Throughout the late 1970s and early 1980s, EPA (U.S. Environmental
Protection Agency) learned the hard way that landfills always leak and
usually contaminate groundwater. So the agency kept making new
restrictions on what chemicals could be buried in the ground. Because
the agency did next to nothing to promote waste avoidance and pollution
prevention, industry continued to produce more and more hazardous waste
each year. Thus each year a larger and more diverse brew of toxins has
been sent to the nation's 18 huge commercial hazardous waste
There is now a decade's experience indicating that hazardous waste
incinerators have never worked as designed, create massive pollution
themselves, and periodically explode. Furthermore, as we saw last week
(RHWN #280), EPA scientists have known since 1985 that hazardous waste
incinerators cannot destroy wastes to the extent required by law.
This week we focus on the human management failures of incineration
Chemical Waste Management is the nation's largest and wealthiest
operator of hazardous waste incinerators. If anyone can afford to run
an incinerator properly, Chem Waste can. Furthermore, the company says
environmental compliance drives everything it does. Some of the parent
firm's top executives donate time to sit on the boards of directors of
prominent environmental organizations like Audubon and National
Wildlife Federation. They have a vice-president in charge of
environmental policy AND ethical standards. If anyone were capable of
running an incineratior well, it would seem to be this company.
Yet during recent years Chem Waste's two incinerators have racked up a
list of leaks, spills, releases, explosions, violations and coverups
that would fill a hefty book.
Standard operating procedure says:
--all wastes must be sampled and incompatible wastes must never be
mixed, BUT CHEM WASTE HAS MIXED INCOMPATIBLE WASTES TOGETHER, CAUSING
CHEMICAL REACTIONS THAT SENT PLUMES OF WASTES WAFTING OFF-SITE.
--The rate at which wastes can enter the furnace is carefully
specified, YET CHEM WASTE ON SEVERAL OCCASIONS HAS BEEN CAUGHT FEEDING
WASTES AT EXCESSIVE RATES, REDUCING THE EFFECTIVENESS OF WASTE
--Temperatures in the furnace must be maintained at 1600o or higher,
YET CHEM WASTE SOMETIMES BURNS WASTES AT TEMPERATURES OF ONLY 1300O.
--CO (carbon monoxide) must not exceed 500 ppm in the stack gas, YET
CHEM WASTE HAS PERMITTED CO TO EXCEED THIS LIMIT.
--Manifests are supposed to say where all the wastes came from, YET
CHEM WASTE HAS FAILED TO MAINTAIN PROPER MANIFESTS.
--Operating records are supposed to be kept, YET CHEM WASTE HAS FAILED
TO KEEP THEM PROPERLY.
--Waste in leaking containers is supposed to be transferred to new
containers, YET CHEM WASTE HAS FAILED TO DO THIS IN SOME CASES.
--All wastes are supposed to be sampled to avoid putting explosives
into the furnace, YET BOTH CHEM WASTE INCINERATORS HAVE EXPLODED DURING
THE PAST YEAR, OFFERING CLEAR EVIDENCE OF FAILURE TO IDENTIFY WASTES
--Explosions are to be reported when they happen, YET CHEM WASTE HAS
FAILED TO REPORT EXPLOSIONS AT ITS INCINERATORS.
--Waste feed is supposed to cut off automatically when hydrochloric
acid (HCl) in the stack gas exceeds 100 ppm BUT CHEM WASTE HAD THEIR
CUT-OFF SET FOR 500 PPM HCL.
--Chem Waste's incinerators are not licensed to burn dioxins, BUT ON
DECEMBER 3, 1991, CHEM WASTE'S INCINERATOR AT SAUGET, ILLINOIS BURNED A
25-MILLIGRAM VIAL OF DIOXIN--ENOUGH DIOXIN TO PROVIDE A MAXIMUM
ALLOWABLE LIFETIME DOSE FOR 232,000 PEOPLE.
The preceding list barely scratches the surface. How could these
lapses, violations and pollution disasters occur? If the company can't
control it's own technology, what about government? The person
responsible for developing EPA's hazardous waste incinerator
regulations back in 1978 was William Sanjour. In a recent letter to a
grass-roots activist, Sanjour offered several reasons why the
regulations, as finally written, don't work:
"I've talked to many people who live near hazardous waste sites and I
have reviewed many records, and this is the way it really works,"
Sanjour wrote. "Inspectors typically work from nine to five Monday
through Friday. So if the incinerator has anything particularly nasty
to burn, it will do so at night or on weekends. When the complaints
come in to the inspector's office the next day he will call the
incinerator operator and ask what's going on. He may also visit the
plant but rarely finds anything. The enforcement officials tend to view
the incinerator operator as their client and the public as a nuisance."
