In 1990, 700,000 U.S. companies created 380 million tons of legally-
hazardous waste. Of this, 285 million tons (75 percent) was land-
disposed, 28.6 million tons (7.5 percent) was incinerated, 13 percent
was treated physically or chemically to detoxify it, and 7.2 percent
was recycled. Of these technologies, recycling is limited because
there just aren't many wastes that are suitable as a raw material for
some other industrial process; the future of land disposal is limited
because both EPA and--more importantly--the general public recognize
that land disposal pollutes land and its associated waters; physical-
chemical processing requires innovative thought and can be expensive.
This leaves incineration as the growth industry and, in fact,
incineration is expected to increase at an astonishing 17.8% yearly
throughout the '90s.
The growth of incineration is definitely something to be concerned
about. From the toxic emissions revealed last week (RHWN #236) for a
typical 35,000-ton-peryear incinerator, we can calculate that,
nationally, incinerators are today putting 835 million pounds of raw,
unburned hazardous wastes directly into the environment (75.9 million
pounds from the stack, 75.9 million pounds from spills and leaks, and
683 million pounds discarded with the scrubber water). Many of these
wastes are going into the air where people can breathe them directly.
Eventually they all become available to enter food chains.
Metals emitted today from existing incinerators total 2.2 billion
pounds each year from the stack, 1.85 billion pounds discarded with
scrubber water, and another 7.3 billion pounds discarded with the ash.
One year's worth of ash weighs 68.3 billion pounds.
Total products of incomplete combustion (PICS) being emitted from
stacks today equal 7.5 billion pounds. PICs are new chemicals created
inside the incinerator; many of them are more toxic, more longlived,
and more likely to enter food chains than are the raw wastes from which
the PICs are derived.
Last week we gave a "best estimate" of the quantities of unburned
wastes--7000 pounds of raw hazardous waste emitted each year from the
stack of a typical 35,000-ton-per-year incinerator. This estimate
assumes that the incinerator operates perfectly every minute of every
day for 20 years. What is the actual record of performance of hazardous
A joint task force of the federal Occupational Safety and Health
Administration (OSHA) and U.S. Environmental Protection Agency (EPA)
conducted 62 unannounced inspections at 29 hazardous waste incinerators
during 1990. Sixty-nine percent of the inspections resulted in
citations for violations. The task force report, issued May 23, 1991,3
describes 320 OSHA violations (214 of which were "serious," meaning
"violations for which there is a substantial probability that death or
serious physical injury [to a worker] could result from the existing
condition") and 75 violations of EPA regulations. In addition to the 75
violations, EPA inspectors noted "a significant number of emergency
waste feed cut-offs and emergency by-pass openings." What are these?
A hazardous waste incinerator is set up to burn wastes continuously.
Wastes enter the combustion chamber through a pipe or a conveyor. One
batch of waste enters the chamber; right behind it comes another batch
of different wastes; behind that is a third batch, and so forth. As
each new batch of waste enters the combustion chamber, the machine has
to be adjusted manually (or by a computer) to do the best job possible
of destroying the waste. If conditions in the combustion chamber are
not adjusted properly for the waste that is entering (or is about to
enter), the operator (or a computer) is supposed to cut off the waste
feed (stop the incoming flow). When the flow in the pipe stops,
this is evidence that something is out of adjustment. The machine is
not being operated as well as it could be.
Sixty-six percent (19 of the 29 incinerators) experienced waste-feed
cutoffs during a 30-day period monitored by EPA during 1990. One large
incinerator (with four burning units) experienced 13,325 waste feed
cutoffs--more than 13,000 instances in which the machine was badly out
of adjustment in one 30-day period. Other incinerators experienced 1800
cutoffs, 1386 cutoffs, 943 cutoffs, 900 cutoffs, and so forth.
EPA says it does not know what the effects of waste-feed cutoffs might
be on emissions from the incinerator. "...[T]o better understand the
actual circumstances and impact of activating waste-feed cutoffs, the
Agency [EPA] will incorporate this issue into its continuing research
program for hazardous waste combustion," the task force report says.
