EPA's MACT standards on Hazardous Waste Combustors

["Alex J. Sagady & Associates" <asagady@sojourn.com>]

....I've been working on drafting comments concerning the
 EPA Maximum Achievable Control Technology
standards under the Clean Air Act for hazardous waste combustors.

Many environmentalists who have been observing these standards
may be under the impression that the dioxin/furan emission limits are
less stringent than the European Union guidelines of 0.10 nanogran per
dry standard cubic meter, and previously advocated that EPA
adopt the European Union number.   When EPA previously published
their CETRED document, it appeared that EPA was going to adopt
a dioxin emission number that was twice the EU number.

However, in EPA's April 19, 1996 Federal Register Notice, EPA finally
displayed these two proposed standards in common format
with the same correction.

EU's dioxin/furan number is 0.10 ng/dscm corrected to 11% oxygen and
0 degrees C.   However, EPA finally converted EU's number to the 
US format for correcting emission limitations (7%oxygen and 20 degrees
C).   It turns out that  EU's dioxin emission numbers are equivalent to 
0.19 ng/dscm corrected to US format (7% oxygen and 20 degrees C).  

EPA is proposing a number only slightly higher  ....  0.20 ng/dscm (7%
oxygen, 20 degrees C)


Some of the other EPA proposed MACT emission limits are significantly
higher, however.  For example, the HCL and CL2  and particulate matter
proposed emission numbers are significantly higher that the EU numbers.

See the table on Page 17411 of the April 19 1996 Federal Register.


Here is some other interesting information from EPA's FR notice
(See page 17366)

Currently emitted mercury emissions per year, nationwide:

All Hazardous waste combustors ---  11.1 tons of mercury

        of this,  hazardous waste incinerators emit  4.6 tons/year
        and,    cement kilns and aggregate kilns emit 6.5 tons/year...


Currently emitted dioxin/furan per year, nationwide

All hazardous waste combustors  -- 122 pounds total congeners/
2.15 pounds TEQs

       of the HWC total....

        .....  9 pounds (total congeners)/;0.2 pounds TEQ come
                 from hazardous waste incinerators

        .....  113 pounds (total congeners)/1.95 pounds TEQ come 
                from cement and aggregate kilns

See page 17366, April 19, 1996 Federal Register...

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When are all of those Missouri, Kansas and South Carolina 
enviros going to wake up to the fact that they may want
to pay some attention to all of the cement kiln hazwaste
burning going on in these three leading hazardous waste
disposal states????   (Maybe Lousiana should also be
included given Marine Shale, but I heard they just 
stopped burning there)....  Particularly in Missouri,
which is the number one hazardous waste burning
state in the US....   but not because of the Times Beach
Incinerator!!!!!   

And you Tar Heals in North Carolina...you'all want
to know that Carolina Solite in Albermarle is fixing
to have four kilns burn hazardous waste when they
only had one burning before.... and that all of the
waste that Solite used to burn in Florida is 
now going to come to your state to be burned....

And folks out in Pennsylvania....  how about paying
some attention to plants like the Medusa Cement
company in Wampum, PA???....  It is not all that 
far away from the WTI hazwaste incinerator
across the border in OH....but
it emits on the order of 100 times the amount of 
dioxins compared to the WTI plant!!!!
And they have been in violation of air pollution
requirements at this site....

And hey, Indiana, wake up to the two waste
burning kilns in your state, and the Cadence
Chemical plant in northern Indiana which
"blends" hazardous waste from all over the
US and sends it out to kilns to be burned.....

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