=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #105
—November 28, 1988—
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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HAZARDOUS WASTE INCINERATORS.
Across the country, citizen groups are fighting the introduction
of hazardous waste incinerators into their neighborhoods. Are
there good reasons to oppose such an incinerator near your home?
Review of available literature reveals the following problems
with these incinerators:
1. Monitoring of smokestack emissions is very crude. Hazardous
chemicals coming from the smokestack are not monitored. Instead,
benign chemicals (such as oxygen and carbon dioxide) are
monitored, and based on these readings, estimates of toxic
emissions are developed. When the oxygen or carbon dioxide levels
show something is wrong, it is guaranteed that toxic emissions
are occurring, but there is no reliable way to estimate the
quantity of toxic chemicals being released into the local air.
The emission of particulate matter (ash, soot) is especially
difficult to control, is especially hazardous to human health,
and is subject only to the crudest of regulations. We will
discuss this subject at length in a future newsletter.
2. A single trial burn provides the basis for establishing that
the machine emits tolerable quantities of toxic pollutants, and
on the basis of the single trial burn, the machine is licensed to
operate for up to 10 years. Unfortunately, the wastes burned
during the trial burn are very likely not the wastes that will be
burned during the active life of the machine, and the
carefully-controlled conditions during the trial burn are
unlikely to mimic the reallife conditions under which the machine
will operate day after day, so the information gathered during
the trial burn may be irrelevant and misleading.
Since the chemicals used by industry change frequently, it is
impossible to predict today what will be contained in tomorrow’s
wastes. This means the operators of hazardous waste incinerators
are often out on a frontier, dealing to some extent with the
unknown. Furthermore, the wastes coming into an incinerator are
usually not carefully sampled to see what they contain. For
example, a drum may be opened and visually inspected, or a sample
may be drawn from the top of the drum, but heavier chemicals may
have settled into the bottom of the drum and may not be sampled
at all.
3. All incinerators undergo frequent periods of “upset” during
which the machine is not operating under ideal (or even
tolerable) conditions. During upsets, the emission of toxic
chemicals can reach very high levels. Puffs of heavily
contaminated smoke are emitted into the neighborhood. Upsets may
occur many times each day.
4. Products of incomplete combustion (PICs) are chemical
compounds created inside the combustion chamber where different
wastes mix together in the presence of high heat. If conditions
in the combustion chamber are not ideal for destroying the
chemicals, new chemical compounds–some of them more toxic than
the hazardous wastes from which they are derived–are created and
then released from the smokestack. PICs may be formed during
upsets, they may be formed when the incinerator is started up or
shut down, and they may be formed when a new type of waste is
introduced into the combustion chamber. Many different
malfunctions of the machine may also give rise to PICs from time
to time.
5. Fugitive emissions. These are unplanned and unintentional
releases that occur through spills, leaky valves, cracks, damaged
drums, and so forth. Fugitive emissions may exceed the amount of
toxic chemicals released intentionally from the smoke stack each
year.
6. Explosions. It does not happen often, but hazardous waste
incinerators can explode, spewing chemicals into the local
environment. Naturally, it is impossible to accurately monitor
emissions from an explosion.
7. Federal regulations require the destruction of 99.99% (“four
nines”) of the waste entering an incinerator. However, a typical
incinerator will process more than 36 million pounds of hazardous
wastes each year. With no unexpected releases, no upsets, no
fugitive emissions, and no accidents, such an incinerator would
still emit 3,600 pounds (nearly two tons) of hazardous chemicals
into the local environment each year. Thus “four nines”
destruction and removal efficiency (DRE) may sound very good, yet
it still allows release of large quantities of chemicals which
may pollute the neighborhood severely.
8. Large quantities of hazardous fly ash and bottom ash are
produced by such an incinerator and must be landfilled somewhere.
9. State and federal oversight of such facilities is generally
lax. Almost everywhere, governments have a poor record of
enforcing existing laws and regulations. It’s as if they are
afraid to admit they created intractable problems when they
issued the original permit, so they close their eyes and pretend
that all is well.
10. Hazardous waste incinerators give the illusion of providing a
technical fix to the hazardous waste problem. They lull the
public into thinking such problems are solved when, in fact, they
will not be solved until pollution prevention comes into wide
practice and industries reduce their use of hazardous chemicals.
For further information:
Joseph Santoleri and others. “Design and Operating Problems of
Hazardous Waste Incinerators.” ENVIRONMENTAL PROGRESS Vol. 4
(Nov., 1985), pgs. 246-251.
William P. Linak, and others. “On the Occurrence of Transient
Puffs in a Rotary Kiln Incinerator Simulator.” JOURNAL OF THE AIR
POLLUTION CONTROL ASSOCIATION [JAPCA] Vol. 37 (January, 1987),
pgs. 54-65.
Andrew Trenholm and others. TOTAL MASS EMISSIONS FROM A HAZARDOUS
WASTE INCINERATOR [EPA/600/S2-87/064]. Springfield, VA: National
Technical Information Service [NTIS], Nov., 1987. Available for
$24.95 from NTIS, 5285 Port Royal Rd., Springfield, VA 22161;
phone (703) 487-4650.
–Peter Montague, Ph.D.
Descriptor terms: incineration; hazardous waste incinerators;
fine particles; air pollution; pics; products of incomplete
combustion; landfilling;