Hazardous waste incinerators, and the web of regulations intended to
make them operate safely, have come under withering criticism from
government scientists, private researchers, and the WALL STREET JOURNAL
during the last 60 days. Officials of EPA (U.S. Environmental
Protection Agency) and private research scientists now admit that
hazardous waste incinerators emit hundreds of times more dioxins and
other toxic air pollutants than is allowed by EPA regulations, and the
JOURNAL revealed a record of malfunctions, including explosions and
major releases of toxins, that incinerator operators have tried to
cover up and that regulatory officials seem powerless to understand,
much less curtail.
Scientists employed by U.S. EPA (Environmental Protection Agency)
admitted last month that modern hazardous waste incinerators simply
cannot comply with existing federal regulations because they cannot
destroy all chemicals with 99.99% destruction/removal efficiency (DRE),
which is the efficiency required by federal law. Federal law further
requires that certain wastes of "special concern" such as dioxins,
furans, and PCBs must be destroyed with 99.9999% DRE. EPA scientists
said last month that they have known since at least 1985 that hazardous
waste incinerators could not meet any of these regulatory requirements.
The story broke when Pat Costner, a chemist and research director for
Greenpeace, published an independent analysis of dioxin emissions from
the Jacksonville, Arkansas incinerator. The Jacksonville incinerator
has begun burning 16.5 million pounds of herbicides (2,4,5-T and 2,4-D)
left over from the Vietnam war. These wastes are known to be
contaminated with total dioxins and furans at concentrations ranging
from to 3 to 40 parts per million (ppm).
Costner's analysis revealed that the Jacksonville incinerator was only
achieving 99.96% destruction of the dioxins entering the incinerator,
thus emitting 400 times more dioxin into the community than the law
allows. An official with the Arkansas Department of Pollution Control
and Ecology (DPC&E) acknowledged in telephone interviews that Costner's
calculations are correct. He also said the department had no intention
of shutting down the incinerator despite its continuing emissions of
dioxin directly into a residential community. He said the department
did not know what the total dioxin emissions into the population of
Jacksonville would be, but, he said, no matter what the total may be,
it is safe.
The Jacksonville incinerator is a key demonstration project,
established with the cooperation of EPA Administrator William Reilly
and Arkansas Governor Bill Clinton to show that dioxin-containing
wastes can be incinerated in a residential neighborhood over the
objections of the community. In a city-wide referendum in March,
1986, the people of Jacksonville voted two-to-one (1383 to 656) to stop
the project but government officials simply ignored the vote and have
overridden all objections ever since. Costner's analysis clearly showed
that residents of Jacksonville are being exposed to levels of dioxin
contamination that exceed federal health and safety standards by a wide
margin. This is the first systematic dioxin experiment on humans using
a residential population. Previous dioxin exposures of humans have
occurred during industrial accidents and in the industrial manufacture
of chemical-biological warfare agents. Dioxin is now known to cause
cancer in humans and to disrupt normal growth and development of
fetuses and infants at low levels of exposure.
About 100 waste sites in the U.S. contain substantial quantities of
dioxin, and the U.S. has stockpiles containing billions of pounds of
chemical-biological warfare (CBW) agents the government has said it
wants to incinerate. If the Jacksonville dioxin experiment can be
maintained despite ethical and public health objections, government
agencies will be able to claim they have a green light to incinerate
just about anything just about anywhere.
However the Jacksonville experiment has brought to light information
that could derail the entire U.S. incineration program. In preparing
her analysis of dioxin exposure of the Jacksonville populace, Costner
uncovered a government study showing that tests in 1984-85 by private
researchers, under contract to EPA, revealed that hazardous waste
incinerators cannot be expected to achieve 99.9999 percent destruction
of wastes that occur in concentrations lower than 10,000 parts per
million, and cannot be expected to achieve 99.99 percent destruction of
wastes that occur in concentrations lower than 1000 ppm. EPA published
the 1985 data in 1989.5
When this information came to light, a news reporter from the ARKANSAS
DEMOCRAT-GAZETTE, Sandy Davis, interviewed Bob Hall, chief of the EPA's
Combustion Research Branch in Research Triangle, North Carolina, and he
confirmed what the EPA report had shown. "The fact is that you run into
problems with your DRE [destruction/removal efficiency] when a low
concentration of wastes is fed into the incinerator," Hall said. "Our
data clearly shows that," he said. Davis asked Hall why EPA hasn't
changed its regulations since it knows existing incinerators cannot
comply with the regulations. Hall said, "I don't know why that hasn't
been changed. It's a regulatory issue. I'm in research." Costner
uncovered a second EPA report, published in 1984 but never widely
circulated, showing that, among eight major hazardous waste
incinerators studied, none could achieve 99.99% DRE. Sandy Davis
interviewed the author of that report, Drew Trenholm of the Midwest
Research Institute in Research Triangle, North Carolina, who said
incinerators simply cannot achieve the DRE required by federal law.