Meanwhile, we must conclude, the operators of the vast majority of
hazardous waste incinerators checked by EPA are conducting their own
research on this matter, using local people as guinea pigs.
The second item that EPA discovered in its surprise inspections was
excessive need for the "bypass" or "dump stack" as it is known in the
trade. The "dump stack" is a emergency smoke stack that bypasses the
air pollution control equipment. It is "intended to prevent... possible
explosions from excessive pressure in the combustion unit." EPA says
further that "it is also intended to protect the air pollution control
equipment when the exit gas temperature is too high." Using the dump
stack is strong evidence that pressures or temperatures (or both)
inside the combustion chamber have gotten dangerously high. Compared to
excessive use of the waste-feed cut-off, "The use of emergency bypasses
is of more serious concern to EPA because it results in direct venting
to the air of emissions that normally are subject to air pollution
control devices," the task force says.
How often was the "dump stack" opened at the 29 incinerators EPA
inspected? Nine of the 29 incinerators (31%) used their dump stacks
during a 6-month period in 1990. The worst offender (the big 4-unit
incinerator) opened its dump stack 867 times in six months; next worst
opened it 91 times, next worst opened it 47 times, and on down the
list. Emissions from dump stacks are not included in any of the
estimates we presented last week--so for 30% of all incinerators, we
can safely assume, the emission estimates we gave last week are too
low. Thus our cumulative total emissions, given above, are also too
Since it is clear that hazardous waste incineration emits large
quantities of toxins directly into the environment, why is it such an
attractive technology to industry (and to its partners-in-progress at
EPA)? Three reasons: (a) you can legally send anything and everything
to an incinerators, whether it can be burned or not, which relieves
waste producers of the need for thought; (b) incineration is generally
affordable; and (c) once you send your waste to an incinerator, you're
not only rid of the waste, you're rid of the liability as well: the
only thing that can be traced is the incinerator ash and the
incinerator company owns that--not the customers of the incinerator
company. This is probably the most attractive feature of incineration--
it breaks the chain of liability for the polluter.
What's the answer? Don't let industry site any more incinerators.
California hasn't been able to site a new incinerator for 5 years, so
state officials got 12 major industries to sign a pact agreeing to
reduce their wastes 50% within 2 years. Stopping up the toilet really
does work. Citizen pressure is the key.
 "US hazwaste market to double by 1995?" HAZNEWS No. 37 (april,
1991), pgs. 12-13, quoting a new report entitled A COMPETITIVE ANALYSIS
OF HAZARDOUS WASTE MANAGEMENT (Cleveland Heights, Oh: Leading Edge
Reports [12417 Cedar Rd., Suite 29, Cleveland Heights, Oh 44106; phone
(216) 791-5500], 1991. The new report is priced at $1950.00.."
 HAZNEWS, cited above.
 Gerard F. Scannell [of OSHA] and Don R. Clay [of EPA], TASK FORCE
REPORT ON COMPLIANCE WITH ON-SITE HEALTH AND SAFETY REQUIREMENTS AT
HAZARDOUS WASTE INCINERATORS (Washington, DC: OSHA and EPA, 1991). 31
pages. To get a copy, contact Don R. Clay, EPA, Office of Solid Waste
and Emergency Response, Washington, DC 20460; phone (202) 382-4610. If
you can't get this report from EPA, for $12 (copying and postage) we
can mail you a copy.
 Pat Costner and Joe Thornton, PLAYING WITH FIRE; HAZARDOUS WASTE
INCINERATION (Washington, DC: Greenpeace, 1991), pg. 7. Available to
activists for $10 and to industry for $100 from Greenpeace, 1436 U St.,
NW, Washington, DC 20009.
Descriptor terms: incineration; hazardous materials; recycling; waste
disposal technologies; water pollution; scrubbers; end-of-pipe
treatments; osha; violations; monitoring; emissions;