RACHEL's Hazardous Waste News #208

=======================Electronic Edition========================

RACHEL’S HAZARDOUS WASTE NEWS #208
—November 21, 1990—
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 INCINERATION–PART 5. WHY EPA IGNORES THE ALTERNATIVES.

Since 1984, the U.S. Environmental Protection Agency (EPA) has
been aggressively promoting the incineration of hazardous wastes.
Some people view this as a positive step–at least the agency is
doing something about this problem, they say. But let us not
forget that, for more than half its 20-year lifetime, the agency
promoted landfills with equal vigor; eventually the public
brought forth abundant evidence that landfills were a disaster
and only then did EPA, grudgingly, start saying, “We, yes, it is
a fact that all landfills leak.” Furthermore, despite this
official recognition that all landfills leak, EPA has continued
to license new landfills on the theory that the agency has an
obligation to provide enough waste disposal capacity to keep the
cost of waste disposal affordably low for industry. Clearly this
attitude puts the agency in a conflict-ofinterest position:
they’re actively promoting the waste disposal technologies that
they also regulate. When the old Atomic Energy Commission (AEC)
got itself into this position (promoting nuclear power plants
while at the same time regulating them), everyone recognized that
this couldn’t work–but so far the conflict within EPA over waste
disposal has escaped attention.

On the question of EPA promoting incinerators, sooner or later
the agency will appear in public, tail between its legs, and say,
“Well, yes, incineration is a major source of contamination of
the human and natural environments,” just as it did with
landfills. The scientific literature is now peppered with
critical appraisals of incineration technology. Presently, EPA is
keeping its finger in the dike, holding back a deluge of
criticism that will eventually overwhelm this technology, but
even EPA cannot hold back the truth forever.

Why does EPA promote incineration? Because it’s a simple (though
dirty) fix to a complex problem and because it gives the
appearance that the agency knows what it’s doing and has things
under control and because it minimizes government interference in
industrial decision-making. If you don’t look into the matter too
closely, hazardous waste incineration gives the appearance of
solving the hazardous waste problem. In one sense, an incinerator
is almost as simple as a landfill. You dig a pit in the ground
and throw wastes in; or you build a furnace with a large hole in
its face and you throw wastes in. It hardly matters what the
wastes contain: one pit, or one furnace, fits all. You don’t have
enough waste-handling capacity? Just dig another pit, or build
another furnace.

Furthermore, incineration has two important advantages over
landfilling: once wastes have been put through an incinerator,
they cannot be traced back to their original source, so the
generator of the waste escapes liability. The second advantage is
that an incinerator has many parts so an incinerator can be made
to appear too complicated for anyone but engineers to understand.
Everyone can see that a landfill is nothing but a bathtub in the
ground and that all bathtubs will eventually leak. On the other
hand, an incinerator can be presented in a way that makes it seem
so complex that only a rocket scientist could comprehend it. This
allows government to effectively discourage people from
participating in decision-making about incinerators. How do we
know Bill Reilly’s EPA wants to discourage public discussion?
Because, for example, in July, 1990, when 37 grass-roots groups
asked EPA to hold a public hearing on its proposed new
regulations for hazardous waste incinerators, EPA took a page
from Nancy Reagan’s book and just said No. Perhaps they were
afraid they would become addicted to hearing new ideas from the
public.

From industry’s viewpoint, a complex technology is far superior
to a simple one. The public is screaming that wastes are
unregulated? Just issue 500 pages of regulations for pits, or for
furnaces; the more complex the better. Lace the regulations with
all the latest engineering language: “state of the art,” “best
available control technology,” “four nines destruction,” “de
minimis risk,” “acceptable risk of 10-5” and so on. The public is
not educated to understand such language, and this leaves the
playing field clear for industry and EPA. Never mind that the
complex regulations won’t discourage the production of an
ever-increasing quantity of wastes and won’t protect public
health. Under such circumstances, industry makes money the
oldfashioned way–by creating massive waste, the costs of which
are passed on to community residents and to the taxpaying public.
At election time, the President (who, after all, controls EPA)
and his friends are rewarded with large cash contributions, and
thus the system regulates itself. Balances and checks, don’t you
know.

