=======================Electronic Edition========================
RACHEL’S HAZARDOUS WASTE NEWS #314
—December 2, 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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CEMENT AND KILN DUST CONTAIN DIOXINS
During routine preparation of a REPORT TO CONGRESS ON CEMENT
KILNS, the U.S. Environmental Protection Agency (EPA) has learned
that cement and cement kiln dust contain dioxins and furans (both
of which are powerful poisons in animals and humans), according
to a briefing document dated October 8, 1992, prepared by EPA
staff for EPA’s Director of Solid Waste, Sylvia Lowrance. The
October briefing document also says 20 percent of the cement kiln
dust that EPA tested contains the non-natural radioactive
elements plutonium-238, plutonium-239 and cesium-137. Dioxins are
the most powerful carcinogens (cancer-causing agents) ever tested
in laboratory animals; plutonium is the most potent carcinogen in
humans ever discovered.
Cement is a principal component of pipe often used to distribute
drinking water in many American cities. Cement kiln dust is a
byproduct of cement manufacture and is routinely given or sold to
farmers as a soil treatment, or is discarded into pits or is
piled on the ground near cement kilns in an uncontrolled fashion.
According to Bill Schoenborn, an EPA staff member working on the
REPORT TO CONGRESS, about 6 million tons of kiln dust is disposed
of each year by cement kilns, 5.1 million tons of it buried
on-site, and 900,000 tons of it shipped off-site for use in
stabilizing other wastes (such as sewage sludge) or as a soil
additive on farms. Cement kiln dust has previously been reported
to contaminate groundwater with the toxic metals lead and
chromium,[1] but until now no one has reported dioxins, furans,
plutonium or cesium-137 in cement or cement kiln dust.
The REPORT TO CONGRESS is required by the federal Resource
Conservation and Recovery Act (RCRA), the nation’s basic
hazardous waste law. Like mine wastes, cement kiln dust was
initially exempt from RCRA because it is a high-volume waste
presumed to be low in toxicity. Cement clinker (that is to say,
cement itself) is exempt from RCRA because it is a product, not a
waste. Section 8002(o) of RCRA required EPA to study cement kiln
dust and to write a report for Congress on its findings. For
several years, EPA dragged its feet preparing the report. Then
Environmental Defense Fund (EDF) brought a lawsuit, and now EPA
is under a court order to finish the report by April, 1993.
In the course of preparing the REPORT TO CONGRESS, EPA randomly
selected 15 cement manufacturing plants (called kilns) for
sampling, out of the 114 such plants presently operating in the
U.S. Of the 15 plants sampled, eight burn hazardous waste as fuel
and seven do not. In recent years, cement kiln operators have
increasingly been using hazardous waste as fuel, to reduce fuel
costs and thus increase profitability. The practice has proved
controversial. (See RHWN #174 and #243.)
Opponents of the
practice say they fear cement will become contaminated with
industrial poisons. Cement is a key raw material in concrete pipe
for water delivery systems, and in concrete block and other
concrete materials used in construction of private homes,
commercial dwellings, public buildings, bridges and highways.
Seventy to 80 million tons of cement are produced in the U.S.
each year, depending on market demand.
Sampling Results
EPA took 15 samples of “clinker” (the product of a kiln, from
which cement is made), plus 28 samples of dust (the unwanted
byproduct of a kiln). All samples were analyzed for metals,
chloride, cyanide, fluoride, total sulfate, total organic carbon,
moisture content, and radioactive elements.
Samples from six kilns (4 burning hazardous waste, 2 not burning
hazardous waste) were tested for dioxins and furans, volatile
organic compounds, semivolatile organic compounds, and
pesticides. All chemical analyses were completed by EPA’s
National Air and Radiation Environmental Laboratory (NAREL) in
Alabama.
Dioxins and furans were detected in all samples of “clinker” and
all samples of kiln dust analyzed for these compounds. The
October briefing document says that the dioxin molecule known as
2,3,7,8-TCDD, the most potent poison in the dioxin family, was
only identified in samples from kilns burning hazardous waste.
Other dioxins were found in samples from kilns not burning
hazardous waste, but no 2,3,7,8-TCDD. However, the October
briefing document says it is not possible to generalize these
differences to the entire 114 operating cement kilns.
