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#236 - Emissions Into The Local Environment From A Hazardous Waste Incinerator, 04-Jun-1991

The production of hazardous waste in the U.S. continues to grow at 5.5%
per year, thus doubling every 12 or 13 years. This means that, during
the lifetime of a person born today, the amount of hazardous waste
produced each year will increase 45-fold. For every ton of hazardous
waste being produced in the U.S. today, 45 tons will be produced 70
years from now if present rates of growth continue.

U.S. Environmental Protection Agency (EPA) has responded to this
situation two ways: First, EPA has declared that one technology can
solve all waste problems: incineration. "A well-operated incinerator
can destroy hazardous waste safely," EPA says flatly.[1] Obviously if
this is true, the problem of hazardous waste has been solved, assuming
a few honest and competent people can be found to operate incinerators

Secondly, however, speaking from the other side of its mouth, EPA says
"Environmental programs that focus on the end of the pipe or the top of
the stack, or on cleaning up after the damage is done, are no longer
adequate. We need new policies, technologies and processes that prevent
or minimize pollution--that stop it from being created in the first
place."[2] Thus, somewhere deep in its innards, EPA seems to recognize
the need for waste reduction and pollution prevention.

Unfortunately, in the struggle between these two viewpoints within EPA,
pollution prevention is not faring well. EPA's "blueprint for a
comprehensive pollution prevention strategy" relies entirely on
voluntary efforts by industry. Industry's program to increase the
incineration of wastes, on the other hand, is being carried out with
active and enthusiastic support from EPA. Collaboration between EPA and
the regulated community is so close that a phrase has been coined to
describe it--"regulatory-industrial complex"--an open alliance between
the regulators and the regulated to promote the burning of waste in
cement kilns, industrial boilers, and hazardous waste incinerators
wherever possible. EPA is so eager to promote this technology that the
agency has threatened to cut off all Superfund cleanup money from those
states that refuse to install sufficient incineration capacity to burn
all wastes that might be created during the next 20 years. Instead of
urging states to initiate mandatory waste-reduction programs that would
control the growth of wastes during the next 20 years, EPA is instead
forcing states to build incinerators. (See RHWN #142.) Clearly EPA is
in a conflict-of-interest position as an enthusiastic proponent of
incinerators and the nation's only agency with responsibility for
controlling the public health effects from incinerators.

Over 57 billion pounds of hazardous wastes are burned each year in U.S.
incinerators, cement kilns and industrial boilers.[3] Ironically, less
than 5 percent of this waste is burned in officially-licensed
"hazardous wastes incinerators"--more than 95 percent is blended with
fuel oil and burned as fuel in kilns and boilers where it is not being
"disposed of" but is being "recycled" in the view of EPA.

According to the best available information on hazardous waste
incineration,[4] an average-sized incinerator (burning 35,000 tons of
waste each year) releases the following quantities of hazardous wastes
into the local environment:

Unburned wastes: A certain amount of organic waste passes directly
through a hazardous waste incinerator and is emitted, unburned, from
the smoke stack. By law, a hazardous waste incinerator is designed to
achieve 99.99 percent destruction of organic waste; another way to say
this is, by law, a hazardous waste incinerator is designed to release
0.01 percent of its organic waste through the smoke stack. This means
that, by design, 7000 pounds of unburned wastes are emitted from the
stack of an average-sized (35,000-ton-per-year) incinerator. The
estimate of 7000 pounds is based on the assumption that the incinerator
operates perfectly during every minute of its 20-year-plus operation.
Actual measurements indicate that, in the real world, operating
incinerators are more likely to emit 70,000 pounds or perhaps even as
much as 700,000 pounds of unburned waste into the local environment
each year.

According to the EPA's Science Advisory Board, spills and leaks can be
expected to release an additional 7,000 pounds of unburned wastes
directly into the local environment.[5]

Additionally, an estimated 63,000 pounds of unburned wastes will be
released into the environment with the discarded pollution control
device effluent (scrubber water).[6]

Thus the total estimated unburned wastes reaching the local environment
each year is 77,000 pounds.

