Incineration a Failed Technology
Here is a brief summary of a few issues to challenge the incinerator.
1. All incinerators—even the best— produce air pollution and significant
amounts of it will be highly toxic, because incineration creates exceptionally
toxic chemicals in these processes which are not contained in the original
materials being burned such as dioxins, dibenzofurans, PCBs, polyaromatic
hydrocarbons, toxic particulate matter, acid gases, and many other pollutants
including toxic heavy metals.
2. Trial burns. Many incinerators fail to meet the requirements of the Trial
Burn without cheating in some way on the test, but even if the trial burns are
passed, the units may not come close to operating as efficiently during normal,
day-to-day incineration operations versus the Trial burns. Trial burns do not
represent normal daily burn conditions as the tests are more like staged events
using surrogate chemicals, etc.
3. Upsets. When upset conditions occur, and they do occur in all incinerators
on an infrequent basis, then unburned chemicals will be literally vented out
the exhaust stacks resulting in extremely dangerous air pollution for the
community and downwinders. In the case of nerve gases and other dangerous
military weapons, this may be catastrophic for Arkansas residents. Many
incinerators have "dump stacks" or bypass vents for use specifically during
upset conditions to prevent the incinerator from exploding.
4. Permit conditions for incinerators. These requirements, in my opinion, are
never stringent enough to adequately protect public health and the environment,
and even then, many incinerators fail to comply fully with their weak permit
conditions. And also, state and federal regulatory agencies too often fail to
enforce the laws and weak permit requirements at incinerators due to the huge
capital costs of such facilities.
5. Communities near incinerators. People living near these machines suffer the
worst as well as workers, and this is because state/federal agencies do not
protect residents who are burdened with the toxic fallout from incinerators.
But nerve gas could have incredible downwind impacts beyond anything we know on
conventional units.
Incineration is a failed technology in the US. Standards are too weak. Those
weak standards are not enforced and the community and environment pay the
price. New alternative disposal technologies are becoming available. Stop the
incineration!
NEIL J. CARMAN, PH.D.
Re: Incinerators for combustion
I am a former government air pollution inspector of industrial, municipal and
medical combustor facilities including incineration units in the state of Texas
from 1980-92. As a regional air quality field inspector for the Texas Air
Control Board during more than a decade, I observed numerous operational
problems and deficiencies with incineration equipment, including
State-of-the-Art incinerators that were new designs. Problems occurred during
day and night even at new facilities.
Most of the incinerators in our multi-county regional area experienced
mechanical and operational problems, which were often linked to human error.
The result inevitably was that local citizens complained—even several miles
downwind—and became outraged that they had to suffer ill effects due to the
harmful air pollutants emitted during infrequent incinerator malfunctions and
operational upsets. Another result of the problems was that the Texas Air
Control Board had to spend valuable resources and limited manpower
investigating numerous citizen complaints, documenting incinerator violations,
preparing detailed investigative reports, sending notices of violations, and
finally pursuing enforcement action including legal action through the Texas
Attorney General to attempt to obtain full and continuous compliance.
As a consequence of my governmental experience for more than a decade, I am
quite skeptical of the ability of incinerators to operate in full and
continuous compliance with the most stringent permit requirements. It is
technically remote to achieve even 80% continuous compliance.
My greatest concern is for the public who live downwind—even several miles away
from large incinerators—because they will inevitably suffer over time as I
observed from the fallout of toxic particulate matter, unburned hazardous
chemicals, a rain of acid gases including hydrochloric acid, and dangerous
heavy metals to which human beings and particularly children should not be
unnecessarily exposed.
Incinerators malfunction! I observed this problem in all units I inspected for
12 years. Even new incinerators can have malfunctions and upset events
producing especially high levels of harmful and dangerous air pollution. This
is when dioxin and other exceptionally toxic substances will be created and
emitted in higher than normal rates into the ambient air. But as an
incinerator ages like anything else, malfunctions tend to become part of the
normal routine of daily operation. When an upset occurs in an incinerator, the
unit suffers poor combustion due to sudden temperature drops, excess combustion
air loss, pollution control equipment failures, loss of scrubber/quench spray,
and other serious problems.