Samples of cement kiln “clinker” did not contain pesticides or
semivolatile organics. Clinker was not analyzed for volatile
organics. On the other hand, cement kiln dust contained amounts
of the volatile organics benzene and acetonitrile that exceeded
RCRA limits “in a number of the samples of hazardous waste
burners” but not in samples from kilns not burning hazardous
wastes. The dust from one kiln not burning hazardous waste proved
to be high in methylene chloride, according to the October
briefing document.
These findings lend support to the view that burning hazardous
waste in a cement kiln increases the amount and potency of toxins
in the resulting cement kiln dust and perhaps in the cement
itself.
At three kilns (2 burning hazardous waste, one not burning
hazardous waste) levels of naturally-occurring radioactive
radium-226 exceeded the cleanup standard for uranium mine and
mill wastes (the standard being 5 picoCuries per gram).
Cesium-137, a non-natural radioactive element, was present in the
dust of 26 percent of the kilns tested (4 out of 15)–one
hazardous waste burner and three non-hazardous waste burners.
Plutonium-238 and plutonium-239 were detected in kiln dust
samples from 3 of the 15 kilns tested. Each of these 3 facilities
is “located near a DOE [U.S. Department of Energy] nuclear
weapons production/testing facility,” according to EPA’s October
briefing document. Plutonium and cesium-137 do not occur in
nature but are created by nuclear bomb explosions and in nuclear
power reactors.
A second EPA briefing document dated November 24, 1992, contains
additional information about the problem of potent toxins being
found in cement and in cement kiln dust. The document is titled
“OSW Office Briefing on Cement Kiln Dust Risk Screening” and it
contains a summary of a risk assessment that is being conducted
by the EPA’s Communications and Budget Division within the
Regulatory Analysis Branch, Office of Solid Waste.
The November briefing document outlines two risk assessment
scenarios: one in which cement dust blows off-site and affects a
person living 750 feet from an active waste pile, and a second in
which an individual is presumed to be living on top of an
abandoned waste pile. No risk assessment was reported for the
case of a farmer growing crops in soil to which cement kiln dust
has been added.
Furthermore, no risk assessment is reported for the dioxins and
furans measured in cement clinker, which it to say, in cement
itself.
Based on the two risk assessment scenarios, the November briefing
document describes amounts of toxins in cement kiln dust that
appear to be acceptable, which is to say will only give cancer to
one in 100,000 individuals so exposed. The November document
lists 22 instances in which one or more EPA tests of cement kiln
dust exceeded the criteria developed in the risk assessments.
Criteria that are exceeded by one or more samples include:
2,3,7,8-TCDD, total dioxins, total dioxins and furans, total
hexachloro dioxins, arsenic, beryllium, cadmium, chromium, lead,
and thallium, plus the following radioactive elements:
bismuth-214, cesium-137, potassium-40, lead-212, lead-214,
radium-226, radium-228 and thorium-227.
The purpose of the risk assessments reported in the November
document is to help EPA decide whether the agency needs to
regulate cement kiln dust as a legally hazardous waste or not.
Declaring cement kiln dust a legally hazardous waste would
greatly increase the cost of waste disposal for some cement
kilns, and thus might reduce the profitability of some kilns.
EPA employee Hugh Kaufman has previously charged that the agency
has been “accommodating the regulated cement kiln hazardous waste
incineration industry with nonexistent, or at best loose,
regulation…”[2]
Now that EPA has found dioxins in cement clinker, and dioxins and
radioactive elements in cement kiln dust, the agency will likely
come under considerable pressure to regulate all cement kiln
wastes as hazardous wastes.
For their part, citizens seem likely to start asking themselves
anew whether kilns can be good neighbors.
–Peter Montague, Ph.D.
===============
[1] Jeffrey D. Smith, “Cement Kilns 1991,” EI DIGEST (August,
[1991),] pgs. 20-32.
Descriptor terms: cement kiln incineration; hazardous waste
incineration; bif rules; sylvia lowrance; cement kiln dust;
plutonium; cesium; dioxin; carcinogens; cancer; lead; chromium;
metals; rcra; risk assessment; edf; concrete;