=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #236
—June 5, 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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EMISSIONS INTO THE LOCAL
ENVIRONMENT FROM A HAZARDOUS WASTE INCINERATOR.
The production of hazardous waste in the U.S. continues to grow
at 5.5% per year, thus doubling every 12 or 13 years. This means
that, during the lifetime of a person born today, the amount of
hazardous waste produced each year will increase 45-fold. For
every ton of hazardous waste being produced in the U.S. today, 45
tons will be produced 70 years from now if present rates of
growth continue.
U.S. Environmental Protection Agency (EPA) has responded to this
situation two ways: First, EPA has declared that one technology
can solve all waste problems: incineration. “A well-operated
incinerator can destroy hazardous waste safely,” EPA says
flatly.[1] Obviously if this is true, the problem of hazardous
waste has been solved, assuming a few honest and competent people
can be found to operate incinerators well.
Secondly, however, speaking from the other side of its mouth, EPA
says “Environmental programs that focus on the end of the pipe or
the top of the stack, or on cleaning up after the damage is done,
are no longer adequate. We need new policies, technologies and
processes that prevent or minimize pollution–that stop it from
being created in the first place.”[2] Thus, somewhere deep in its
innards, EPA seems to recognize the need for waste reduction and
pollution prevention.
Unfortunately, in the struggle between these two viewpoints
within EPA, pollution prevention is not faring well. EPA’s
“blueprint for a comprehensive pollution prevention strategy”
relies entirely on voluntary efforts by industry. Industry’s
program to increase the incineration of wastes, on the other
hand, is being carried out with active and enthusiastic support
from EPA. Collaboration between EPA and the regulated community
is so close that a phrase has been coined to describe
it–“regulatory-industrial complex”–an open alliance between the
regulators and the regulated to promote the burning of waste in
cement kilns, industrial boilers, and hazardous waste
incinerators wherever possible. EPA is so eager to promote this
technology that the agency has threatened to cut off all
Superfund cleanup money from those states that refuse to install
sufficient incineration capacity to burn all wastes that might be
created during the next 20 years. Instead of urging states to
initiate mandatory waste-reduction programs that would control
the growth of wastes during the next 20 years, EPA is instead
forcing states to build incinerators. (See RHWN #142.) Clearly
EPA is in a conflict-of-interest position as an enthusiastic
proponent of incinerators and the nation’s only agency with
responsibility for controlling the public health effects from
incinerators.
Over 57 billion pounds of hazardous wastes are burned each year
in U.S. incinerators, cement kilns and industrial boilers.[3]
Ironically, less than 5 percent of this waste is burned in
officially-licensed “hazardous wastes incinerators”–more than 95
percent is blended with fuel oil and burned as fuel in kilns and
boilers where it is not being “disposed of” but is being
“recycled” in the view of EPA.
According to the best available information on hazardous waste
incineration,[4] an average-sized incinerator (burning 35,000
tons of waste each year) releases the following quantities of
hazardous wastes into the local environment:
Unburned wastes: A certain amount of organic waste passes
directly through a hazardous waste incinerator and is emitted,
unburned, from the smoke stack. By law, a hazardous waste
incinerator is designed to achieve 99.99 percent destruction of
organic waste; another way to say this is, by law, a hazardous
waste incinerator is designed to release 0.01 percent of its
organic waste through the smoke stack. This means that, by
design, 7000 pounds of unburned wastes are emitted from the stack
of an average-sized (35,000-ton-per-year) incinerator. The
estimate of 7000 pounds is based on the assumption that the
incinerator operates perfectly during every minute of its
20-year-plus operation. Actual measurements indicate that, in the
real world, operating incinerators are more likely to emit 70,000
pounds or perhaps even as much as 700,000 pounds of unburned
waste into the local environment each year.
According to the EPA’s Science Advisory Board, spills and leaks
can be expected to release an additional 7,000 pounds of unburned
wastes directly into the local environment.[5]
Additionally, an estimated 63,000 pounds of unburned wastes will
be released into the environment with the discarded pollution
control device effluent (scrubber water).[6]
Thus the total estimated unburned wastes reaching the local
environment each year is 77,000 pounds.
Heavy metals emitted from the smoke stack: The average metals
content of hazardous waste in the U.S. is 1.5 percent, so an
average 35,000-tonper-year incinerator will burn 1,050,000 pounds
of metals each year. Many of these metals are toxic, such as
lead, cadmium, chromium, nickel, arsenic, thallium, mercury,
beryllium, antimony and 8 other metals commonly found in
hazardous waste. Metals are not destroyed in an incinerator;
about 19% of them (204,000 pounds) will go up the smoke stack, an
additional 171,000 pounds will be discarded with the scrubber
water, and 672,000 pounds will be discarded with the 6.3 million
pounds of ash created each year. Like unburned wastes, metals
that go up the stack will be distributed into the local
environment immediately, becoming available to enter food chains.
The scrubber water and the ash will eventually also make their
way into the environment, wherever they are discarded.
Products of incomplete combustion (PICS): Under ideal burning
conditions, an organic hazardous waste will be converted into
pure carbon dioxide, pure water and a relatively-harmless salt.
In a laboratory, it is possible to set up nearly-ideal conditions
for burning a single chemical and thus “destroy” it completely.
Unfortunately, it is the nature of wastes that they are not pure
chemicals; wastes include many chemicals mixed together (if they
weren’t mixed they wouldn’t be wastes at all–they’d be valuable
products). Since each chemical has unique ideal conditions for
burning, it is impossible to achieve ideal burning conditions for
all the components of a mixed waste. For example, raising the
temperature to destroy one chemical may actually make it harder
to destroy another chemical and may also force more metals out
the smoke stack. Because of this, burning waste always creates
partially-burned chemicals which can then turn into new chemicals
inside the combustion chamber.
Think of a lump of bread dough. Leave it in a hot oven and it
starts to turn brown. Leave it longer and parts of it turn black.
Test those black parts and you’ll find chemicals that didn’t
exist at all in the original dough. These new chemicals are PICS,
or products of incomplete combustion. In the case of bread, PICS
taste bad. In the case of hazardous waste incineration, PICS can
be much more toxic than the original chemicals from which they
were derived. The amount of PICS emitted from the smoke stack of
an incinerator is just under 1% of the weight of the waste going
in–or about 693,000 pounds in the case of a 35,000-ton-per-year
incinerator. Unknown –but substantial –quantities of additional
PICS will be discarded with the ash.
–Peter Montague, Ph.D.
===============
[1] U.S. Environmental Protection Agency, PERMITTING HAZARDOUS
WASTE INCINERATORS [EPA/530-SW-88-024] (Washington, DC: U.S.
EPA, Office of Solid waste, April, 1988), pg. 1.
[5] EPA cited in Costner and Thornton, cited above, pg. 21.
[6] Estimated in Costner and Thornton, cited above, pg. 20.
Descriptor terms: hazardous materials; incineration; epa;
voluntary emissions-reduction program; monitoring; regulation;
cement kilns; pics; spills; leaks; heavy metals; toxic
substances; scrubbers; pollution prevention; waste avoidance