EPA's MACT, HWI's and dioxin

[charlie.cray@green2.greenpeace.org]

----------
Original-TO:      dioxin-l@essential.org
----------
Alex--
 
In your memo on the new CAA MACT standards you cite a figure on 
dioxin emissions from incinerators:

 
"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...
 
(Having not reviewed the rule, I assume this figure only covers 
commercial incinerators, kilns, etc.?)
-----------------------------------------------
(turn tirade mode on)
I agree with you about the attention deserved to the states that 
host a lot of kilns (e.g. Missouri), esp. given the fact that 
they are surrounded by agricultural areas.
 
Another problem with EPA's rule is that it exempts on-site BIFs 
and HWIs, which have been put off until phase 2, along with all 
the other categories of combustors.  The importance of this is 
that some of these incinerators burn the most highly-chlorinated 
wastes generated and probably release more dioxin than any other 
kind of incinerator.  

 
The vinyl chloride manufacturers, for instance, burn thousands of 
tons per year of "tars" from EDC/VCM production, which have high 
levels of PCBs and dioxins.  Dow's VCM wastes are documented to 
contain up to 320 ppm PCBs.  We sampled a barrel of distillation 
tars from Vulcan and found 6 ppm TEQ dioxin!  Since they also 
contain (in some instances) copper catalysts from the reaction 
process, they not only release uncombusted dioxin, but most 
likely form all sorts of PICs.
 
Some of these facilities (like PPG in Lake Charles) not only burn 
their own wastes, but those of other companies.  Must be 
lucrative. 
 
EPA also failed to look closely at these incinerators as part of 
its Dioxin Reassessment source inventory.  Industry has failed to 
submit any data as part of its voluntary self-characterization 
scam (they are testing water etc. first), though they know that's 
likely to be the largest source of dioxin from production plants.  
 
Dow has 18 on-site HWI's and BIFs at its Freeport facility alone.  
A week or so before their shareholders' meeting this May they did 
a press conference at the National Press Club in DC claiming (for 
the second time) that they will get 90% dioxin reduction in the 
next ten years.  Either they are lying because they have no 
baseline of data to stake this claim upon, or they have failed to 
cough up the data for the EPA's call-in.  Which is it?
 
Some of the VCM plants (like PPG and Borden) still use mercury in 
their chloralkili process.  PPG has a mercury recovery unit 
which is also likely to be a significant source of mercury.  
Unfortunately, I don't have exact figures.
 
(end tirade)
----------