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Re: GP sampling
At 10:48 PM 7/29/97 -0400, email@example.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
>HAVE ESCAPE VENTS (the DUMP STACK)
>WHICH ARE NOT MONITORED.
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
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
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
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
>because CEMENT KILNS CANNOT BE TUNED TO
>HAVE EXTREMELY HIGH DESTRUCTION and REMOVAL
>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.
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
>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
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: firstname.lastname@example.org
Environmental Consulting and Database Systems
PO Box 39 East Lansing, MI 48826-0039
(517) 332-6971 (voice); (517) 332-8987 (fax)