Re: EPA to require incineration of VC/EDC wastes

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

 At 01:53 PM 08/30/1999 -0400, you wrote:
>>In the larger scheme of things, thermal treatment/incineration of these
>>wastes will prevent
>>more contamination of the environment.
>
>Burning these wastes simply puts dioxins, etc. into the lungs 
>of the general public.  It should be opposed, and be a 
>point of no negotiation, period, in my opinion.  The 
>world has too much going up in smoke as it is, 
>without adding more dioxins and the like into the air.  .
>Joe
>NJ/NY Environmental Watch

Joe, I remember a time prior to RCRA when routine industrial procedure was
to take liquid and solid hazardous wastes and dump them untreated
into ordinary municipal landfills.   We're still dealing with the results of
these practices 
today in the form of uncontrolled/poorly controlled/poorly characterized
release of toxicants into air, surface waters and groundwater.

This kind of landfill disposal will emit far more....by many orders of
magnitude....
emissions of airborne toxicants to ambient air than sources that either 
incinerator or treat, and still create actual/potential threats to ground
and surface 
water.  In quantitive terms the absolute magnitude of the risks to public 
health and environment will be far greater from this type of disposal practice.

In the case of vinyl production wastes, such disposal would mean emissions
of a powerful
liver carcinogen, vinyl chloride monomer.

Alternative means of hazardous waste disposal may
not be available for all types of wastes in all media in which they may 
come.   When all is said and done, some of the alternative technologies will not
also not perform as well as claimed with, for example, incomplete dechlorination
of chlorinated compounds, partial destruction efficiencies, creation of
residual wastes
and other problems.

In 1984, Congress enacted amendments to the solid waste disposal act that
ended uncontrolled disposal in MSW landfills.   Disposal of hazardous wastes
could no
longer take place in ordinary urban landfills (except for exempt small quantity
generators), and hazardous wastes that exhibited certain characteristics
would have to be treated before they could be disposed of in any kind of 
hazardous waste landfill.....and any residuals from a process in which hazardous
waste was handled/treated would have to go to a hazardous waste landfill
instead of an ordinary landfill.

Industry has fought these changes all along.   Even now, EPA and the states
continue to weaken standards on cleanup of existing contamination, allowing
highly threatening waste contamination to stay in place, allowing disposal 
of persistent bioaccumulative toxicants from cleanups in ordinary landfills 
without treatment, allowing "cap it and leave it" strategies for open bottom
landfills to continue groundwater contamination, allowing higher and higher
concentrations of toxicants in soil to which the public will be exposed at
brownfields, 
allowing uncontrolled disposal of PCB capacitors in MSW landfills, etc.

While there are plenty of alternative means of dealing with municipal solid
waste
and medical waste, and thus means by which MSW/medwaste  incineration can be
avoided altogether,
there are fewer alternatives available for dealing with hazardous industrial
waste.
There have been a lot of efforts made to reduce waste generation through 
changes in industrial processes, materials substitution, pollution prevention, 
and toxics use reduction.  But all of these efforts aren't going to take the
burden of industrial waste to zero.  In fact, TRI data shows that industrial
waste streams have, at times, increased with the control of air and water 
pollution in traditional abatement settings.

I find it outrageous that the environmental community would now advocate 
landfilling of untreated hazardous waste in order avoid confronting, in one
form or another, treatment of those wastes to render them far, far less of a
long term threat.     This would be just about as big as a mistake as
the last ten years of "ban the burn" activity on hazardous industrial waste
that led to a shift of the vast
majority of hazardous wastes going to cement kilns with far poorer controls
and much higher inherent emissions than from other types of combustion 
devices..... frequently with orders of magnitude less emissions than 
come from cement plants.  

>From an environmental performance 
standpoint, the "ban the burn" ideology only shifted the problem to 
far worse performing players who remain unchallenged, for whatever
reason......be it environmental community mismanagement of the issue,
failure to take the broad
view, fear of dealing with an even more powerful industry, or a misguided
acceptance of a view that getting rid of vinyl plastics would somehow solve
the problem for good (a mistaken notion promoted by Greenpeace).....

The real issues that remain that need citizen attention are the treatment
methods to which wastes should be subject, how emissions are controlled, 
the level of performance of treatment technologies,
what level of enforcement and monitoring is done, where facilities are
sited, assessment of all exposure pathways and limitation of risks, and
other questions.

To an even greater extent on the issue ....is the need for a quantitive view
of these issues.....to ignore
the differences between sources that emit toxicants, including PCDD/PCDF, at 
mass rates that differ by 4-5 orders of magnitude and to somehow lump it all
together...is 
to ignore a fundamental responsibility to the public health and environmental 
concerns that should be motivating an entire movement.
 
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Environmental Enforcement, Technical Review, Public Policy and
Communications on Air, Water and Waste Issues
and Community Environmental Protection

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