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Re: GP sampling

  At 10:48 PM 7/29/97 -0400,  jon@cqs.com wrote:
  The name is "Alex"....
  >Please wake up and smell the dioxin. If the wastes are
  >taken to a rotary kiln incinerator, they most certainly make
  >it to the air because ALL ROTARY KILN INCINERATORS
  A hazardous waste incinerator's dump stack
  is not an emission point that is designed to continuously
  emit to the air.   The principle purpose of a dump stack is
  for emergency conditions to avoid explosions, to deal with
  other types of malfunctions (such as loss of quench and 
  scrubber water supply) and to deal with the problem of 
  excessively high BTU/high volatility liquid wastes that are
  inadvertantly introduced into hazardous waste incinerator
  rotary kilns.
  A hazardous waste incinerator operator can ensure
  that dump stack openings will be absolutely  minimal  if they do 
  the following things:
  1.  They must  ensure that all liquid wastes are blended prior to
  introduction to
  burning units at hazardous waste incinerators and that containers of
  liquid wastes are kept out of flows of containers of solid wastes.
  2.  They must do intensive  preventive maintenance on scrubber
  water supply and pumping systems to ensure that there is 
  no interruption of quenching of hot flue gases.
  3.   They must  carefully meter the flow rates for solid wastes and
  they ensure that large amounts of explosive wastes 
  are not introduced to rotary kilns in large batch units.
  4.   If the dump stack opens, they can reduce emissions by
  immediately ceasing waste/fuel feed, switching to 
  natural gas, cutting air flows and reducing rotary kiln 
  If they do these things, then the usual downstream air pollution controls 
  can do the job they were intended to do 99+% or greater of the 
  time.   There have been many times in the past when 
  hazwaste incinerator operators have not done a good job on 
  these matters.  That doesn't mean that it is not possible to
  do the job correctly.
  The problem, which you don't want to acknowledge, is that the 
  performance of those air pollution controls varies enormously
  between different facilities causing dramatically varying 
  emissions from site to site, both for the class of hazardous waste incinerators
  and for the separate cement kilns class.  Differences that can be up to a
  factor of 
  10,000 from the highest emitting hazardous waste incinerator
  to the lowest emitting hazardous waste incinerator (and 
  similarly for hazardous waste burning cement kilns).
  You just can't pretend that the same level of health and environmental
  concern should exist for different pollution emitting units that
  have emissions that vary by these amounts.
  The "worst" deserve the bulk of the effort, concern and campaigning  first...
  > If they are burned in
  >a cement kiln, they most certainly make it to the air
  >EFFICIENCY! (Their parameters are rather rigid for highest
  >quality cement production, not designed to be
  >tunable for burn efficiency and cleanliness for every
  >kind of fuel they are burning)
  Folks like John Pruden and myself have been trying to 
  tell people for a long time that cement kilns are serious
  dioxin and air toxics emitters.   And here is one case
  where EPA's proposed rules actually deserve the kind of 
  hard line criticisms from the anti-dioxin movement
  that you and others been talking about  ("institutionalizing the 
  status quo" ).   Despite the seriousness of this rulemaking,
  there really has been no sustained, concerted, loud response from the
  grassroots  anti-dioxin movement.   Yet these rules, for all 
  practical purposes, will be the "ball game" on hazardous 
  waste incineration for years to come...
  I recently wrote comments on these proposed rules for a  major
  national non-profit public health association.
  In the comments,  I calculated the permissible mass per unit time emissions
  that would be allowed under the rules for the example 
  facilities EPA cites in their background document.   The 
  results are troubling and illustrate the kind of 
  cement kiln blindspot that the both the anti-incineration/dioxin 
  movement and U.S. EPA has had.   
                                      PCDF ng
  Case	Type	TEQ/Hour
  K1	LWAK	7.90E+03 
  J	LWAK	9.55E+03 
  K3	LWAK	1.09E+04 
  K2	LWAK	1.26E+04 
  G	HWI	1.30E+04 
  I	HWI	7.16E+03 
  E	HWI	1.14E+04 
  A	HWI	9.26E+03 
  C	CK	4.81E+04 
  B2	CK	9.80E+04 
  B1	CK	9.80E+04 
  H1	CK	7.60E+04 
  F	CK	1.21E+05 
  D	CK	6.45E+04 
  H2	CK	7.60E+04 
  Thus, EPA's proposed rules would allow the highest 
  permissible mass per unit time emissions for a waste burning
  cement plant (B2+B1) to be over 15 times the 
  amount of the dioxin emissions
  of the highest permissible emitting hazardous waste incinerator (G)
  It is worse on toxic metals....
  The permissible mass rate emissions for mercury would be 27 times for
  the largest cement plant compared to the largest hazwaste 
  The permissible mass rate emissions for lead and cadmium from the 
  largest waste burning cement plant would be 101 times the permissible 
  emissions for the largest hazardous waste incinerator.
  The permissible mass rate  emissions for chromium, arsenic, berylleum
  for the largest waste burning cement plant 
  would be over 17 times the  permissible rate for the largest hazardous
  waste incinerator. 
  >You are comparing the activities of an organization
  >committed to the environment and the continued
  >habitability of the planet, who sometimes need to
  >break the law to get the information they need,
  >with companies that have purposely hidden important
  >data from the public and have made deals with the
  >EPA administrators to do so. I find that comparison
  >appauling. Greenpeace's activities are not "Black Bag
  >Jobs". I already stated that there were times when
  >higher laws take precedent.
  >Why are you so concerned what Greenpeace does?
  >Whether Greenpeace got their samples by scaling a fence
  >or politely asking Dow, etc. to let them scoop it up is
  >really immaterial. They have not harmed the companies'
  >property, or stolen data so it cannot be used. They
  >have not threatened anyone. They merely
  >made public what should rightly be public, and I frankly
  >don't care if they broke trespass laws in order to do that.
  >"Black Bag" jobs are done to threaten, harass, and steal
  >data to make it unavailable for use. Greenpeace was
  >doing the opposite - sharing data that would normally be
  >kept secret!
  When "God is on my side" anything goes, eh?? 
  >From my admittedly jaundiced viewpoint in Michigan, I see 
  Greenpeace come to town, pull a publicity stunt, send
  the canvasers around and then leave town.   I don't
  see any determined, concerted depth or staying power on 
  site related issues with infrequent exception.  And
  working site issues...issues of air, water and land
  contamination...is where the "rubber meets the road"
  at getting real, on-the-ground results for people, their
  communities and their environment.  Getting improvements
  in these kind of situations frequently takes 2-5 years,
  but Greenpeace never stays around long enough  to get anything
  Up on Lake Superior in Canada there are a number of kraft pulp
  mills which have long histories of dumping uncontrolled
  water pollution in Lake Superior.  But on an issue
  that ostensibly is "owned" by Greenpeace they are nowhere
  to be found with a consistent, persistent effort
  targeted on such sites of gross pollution and resource
  Alex J. Sagady & Associates        Email:  asagady@sojourn.com
  Environmental Consulting and Database Systems
  PO Box 39  East Lansing, MI  48826-0039  
  (517) 332-6971 (voice); (517) 332-8987 (fax)