; the future of land disposal is limited
because both EPA and–more importantly–the general public
recognize that land disposal pollutes land and its associated
waters; physical-chemical processing requires innovative thought
and can be expensive. This leaves incineration as the growth
industry and, in fact, incineration is expected to increase at an
astonishing 17.8% yearly throughout the ’90s.[2]
The growth of incineration is definitely something to be
concerned about. From the toxic emissions revealed last week
for a typical 35,000-ton-per-year incinerator, we can
calculate that, nationally, incinerators are today putting 835
million pounds of raw, unburned hazardous wastes directly into
the environment (75.9 million pounds from the stack, 75.9 million
pounds from spills and leaks, and 683 million pounds discarded
with the scrubber water). Many of these wastes are going into the
air where people can breathe them directly. Eventually they all
become available to enter food chains.
Metals emitted today from existing incinerators total 2.2 billion
pounds each year from the stack, 1.85 billion pounds discarded
with scrubber water, and another 7.3 billion pounds discarded
with the ash. One year’s worth of ash weighs 68.3 billion pounds.
Total products of incomplete combustion (PICS) being emitted from
stacks today equal 7.5 billion pounds. PICs are new chemicals
created inside the incinerator; many of them are more toxic, more
longlived, and more likely to enter food chains than are the raw
wastes from which the PICs are derived.
Last week we gave a “best estimate” of the quantities of unburned
wastes–7000 pounds of raw hazardous waste emitted each year from
the stack of a typical 35,000-ton-per-year incinerator. This
estimate assumes that the incinerator operates perfectly every
minute of every day for 20 years. What is the actual record of
performance of hazardous waste incinerators?
A joint task force of the federal Occupational Safety and Health
Administration (OSHA) and U.S. Environmental Protection Agency
(EPA) conducted 62 unannounced inspections at 29 hazardous waste
incinerators during 1990. Sixty-nine percent of the inspections
resulted in citations for violations. The task force report,
issued May 23, 1991,[3] describes 320 OSHA violations (214 of which
were “serious,” meaning “violations for which there is a
substantial probability that death or serious physical injury [to
a worker] could result from the existing condition”) and 75
violations of EPA regulations. In addition to the 75 violations,
EPA inspectors noted “a significant number of emergency waste
feed cut-offs and emergency by-pass openings.” What are these?
A hazardous waste incinerator is set up to burn wastes
continuously. Wastes enter the combustion chamber through a pipe
or a conveyor. One batch of waste enters the chamber; right
behind it comes another batch of different wastes; behind that is
a third batch, and so forth. As each new batch of waste enters
the combustion chamber, the machine has to be adjusted manually
(or by a computer) to do the best job possible of destroying the
waste. If conditions in the combustion chamber are not adjusted
properly for the waste that is entering (or is about to enter),
the operator (or a computer) is supposed to cut off the waste
feed (stop the incoming flow). When the flow in the pipe stops,
this is evidence that something is out of adjustment. The machine
is not being operated as well as it could be.
Sixty-six percent (19 of the 29 incinerators) experienced
waste-feed cutoffs during a 30-day period monitored by EPA during
1990. One large incinerator (with four burning units) experienced
13,325 waste feed cutoffs–more than 13,000 instances in which
the machine was badly out of adjustment in one 30-day period.
Other incinerators experienced 1800 cutoffs, 1386 cutoffs, 943
cutoffs, 900 cutoffs, and so forth.
EPA says it does not know what the effects of waste-feed cutoffs
might be on emissions from the incinerator. “…[T]o better
understand the actual circumstances and impact of activating
waste-feed cutoffs, the Agency [EPA] will incorporate this issue
into its continuing research program for hazardous waste
combustion,” the task force report says. Meanwhile, we must
conclude, the operators of the vast majority of hazardous waste
incinerators checked by EPA are conducting their own research on
this matter, using local people as guinea pigs.
The second item that EPA discovered in its surprise inspections
was excessive need for the “bypass” or “dump stack” as it is
known in the trade. The “dump stack” is a emergency smoke stack
that bypasses the air pollution control equipment. It is
“intended to prevent… possible explosions from excessive
pressure in the combustion unit.” EPA says further that “it is
also intended to protect the air pollution control equipment when
the exit gas temperature is too high.” Using the dump stack is
strong evidence that pressures or temperatures (or both) inside
the combustion chamber have gotten dangerously high. Compared to
excessive use of the waste-feed cut-off, “The use of emergency
bypasses is of more serious concern to EPA because it results in
direct venting to the air of emissions that normally are subject
to air pollution control devices,” the task force says.
How often was the “dump stack” opened at the 29 incinerators EPA
inspected? Nine of the 29 incinerators (31%) used their dump
stacks during a 6-month period in 1990. The worst offender (the
big 4-unit incinerator) opened its dump stack 867 times in six
months; next worst opened it 91 times, next worst opened it 47
times, and on down the list. Emissions from dump stacks are not
included in any of the estimates we presented last week–so for
30% of all incinerators, we can safely assume, the emission
estimates we gave last week are too low. Thus our cumulative
total emissions, given above, are also too low.
Since it is clear that hazardous waste incineration emits large
quantities of toxins directly into the environment, why is it
such an attractive technology to industry (and to its
partners-in-progress at EPA)? Three reasons: (a) you can legally
send anything and everything to an incinerators, whether it can
be burned or not, which relieves waste producers of the need for
thought; (b) incineration is generally affordable; and (c) once
you send your waste to an incinerator, you’re not only rid of the
waste, you’re rid of the liability as well: the only thing that
can be traced is the incinerator ash and the incinerator company
owns that–not the customers of the incinerator company. This is
probably the most attractive feature of incineration–it breaks
the chain of liability for the polluter.
What’s the answer? Don’t let industry site any more incinerators.
California hasn’t been able to site a new incinerator for 5
years, so state officials got 12 major industries to sign a pact
agreeing to reduce their wastes 50% within 2 years. Stopping up
the toilet really does work.[4] Citizen pressure is the key.
–Peter Montague, Ph.D.
===============
[1] “US hazwaste market to double by 1995?” HAZNEWS No. 37
(april, 1991), pgs. 12-13, quoting a new report entitled A
COMPETITIVE ANALYSIS OF HAZARDOUS WASTE MANAGEMENT (Cleveland
Heights, Oh: Leading Edge Reports [12417 Cedar Rd., Suite 29,
Cleveland Heights, Oh 44106; phone (216) 791-5500], 1991. The
new report is priced at $1950.00..”
Descriptor terms: incineration; hazardous materials; recycling;
waste disposal technologies; water pollution; scrubbers;
end-of-pipe treatments; osha; violations; monitoring; emissions;