"The trend is very strong in the data that this is the case," Trenholm
At public hearings over the past decade, dozens of EPA officials have
stated for the record that incinerators can achieve the legally-
required DREs, in what appears to be a coverup of public health
information of astonishing proportions.
Many of the most dangerous toxins such as dioxins, furans, and PCBs
occur in wastes at low concentrations. If low-concentration chemicals
cannot be destroyed effectively, this means all sludge incinerators,
all contaminated-soil burners, and all wood-treatment-waste
incinerators will fail to meet federal regulations and will emit
illegal quantities of potent toxins into surrounding air.
Ongoing failure to achieve the required destruction efficiencies is not
all that plagues incinerators. WALL STREET JOURNAL reporter Jeff Bailey
pointed out March 20 that federal, state and local regulatory officials
pay close attention to hazardous waste incinerators but they can't be
everywhere at the same time and they often learn about accidents,
explosions and violations from tips phoned to them anonymously by
insiders. For example, Chem Waste, the nation's largest hazardous
waste hauler, is not considered a fly-by-night operator. According to
Joan Bernstein, vice-president for environmental policy and ethical
standards at Chem Waste, "Environmental compliance is what drives this
If this is true, then Chem Waste's ongoing record of accidents,
explosions, leaks, releases and coverups involving their incinerators
must mean that even the wealthiest companies that have written down
their best intentions on a piece of paper still cannot operate
hazardous waste incinerators in a fashion that any reasonable person
would call safe.
[To be continued.]
 Pat Costner, THE INCINERATION OF DIOXIN IN JACKSONVILLE, ARKANSAS:
A REVIEW OF TRIAL BURNS AND RELATED AIR MONITORING AT VERTAC SITE
CONTRACTORS INCINERATOR, JACKSONVILLE, AR (Washington, DC: Greenpeace
Toxics Campaign, January 29, 1992).
 Stephanie Arbanel and others, "Toxic Nightmare on Main Street,"
FAMILY CIRCLE August 14, 1990, pgs. 77-80, 120-128.
 Karen F. Schmidt, "Puzzling Over a Poison; On closer inspection,
the ubiquitous pollutant dioxin appears more dangerous than ever," U.S.
NEWS & WORLD REPORT April 6, [1992,] pgs. 60-61.
 Peter A. Johnson and others, DIOXIN TREATMENT TECHNOLOGIES:
BACKGROUND PAPER [OTA-BP-O-93] (Washington, DC: U.S. Government
Printing Office, 1991). 80 pages. $4.00 from U.S. Government Printing
Office, P.O. Box 371954, Pittsburgh, PA 15250-7954 or phone your order
to (202) 783-[3238.]3238.
 John C. Kramlich and others, EXPERIMENTAL INVESTIGATION OF CRITICAL
FUNDAMENTAL ISSUES IN HAZARDOUS WASTE INCINERATION (Springfield, VA:
National Technical Information Service [NTIS], September, 1989.) This
is EPA document No. EPA/600/2-89/048 available from NTIS for $26.00;
phone (800) [553-6847] and request NTIS document No. PB90-108507.
 Sandy Davis, "Incinerator can't do job, engineer says," ARKANSAS
DEMOCRAT-GAZETTE March 14, 1992, pgs. 1A, 15A.
 A. Trenholm and others, PERFORMANCE EVALUATION OF FULL-SCALE
HAZARDOUS WASTE INCINERATORS. VOL. I. EXECUTIVE SUMMARY. [EPA/600/2-
84/181A]. (Washington, DC: U.S. Environmental Protection Agency, 1984).
Available from NTIS as document No. PB 85-129500. $17.00. Phone
 Jeff Bailey, "Concerns Mount Over Operating Methods Of Plants That
Incinerate Toxic Waste," WALL STREET JOURNAL March 20, 1992, pgs. B1,
Descriptor terms: hazardous waste; incineration; regulation; wall
street journal; epa; dioxin; air pollution; accidents; federal; pcdfs;
pcbs; pat costner; greenpeace; ar; pesticides; health; birth defects;
cbw; sludge incineration; cwmi; jacksonville, ar;