Re: EPA to require incineration of VC/EDC wastes

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

At 12:52 AM 09/01/1999 -0400, you wrote:


>Alex, you say enviros supported the cement kiln industry burning haz waste.
>This is wildly untrue!  It was that industry, not enviros, that had secret
>meetings w/ EPA, which then illegally issued "technical" (no public comment
>needed) ammendments to allow the industry to burn haz wastes, as you say,
>w/out controls.  It  was enviros who protested this, w/ honest disclosures
>from the likes of EPA's Wlm Sanjour.  I don't know any enviros who support
>the haz waste cement kilns...can you support it?

No I don't....

Now in your state of Montana, the enviros did a great job of running 
off Ash Grove Cement and the one other company whose name escapes
me that tried to import hazardous waste as fuel.   That whole operation
that you, MEIC and others ran was very effective.

Down in Texas they've tried as hard as they possibly could but they still
haven't made any ultimate  headway against the hazwaste burner with the largest
capacity in the US.....TXI Cement in Midlothian TX....but the citizen effort
has still been
outstanding.

And out in California they won their issue with National Gypsum after a big
citizen effort.

And up in Alpena MI, the citizen effort on cement kiln incineration has also 
been outstanding, and Lafarge is just about ready to throw in the towel after
having announced they will quit burning hazwaste by sometime in early 2000.

And down in Florida, Florida Solite never knew what hit them....with the citizen
effort down there not far from Jacksonville.

But everywhere else, it is a handful of citizens opposing cement kiln hazwaste
incineration but with very little support, leadership, recognition or
coordination
from either national  or state organizations.....or there is absolutely no 
effort, activity or awareness at all...like in SC, MO, OH, IN

Marine Shale could bounce back into operation in LA, which had been the 
largest burning recipient in the US for a long time before EPA shut them 
down.

My point is the "ban the burn" as a strategy and ideology on hazardous waste is
very ineffective, given the massive shift to dirtier cement kiln hazwaste
incineration,
with only token opposition from a national environmental community
standpoint.   And "ban the 
burn" isn't even in the ball park when it comes to recognizing other large
PCDD/PCDF
sources....such as cement plants that don't burn hazwaste....    


>This brings up the real issue.  I hope from my original comment it was
>apparant I wasn't really promoting the landfilling of these wastes (rather
>saying landfilling may be less risky).  Enviros don't support land disposal
>of haz waste.  It's been a good while since I've been trapped 'NOT thinking
>outside the envelope' on this particular question!  You address it with the
>explicit assumption that industry has to produce some haz's waste.  In the
>instant matter, you say Gpeace's position of banning chlorinated vinyl
>plastics is wrong or ineffectual (but don't elaborate.

Greenpeace has portrayed the anti-PVC plastic issue as though it
is the major problem with PCDD/PCDF emissions from combustion 
sources.   But given the large differences over several orders of magnitude
of PCDD/PCDF emissions from different waste combustors burning similar
wastes, such
a position is a gross over-simplification/distortion of the issue.   You
could completely
eliminate PVCs from the waste stream and still have high PCDD/PCDF 
emissions from, for example, MSW waste combustors.  The PCDD/PCDF
emissions are far more related to other factors (i.e. flue gas temperatures, 
efficacy of air pollution controls, combustion characteristics, etc.).   It
takes
precious little chlorine, which is ubiquitous, to form the chlorine content
of PCDD/PCDF emissions coming from the absolute largest source.
Chlorine from plastics or organic chemical sources is not necessary to form
PCDD/PCDF.....table salt injected into a zone of poor combustion with the
wrong flue gas conditions will also form very significant PCDD/PCDF.

>From my standpoint, the Greenpeace argument that PVC is the main cause of the 
PCDD/PCDF problem is grossly oversold.  In fact, I'd make the 
argument that the anti-PVC emphasis concerning PCDD/PCDF distracts
from a real problem assessment on solving the PCDD/PCDF problem.

I think the citizens down in Columbus OH had it right with working a 
"worst first" approach in addressing the dirtiest MSW combustor apparently 
in the country.   "Worst first" means figuring out who is the worst threat to 
public health and environment and focusing your attention there, be it on 
cleanup or shutdown or change in societal practices.

>Similar arguments apply to other chlorine uses.  We who support Gpeace's
>early call for phasing out most uses of chlorine challange opponents of
>that to show their logic!  (I can do a lot better at postulating it than
>the above, so I apologize for its form).

Given all of the ubiquitous naturally occurring forms of organo-chlorines,
one has to 
ask what are you going to achieve???   ...and how effective can an
"anti-chlorine
ideology" be.   I see virtually no support from the toxicology profession,
being university types or others, for an across the board ban on chlorine....it
isn't going to happen.   In fact, societal use of chlorine has continued to 
rise, relatively unabated.....Greenpeace just isn't getting any traction on it, 
and if they were there would be a very substantial effect on chlorine use by
now....
after several years of effort....but they are spending lots of contributor
dollars
that could go into other types of environmental improvement and natural
resource protection activity, not the least of which would be more assistance
of citizen grass roots and community environmental protection efforts
that are really needed (especially in places like TX, SC and LA).

The problem isn't chlorine use, per se.  The problem is production of 
materials or operation of processes that have an adverse impact.   
The task is to identify the emissions, the impacts and to do something
about it after setting priorities.   Adopting an ideological approach, 
like the anti-chlorine campaign, is not helpful to this process since it is
like strapping on a set of blinders that keep you from seeing what is actually 
happening.

Now don't get me wrong....certain practices involving chlorine uses have 
been tremendously destructive.    For example, molecular chlorine bleaching
of pulp is a very destructive practice....I've been actively working to end
this type of bleaching at a PA paper mill for one of my citizen group clients.
Using Cl2 to bleach pulp produces a plethora of undesirable highly toxic
compounds
in bleach plant wastewater.   Using chlorine dioxide reduces, but does not
eliminate, the generation of some of the same compounds....for example you
can still get measurable 2,3,7,8 TCDF (still highly toxic at 1/10 the 
potency of 2,3,7,8 TCDD) in wastewater effluent from chlorine
dioxide bleaching.

My point  is that the citizen environmental movement needs to 
keep its eyes wide open as to what is actually happening....
and the real impacts of emissions on public health and environment; and not
substitute an ideology for an environmental science approach to the issues.
....or even worse, to adopt an anti-science, anti-technology approach....

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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  
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