Heavy metals emitted from the smoke stack: The average metals content
of hazardous waste in the U.S. is 1.5 percent, so an average 35,000-
tonper-year incinerator will burn 1,050,000 pounds of metals each year.
Many of these metals are toxic, such as lead, cadmium, chromium,
nickel, arsenic, thallium, mercury, beryllium, antimony and 8 other
metals commonly found in hazardous waste. Metals are not destroyed in
an incinerator; about 19% of them (204,000 pounds) will go up the smoke
stack, an additional 171,000 pounds will be discarded with the scrubber
water, and 672,000 pounds will be discarded with the 6.3 million pounds
of ash created each year. Like unburned wastes, metals that go up the
stack will be distributed into the local environment immediately,
becoming available to enter food chains. The scrubber water and the ash
will eventually also make their way into the environment, wherever they
are discarded.

Products of incomplete combustion (PICS): Under ideal burning
conditions, an organic hazardous waste will be converted into pure
carbon dioxide, pure water and a relatively-harmless salt. In a
laboratory, it is possible to set up nearly-ideal conditions for
burning a single chemical and thus "destroy" it completely.
Unfortunately, it is the nature of wastes that they are not pure
chemicals; wastes include many chemicals mixed together (if they
weren't mixed they wouldn't be wastes at all--they'd be valuable
products). Since each chemical has unique ideal conditions for burning,
it is impossible to achieve ideal burning conditions for all the
components of a mixed waste. For example, raising the temperature to
destroy one chemical may actually make it harder to destroy another
chemical and may also force more metals out the smoke stack. Because of
this, burning waste always creates partially-burned chemicals which can
then turn into new chemicals inside the combustion chamber.

Think of a lump of bread dough. Leave it in a hot oven and it starts to
turn brown. Leave it longer and parts of it turn black. Test those
black parts and you'll find chemicals that didn't exist at all in the
original dough. These new chemicals are PICS, or products of incomplete
combustion. In the case of bread, PICS taste bad. In the case of
hazardous waste incineration, PICS can be much more toxic than the
original chemicals from which they were derived. The amount of PICS
emitted from the smoke stack of an incinerator is just under 1% of the
weight of the waste going in--or about 693,000 pounds in the case of a
35,000-ton-per-year incinerator. Unknown --but substantial --quantities
of additional PICS will be discarded with the ash.

--Peter Montague


[1] U.S. Environmental Protection Agency, PERMITTING HAZARDOUS WASTE
INCINERATORS [EPA/530-SW-88-024] (Washington, DC: U.S. EPA, Office of
Solid waste, April, 1988), pg. 1.

[2] U.S. Environmental Protection Agency, "Environmental Protection
Agency Pollution Prevention Strategy," FEDERAL REGISTER Vol. 56 No. 37
(Feb. 26, 1991), pg. 7849. Available free by phoning EPA at (202) 382-
2736 in Washington, DC.

[3] "US hazwaste market to double by 1995?" HAZNEWS No. 37 (April,
1991), pgs. 12-13. [Haznews is an industry publication originating in
London, England.]

[4] Pat Costner and Joe Thornton, PLAYING WITH FIRE; HAZARDOUS WASTE
INCINERATION (Washington, DC: Greenpeace, 1991). Available to activists
for $10 and to industry for $100 from Greenpeace, 1436 U St., NW,
Washington, DC 20009.

[5] EPA cited in Costner and Thornton, cited above, pg. 21.

[6] Estimated in Costner and Thornton, cited above, pg. 20.

Descriptor terms: hazardous materials; incineration; epa; voluntary
emissions-reduction program; monitoring; regulation; cement kilns;
pics; spills; leaks; heavy metals; toxic substances; scrubbers;
pollution prevention; waste avoidance;