The main alternative to incineration has the serious disadvantage
of being simple. Waste avoidance, or pollution prevention–in
short, not making waste–is a simple idea. Behind the scenes it
may be complicated but from an enforcement perspective, it is
easy: you require industry to report their annual waste
production (about the same as they do now under the federal
Community Right to Know law) plus their annual output of
products, then you require them to reduce their waste (measured
as a percentage of the amount of product produced) by a small
amount each year–say, 10% per year. If they don’t reduce their
waste production, they draw a fine; the fines can help support
the governmment’s enforcement program which, like the IRS,
periodically investigates to see who’s been lying to Uncle Sam,
with stiff penalties including jail for those who get caught. The
chief advantage of such a scheme is that it minimizes government
interference in specific industrial processes–Uncle Sam doesn’t
have to decide what is “best available technology.”

The chief disadvantage of such a scheme is that it would require
our industrial leaders to get off the dime and do things
differently. Pollution prevention calls for initiative,
ingenuity, imagination, brainpower, longerterm strategic
thinking, managerial skill–all the things that many people say
Japan now has but America hasn’t. It calls for the recognition
that pollution is a visible sign of inefficiency in industrial
operations. Pollution is money going up the chimney, down the
sewer, or out the door into waste trucks. Pollution is raw
material unconverted, or it is products that are not fully
recovered. Increased efforts to reduce waste can result in
increased profit.

But EPA seems to hold the view that America’s industrial leaders
are losers and has-beens, incapable of change, so EPA talks a lot
about pollution prevention (because every school child can figure
out that’s what we need), but meanwhile EPA works overtime to
help the waste industry build yet more incinerators because
incinerators don’t require anything of industry–they only
require the general public to absorb more pollution. People who
occupy the middle ground–those who believe American industry is
simply too lethargic and too unimaginative to ever achieve
significant pollution prevention, yet are themselves unwilling to
let incinerators proliferate across the land like chancre
sores-these people are asking, “What are the alternatives to
incineration (besides pollution prevention)?”

Even a small technical library contains so many answers to such a
question that the problem is one of information overload. There
are too many ways to detoxify wastes, besides incineration, for
most people to have sufficient time to review them all. (Of
course, people who decide to produce toxic wastes have a special
obligation to figure out what to do about them; for these people,
lack of time is no excuse.)

Still, for those who want to know, here are some books to start
with: E. Ellsworth Hackman III, TOXIC ORGANIC CHEMICALS,
DESTRUCTION AND WASTE TREATMENT (Park Ridge, NJ: Noyes Data
Corporation, 1978); Amir A. Metry, THE HANDBOOK OF HAZARDOUS
WASTE MANAGEMENT (Westport, CT: Technomic Publishing Co., 1980
[Technomic is now located in Lancaster, PA]); Edwin J. Martin and
James H. Johnson, Jr., editors, HAZARDOUS WASTE MANAGEMENT
ENGINEERING (NY: Van Nostrand Reinhold, 1987); D.J. De Renzo,
UNIT OPERATIONS FOR TREATMENT OF HAZARDOUS INDUSTRIAL WASTES
(Park Ridge, NJ: Noyes Data Corporation, 1978); Gary F. Lindgren,
GUIDE TO MANAGING INDUSTRIAL HAZARDOUS WASTE (Woburn, MA:
Butterworth Publishers, 1983); Harry Freeman, INNOVATIVE THERMAL
PROCESSES FOR TREATING HAZARDOUS WASTES (Lancaster, PA: Technomic
Publishing Co., 1986); Harasiddhiprasad G. Bhatt, Robert M.
Sykes, and Thomas L. Sweeney, editors, MANAGEMENT OF TOXIC AND
HAZARDOUS WASTES (Chelsea, MI: Lewis Publishers, 1983). And this
just scratches the surface of available literature on
technologies besides incineration for detoxifying wastes.
–Peter Montague, Ph.D.

Descriptor terms: epa; hazardous waste incineration; aec; waste
reduction; rtk; alternative treatment technologies;

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