Re: EPA to require incineration of VC/EDC wastes

["Alex J. Sagady & Associates" <ajs@sagady.com>]

At 02:50 AM 08/30/1999 -0400, you wrote:
>..not quite an absolute requirement, under RCRA Land Disposal
>Restriction's  Universal Treatment Standards, but to all practical effects
>& purposes it is...  So, e.g., that octa-CDD/F under this rule would be
>added to the list of RCRA wastes  for the 1st time (because EPA is using
>the TEF in dioxin regulations, see next p'graph) could well be a bad thing,
>as it may cause more cholorinated wastes to be burned.  Nothing new--e.g.
>the whole country is now laboring under the same scenario for the hundreds
>of pentachlorophenol production and superfund wastes sites, where as of
>last year the only (actual or practical, not sure which) treatment allowed
>under the LDR's is incineration.  Chlorine in = O-cl's out...  So I suppose
>it's "good" some of these wastes are going to be allowed to be managed in
>landfills instead of being land disposal banned.

Tony, why are you supporting an industry position that would undermine
the Resource Conservation and Recovery Act land ban for disposal of 
problematic wastes??

In the larger scheme of things, thermal treatment/incineration of these
wastes will prevent
more contamination of the environment.

The whole reason the land ban was enacted was to keep wastes whose 
toxicity could be reduced from being disposed of landfills.

Why environmentalists would join with the Chemical Manufacturers Association
and the waste-industry influenced revisionist elements at EPA to undermine
the land ban is beyond me. 

While EPA's proposed standards for hazardous waste incinerators are
in many respects disappointing, I'd much rather see VC production wastes
and other chlorinated aliphatic wastes
being incinerated than being sent to landfills.   

EPA's database on hazardous waste combustors shows that there is a
10,000 fold difference between the worst and the best hazardous waste
combustors when it comes to PCDD/PCDF emissions.

EPA's new MACT standard for hazardous waste combustors,
even though it is probably 40 times too high for
PCDD/PCDF emissions compared to what this technology can achieve
(and what enviro's will try to enforce in the courts), and still
disappointing in many ways,
will still result in significant PCDD/PCDF emission reductions
at many hazardous waste combustor sites.

Zero emissions should still be the goal, but not if it means
that 100% dispersal of toxicants are implicit by disposal to the environment in 
another medium.   And failure to quantitatively assess
the impact of emissions....assumming that it makes no difference whether
emissions are 0.2-0.4 ng/dscm as opposed to 20+ ng/dscm....  this
isn't too realistic of a path either....   There IS a difference between
the best controlled and the worst controlled units and pretending 
that there isn't abdicates a common sense approach to understanding
the impacts of emissions on environment and public health.


>EPA again shows it is moving away from dioxin regulations based on
>2,3,7,8-TCDD alone (due to its relatively well characterized risk) to regs
>based on the 17 2,3,7,8-substituted congeners (as these all all thought to
>have a common mechanism of action, binding the Ah receptor, that activates
>toxicity; their different ability to bind the receptor indirectly allows
>them to be assigned relative toxicity equivalency factors (TEFs), from 0 to
>1.0).  So again, an otherwise positive move'll mean that more dioxin
>bearing wastes will be incinerated. 

I don't buy this either....   past sole reliance only on regulating the most
toxic congeners of PCDD/PCDF has meant far less environmental control.
For example, a number of wastewater permits I've reviewed only deal with
2,3,7,8 TCDD
and ignore the other congeners.   It is a good thing that all of the congeners
will be regulated and come under control






----------------------------------------------------------------------------
Alex J. Sagady & Associates        Email:  ajs@sagady.com

Environmental Enforcement, Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

PO Box 39  East Lansing, MI  48826-0039  
(517) 332-6971 (voice); (517) 332-8987 (fax)
----------------------------------------------------------------------------