Re: New Incinerator Scheme

[asagady@sojourn.com]

At 12:19 AM 12/23/96 -0500, you wrote:
>This is my first post to these lists, so I beg pardon if not appropriate.
>
>We are in the early stages of reacting to a scheme for a mass-burn municipal
>waste incinerator in New Castle County Delaware near Wilmington.  (This, if

[snip]

>"In July 1989 an emission test program...indicated that, at times, extremely
>high levels of total dioxins were emitted....The stack tests indicate that
>dioxin levels are an order of magnitude ligher than the future expected
>emission requirements."  An accompanying table shows dioxin levels of
>"100-600 ng/dscm"). (I have not yet gotten the complete stack test report.)
>
>Finally to my questions:  Just how high are these dioxin levels in light of
>current knowledge?  Any sense of whether dioxin emissions at these levels
>would likely produce measurable or observable health effects in nearby
>residents?  (Of course, high levels of HCl and SOx were emitted due to
>absence of acid gas scrubbers.)  Where should we go from here on this?
>
>Thanks in advance.
>
>Alan Muller
>Green Delaware
>

Those are high dioxin numbers, although you don't say whether the numbers
are in TEQs  (Toxic Equivalents) or in total dioxin congeners.

By way of comparison, if my memory serves me correct, EPA's 
recent municipal waste combustor standards for large 
MW incinerators are.....

Existing municipal waste combustors:
30 ng/dscm  (nanograms per dry standard cubic meter) (Total congeners)

New municipal waste combustors:
15 ng/dscm  (total congeners)


EPA's proposed medical waste standard:
1.9 ng/dscm  (total congeners)


EPA's Proposed new and existing hazardous waste combustor 
maximum achievable control technology standard:
(for hazardous waste incinerators, hazwaste burning cement
and lightweight aggregate kilns).....
0.20 ng/dscm  (TEQs)

TEQs are roughly 15-30 times less than total congeners, for ballpark
conversions...

The worst waste combustors are far as dioxin emissions are concerned
are generally those with flue gas temperatures of 450-650 degree F
at the inlet to the air pollution control device.  However, not all waste
combustors with flue gas temperatures outside of this range have low
dioxin emissions....

Your post is not completely specific as to whether this will be 
a completely new mass-burn incinerator or a retrofit of a new
incinerator.    Here in Michigan, a garden-variety old  high emitting
incinerator in Dearborn Heights MI is planning a switch to 
energy recovery.  EPA Region 5 concluded that this existing
source was to be treated as a new source because of the 
amount of investment that was required.  As a result, they will
have to comply with more stringent EPA rules for new sources.

One of the weakest links in the whole promotional matter of
building these plants is economics.  Many of the plants will
frequently not have enough waste to justify the size of the 
operation, or they will try to enact flow control ordinances that
have the effect of eclipsing recycling efforts in order to preserve
enough waste to run the plant.   Be sure to examine the bonding
documents and report of bond counsel.

Unfortunately, on the negative side, some of our federal laws
designed originally to favor solar energy electricity producers
are now regularly used by waste burning facilities to ensure
a "replacement rate" for electricity that local utilities must purchase
from such energy recovery operations at waste burning plants.  This
is an artificial economic subsidy for waste burning operations.

As far as predicted risk from these plants, if the sources operate
in compliance with EPA's MSW emission standards, they will 
probably be able to demonstrate compliance with state-based
ambient dioxin risk screening levels for the inhalation route.  This type of 
risk assessment, however, does not deal with cumumlative 
environmental and ecological  impacts or non-inhalation routes of exposure.
This
type of analysis is generally not required for MSW plants, but is now
being required for RCRA permits for hazardous waste combustors
(but these same analyses are also  being done poorly
by EPA, particularly in Region 7 and particularly for waste burning 
cement kilns.)

The achilles' heals for MSW plants are, in general,...

high emissions for poorly designed and operated plants

introduction of small quantity hazardous wastes to MSW plants

improper operation due to poor operator training

uncontrolled emissions during dump stack events

uncontrolled emissions from poor ash handling

high cost, undesireable economics, coupled with local municipality financial
    gullibility.... when other alternatives are better/cheaper

poor ash disposal practices causing air/water pollution

failure to consider inhalation toxicity potential from metals
   and PCDD/PCDF in ash residuals

failure in the US to require separation of fly ash (more toxic) from
    bottom ash

poor maintenance of air pollution controls leading to high emissions

undesireable flow control ordinances

fudging ash toxicity testing by lime incorporation to "cheat" on TCLP test
     for metals hazardous waste designation

availability of inexpensive landfill space...cheaper than incineration

failure to do toxic source reduction in conjunction with a mass burn
    plant leading to high lead and mercury emissions and ash 
    contamination  from batteries getting into the incinerator.

adverse effects on recycling

technical difficulty in controlling mercury emissions and pre-existing
    ambient mercury contamination problems leading to increased
    mercury related risks.

failure to require or incorporate new and emerging technologies for
   continuous stack emission monitoring of toxic metals

potential for catastrophic fires and explosions in waste derived fuel
preparation 
    plants

potential for explosions and release of pyrolosis products from 
    MSW plants incorporating alternative pyrolizing waste reduction methods

from an electricity buyer standpoint, poor reliability on continuous uptime
    for electricity generation  (i.e.  plant malfunctions, lack of waste to
burn...)

occupational exposures


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Environmental Consulting and Database Systems
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