"Keep in mind that hazardous waste is a factory's garbage. If they
typically ship out say a thousand gallons a month of waste solvents and
they find themselves with say fifty gallons of waste PCB which they
don't know what to do with, what is more natural than dumping it in
with the waste solvent to he hauled away to the incinerator? No one
would be the wiser," Sanjour wrote. He offered other reasons as well:
--The regulations require no monitoring of ambient air in the vicinity
of the incinerator.
--It's easy for an operator to cheat because he or she produces and
maintains the records.
--Government inspectors are typically poorly trained. They have low
morale and high turnover. EPA statistics show that 41% of inspectors
have conducted fewer than 10 inspections. "There is no reward to
inspectors for finding serious violations and, indeed, zealous
inspectors are typically given a hard time by their supervisors,"
* * *
Recent events at the Jacksonville, Ark., incinerator (not a Chem Waste
facility) appear to follow a script that might have been written by
The Jacksonville site manager, Robert Apa, issued respirator masks to
all employees and sent an inter-office memo April 1 ordering everyone
to keep their masks handy because of dangerous "puffs" of pollution
being emitted from the furnace, which has begun burning 16 million
pounds of dioxin-contaminated chemical warfare wastes left over from
Vietnam. Seals in the fire box are leaking, and periodically, for
reasons that are not understood, pressure builds up inside the furnace,
forcing "puffs" of contaminants to escape. The puffs last from 5 to 45
seconds and, of course, represent emissions that entirely bypass the
pollution control system. The Jacksonville incinerator was constructed
in the middle of a residential neighborhood, over the objection of
local citizens, as a demonstration of the manly prowess of the
government-industry partnership that developed during the governorship
of Bill Clinton.
When news of the puffs got out, Mark McCorkle, an Arkansas state
official assigned to regulate the Jacksonville incinerator, first tried
to pressure the ARKANSAS DEMOCRAT-GAZETTE (the state's largest paper)
not to print anything about it. McCorkle then conceded that the
pollution "puffs" posed a potential hazard to workers, but denied that
the public could be affected when the puffs drifted off-site to the
homes that lie a long stone's-throw from the furnace. "If you were to
take this memo out of context, it would appear to be a horror story,"
Site manager Apa stressed the difficulty of preventing the puffs. He
said, "We have taken measures via procedural changes and a new
interlock, to minimize the duration [of the puffs.] However, as soon as
one problem is identified, another seems to appear. This last week, the
slag dams caused release of unburned material onto the TDU pad."
Jacksonville citizens continue to work desperately to shut down the
incinerator. A new group, Jacksonville Mothers and Children Defense
Fund (JAMAC), will soon file a lawsuit seeking shutdown. They are
asking groups everywhere to sign on to their suit. For details, contact
Sharon Golgan at JAMAC, 1105 Wilds, Jacksonville, AR 72076; phone (501)
982-4366. Or contact attorney Gregory Ferguson in Little Rock:
telephone (501) 372-0771.
After a decade of experimentation and experience, the record now
indicates that hazardous waste incinerators cannot be operated safely
even when the operator desires to do so. If the operators have any
inclination to cut corners, regulatory officials seem unwilling or
unable to bring them to justice.
 Jeff Bailey, "Concerns Mount Over Operating Methods Of Plants That
Incinerate Toxic waste," WALL STREET JOURNAL March [20,] 1992, pg. B1,
B5. And: Julia Flynn, "The Ugly Mess at Waste Management," BUSINESS
WEEK April 13, 1992, pgs. 76-77. Court records related to Chem Waste's
Sauget, IL, and Chicago incinerators provide details of the many
problems we have listed.
 Correspondence from William Sanjour to Terri Swearingen dated March
27, 1992. Eight pages; available from us for $2.00.
 Sandy Davis, "Incinerator Safety Stiffened," ARKANSAS DEMOCRAT-
GAZETTE April 9, 1992, pgs. 1, 10A.
Descriptor terms: epa; landfilling; groundwater; incineration;
hazardous waste; cwmi; explosions; compliance; carbon monoxide; co;
sauget, il; il; dioxin; hydrochloric acid; william sanjour;
enforcement; pcbs; jacksonville, ar; ar; cbw; vietnam war; bill
clinton; chicago, il;