The only safe level of incinerator air pollution is zero! Unfortunately, no
incinerator technology in the world can meet a set of zero emissions standards.
Another unfortunate fact is that most incinerators even have difficulty
passing the Trial Burns. Trial Burns may not necessarily be representative of
daily operations, since surrogate simple organic chemicals (rather than more
complex chlorinated hydrocarbons like dioxins, dibenzofurans and PCBs) are used
in the Trial Burns such as carbon tetrachloride to measure the combustion
efficiency of the units for destroying organic compounds. Trial Burns fail to
adequately address the hysteresis effect in which there are delayed releases of
dioxins formed during or after the tests by being emitted after the stack
sampling has officially ended.
What is most unfortunate of all is that virtually all incinerators do not
perform on a normal daily basis nearly as efficiently as during Trial Burns
when operational conditions are idealized as much as possible. Once the Trial
Burn is complete, normal daily operations will tend to become complacent and
sloppy. Without government inspectors on hand on a routine basis, sloppiness
will seriously erode the efficiency of the incineration process by failing to
perform as much preventive maintenance, failing to find problems as promptly,
failing to operate equipment as required, and other problems will creep into
the operations.
All incinerators are ultimately doomed to have failures in all aspects of their
process. My experience revealed that no matter how good the technology, how
well trained the personnel, and how effective the process monitoring systems,
there will be major failures leading to high levels of emissions during major
upset events. Simply stated, the potential is that the community will be
poisoned slowly but surely until the incineration is permanently failed.
Incineration even of garbage is merely trading one set of manageable problems
for another set of more difficult problems. Incineration is not a real
solution. It is simply a shell game of creating more toxic substances for your
citizens to breathe from the garbage. Banning incineration is the most
enlightened approach to incineration. Pollution prevention and recycling go
hand-in-hand to more effectively avoid pollution problems up front, but pushing
waste incineration seriously undermines pollution prevention programs and
recycling efforts.
The future is not waste incineration. Fortunately, the enlightened people of
Ontario perceive that incineration is not in their future in 1992 by banning it
from their communities. Ontario's children are the future. Banning garbage
incineration permanently will help to guarantee that Ontario's children have
the healthy future they deserve.
Sincerely yours,
Neil J. Carman, Ph.D.
Lone Star Chapter of the Sierra Club
P. O. Box 1931
Austin, Texas 78767
Phone: 512-472-1767 Fax 512-477-8526
LIST OF REASONS WHY PCB INCINERATION IS A THREAT TO PUBLIC HEALTH
1. Incinerators do not burn all the waste gases like the PCBs so some of the
PCBs escape unburned into the community air supply and environment. Even
burning under the best conditions, unburned PCBs will be released into the air.
And during many hours of thermal treatment, the incinerator will be subjected
to upsets and malfunctions releasing even more PCBs than during the best burn
performance. This is unacceptable to protect public health.
2. Fugitive PCBs (invisible tiny vapor and liquid leaks) will leak during
transfer of PCB liquids from storage/tankage/trucks into the incinerator. This
is unacceptable.
3. Most incinerators have had major spills of PCBs onto the ground resulting in
more fugitive PCB gases drifting into the community. Human error will always
occur because human beings are not perfect and also because the personnel
operating these incinerators are under daily pressures to increase corporate
profits by burning wastes as fast as possible. Sloppiness is often a problem.
4. Incinerators create new combustion byproducts like dioxins and dibenzofurans
in the cooling stack gases. So incineration is one of the worst technological
approaches to attempt to destroy toxic materials by creating and releasing new
even more deadly chemicals like dioxins.
5. Incinerators are subject to catastrophic accidents and explosions since they
age and undergo wear and tear just like anything else mechanical. They become
even more prove to accidents as they suffer wear and tear.
6. Incinerators will routinely fail to perform at the 99.9999% DRE as required
in US permits issued by EPA for hazardous waste incineration. This level of
destruction is pie in the sky.
7. Incinerators will emit many toxic metals like mercury, lead, arsenic,
cadmium, chromium, and many more if they are in the wastes bring burned.
