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#105 - Hazardous Waste Incinerators, 27-Nov-1988

Across the country, citizen groups are fighting the introduction of
hazardous waste incinerators into their neighborhoods. Are there good
reasons to oppose such an incinerator near your home? Review of
available literature reveals the following problems with these

1. Monitoring of smokestack emissions is very crude. Hazardous
chemicals coming from the smokestack are not monitored. Instead, benign
chemicals (such as oxygen and carbon dioxide) are monitored, and based
on these readings, estimates of toxic emissions are developed. When the
oxygen or carbon dioxide levels show something is wrong, it is
guaranteed that toxic emissions are occurring, but there is no reliable
way to estimate the quantity of toxic chemicals being released into the
local air.

The emission of particulate matter (ash, soot) is especially difficult
to control, is especially hazardous to human health, and is subject
only to the crudest of regulations. We will discuss this subject at
length in a future newsletter.

2. A single trial burn provides the basis for establishing that the
machine emits tolerable quantities of toxic pollutants, and on the
basis of the single trial burn, the machine is licensed to operate for
up to 10 years. Unfortunately, the wastes burned during the trial burn
are very likely not the wastes that will be burned during the active
life of the machine, and the carefully-controlled conditions during the
trial burn are unlikely to mimic the reallife conditions under which
the machine will operate day after day, so the information gathered
during the trial burn may be irrelevant and misleading.

Since the chemicals used by industry change frequently, it is
impossible to predict today what will be contained in tomorrow's
wastes. This means the operators of hazardous waste incinerators are
often out on a frontier, dealing to some extent with the unknown.
Furthermore, the wastes coming into an incinerator are usually not
carefully sampled to see what they contain. For example, a drum may be
opened and visually inspected, or a sample may be drawn from the top of
the drum, but heavier chemicals may have settled into the bottom of the
drum and may not be sampled at all.

3. All incinerators undergo frequent periods of "upset" during which
the machine is not operating under ideal (or even tolerable)
conditions. During upsets, the emission of toxic chemicals can reach
very high levels. Puffs of heavily contaminated smoke are emitted into
the neighborhood. Upsets may occur many times each day.

4. Products of incomplete combustion (PICs) are chemical compounds
created inside the combustion chamber where different wastes mix
together in the presence of high heat. If conditions in the combustion
chamber are not ideal for destroying the chemicals, new chemical
compounds--some of them more toxic than the hazardous wastes from which
they are derived--are created and then released from the smokestack.
PICs may be formed during upsets, they may be formed when the
incinerator is started up or shut down, and they may be formed when a
new type of waste is introduced into the combustion chamber. Many
different malfunctions of the machine may also give rise to PICs from
time to time.

5. Fugitive emissions. These are unplanned and unintentional releases
that occur through spills, leaky valves, cracks, damaged drums, and so
forth. Fugitive emissions may exceed the amount of toxic chemicals
released intentionally from the smoke stack each year.

6. Explosions. It does not happen often, but hazardous waste
incinerators can explode, spewing chemicals into the local environment.
Naturally, it is impossible to accurately monitor emissions from an

7. Federal regulations require the destruction of 99.99% ("four nines")
of the waste entering an incinerator. However, a typical incinerator
will process more than 36 million pounds of hazardous wastes each year.
With no unexpected releases, no upsets, no fugitive emissions, and no
accidents, such an incinerator would still emit 3,600 pounds (nearly
two tons) of hazardous chemicals into the local environment each year.
Thus "four nines" destruction and removal efficiency (DRE) may sound
very good, yet it still allows release of large quantities of chemicals
which may pollute the neighborhood severely.

8. Large quantities of hazardous fly ash and bottom ash are produced by
such an incinerator and must be landfilled somewhere.

9. State and federal oversight of such facilities is generally lax.
Almost everywhere, governments have a poor record of enforcing existing
laws and regulations. It's as if they are afraid to admit they created
intractable problems when they issued the original permit, so they
close their eyes and pretend that all is well.

10. Hazardous waste incinerators give the illusion of providing a
technical fix to the hazardous waste problem. They lull the public into
thinking such problems are solved when, in fact, they will not be
solved until pollution prevention comes into wide practice and
industries reduce their use of hazardous chemicals.

For further information:

Joseph Santoleri and others. "Design and Operating Problems of
Hazardous Waste Incinerators." ENVIRONMENTAL PROGRESS Vol. 4 (Nov.,
1985), pgs. 246-251.

William P. Linak, and others. "On the Occurrence of Transient Puffs in
a Rotary Kiln Incinerator Simulator." JOURNAL OF THE AIR POLLUTION
CONTROL ASSOCIATION [JAPCA] Vol. 37 (January, 1987), pgs. 54-65.

INCINERATOR [EPA/600/S2-87/064]. Springfield, VA: National Technical
Information Service [NTIS], Nov., 1987. Available for $24.95 from NTIS,
5285 Port Royal Rd., Springfield, VA 22161; phone (703) 487-4650.

--Peter Montague



The meeting in Pittsburgh Oct. 1 (see RHWN #96) was called to plan
direct actions to stop pollution, to strengthen democracy at the local
level, to build the grass roots toxics movement. It brought 18 people
together from across the country to describe their local situations, to
dream strategies and tactics for a different future, to begin something
new for the toxics movement. The meeting was called by Richard
Grossman, editor of the WRENCHING DEBATE GAZETTE.

The next WRENCH meeting will happen Dec. 3 and 4 near Wichita, KS,
starting at 10 a.m. at Spear's Restaurant, 239 West Greenway, in Derby,
KS; the phone there is (316) 788-5517. On the 3rd, the group plans a
non-violent demonstration against local chemical poisoners, to observe
the 4th anniversary fo the Bhopal massacre. The Wrench group is
growing, and everyone is welcome. Probably the key agenda item will be:
what's next? For more information, phone Lauri Maddy at (316) 776-0921
or Donna Hinderliter at (316) 524-5719, both in Kansas, or Richard
Grossman at (202) 387-1000. If you're not already, you should be
reading the GAZETTE, which is free. Write: GAZETTE, 1801 Connecticut
Ave., NW, Washington, DC 20009.

--Peter Montague


Descriptor terms: incineration; hazardous waste incineration; fine
particles; air pollution; pics; landfilling; citizen activism;