8. Incinerators always possess bypass or dump stacks where they will briefly
circumvent the entire Air Pollution Control System in order to prevent an
explosion, and this is one of the most outrageous aspects of incinerators that
should never be allowed. Because the air pollution rates will be the highest
during bypass dump stack operations and the community is not warned about these
horrible events.
9. Power failures and lighting strikes in the power grid can cause the
incinerator's electrical controls to trip off line and air pollution controls
to shutdown when they need to be 100% operational, but again the community will
not be warned.
10. The ash from the incinerator will be so toxic that it must be placed into a
hazardous waste landfill creating permanent waste dumps near the community.
11. Burning PCBs means that the incinerator will produce large volumes of
hydrochloric acid (HCl) since most (99%) of the chlorine released from the PCB
molecules will end up as HCl. But HCl may be emitted from the incinerator when
the scrubber system fails to perform as required and HCl is very corrosive to
metallic materials and aggressively attacks human lung tissue.
12. Failure to perform adequate maintanence on the incinerator and keep it in
proper working condition so that malfunctions are minimized.
Sincerely yours,
NEIL J. CARMAN, PH.D.
Points of Agreement from the Technical Workshop
Introduction:
The technical roundtable section of the Toronto meeting focused on determining where the participants had basic consensus in key areas of PCB elimination efforts. Following several presentations on topics related to alternative technologies and PCB elimination, the participants broke into groups based on their particular interest and/or work. Each group discussed and developed a list of core statements describing points of agreement on that issue. Each list of statements was then presented to the plenary to determine which represented the basic consensus of the group on that issue. If any individual could not agree with the statement, it was set aside.
Some of the statements set aside were dropped altogether; others were rewritten over the course of the meeting, presented again, and again, either agreed upon, dropped, or deferred for further work. Most of the deferred statements were carried over into the discussion of obstacles and opportunities which followed the technical workshop, and integrated into the action plan which emerged from that part of the meeting.
I. Community issues
1. Solutions for one community should not be accepted at the cost of injury to the health of another community or the general environment.
2. Communities have the right to define themselves and to self-organize.
3. We encourage communities to consider short and long term impacts on national, regional and global levels.
4. Community and public interest groups have a right to seek information from outside sources and a right to access outside expertise.
5. When in stakeholder processes, then public interest and community stakeholders must insist on equity in power relationships.
6. In relationships between public interest groups and community-based popular organizations, public interest groups should strive to anticipate the consequences of their intervention in the community and should strive to communicate likely implications and expectations.
7. People have a right to have the information they need to make informed decisions about risks.
8. Communities have the right to be informed and the right to refuse prior to any PCB waste coming into their communities.
II. Health Effects
What we know:
1. PCBs can cause cancer and disrupt endocrine systems.
2. PCBs are a neurodevelopmental toxin; a fetus exposedin utero is at higher risk for a variety of developmental effects.
3. PCBs bioaccumulate in food chains. The general public is exposed through diet, including meats, dairy, and fish.
4. For populations located near sources, inhalation and dermal absorption can be a significant route of exposure.
5. PCBs are persistent. They remain in water, soils, sediments and living organisms for long periods of time, increasing the likelihood and duration of human exposure.
6. PCBs persist in human body fat with known and unknown long-term consequences.
7. PCBs travel long distances from their sources and are now distributed throughout the global environment. PCB contamination of human beings and all living creatures is ubiquitous.
8. PCBs have transgenerational effects.
9. We don't know everything about the toxicity of PCBs, but we know enough to act.
10. Some PCB congeners have dioxin-like toxicities.
11. Statement on Breast Feeding:
a. Industrial and agricultural processes involving chlorine are poisoning women's bodies everywhere.
b. The physical, emotional, spiritual and cultural benefits of breast-feeding are incalculable.
c. A fundamental human right is to breast-feed and to be breast-fed.
d. Fetuses, infants and children are more vulnerable to health effects of PCBs.
e. Based on recent studies, prenatal exposure to PCBs appears to be more dangerous than PCB exposure by breast-feeding.
f. A significant amount of a mother's total burden of toxic chemicals, including PCBs, is transferred to the infant in the first six months of breast-feeding.
g. It is an unacceptable irony that women have to face the agony of choosing between the incalculable benefits of breast-feeding and downloading their burden of industrial chemicals into their child. The long-term solution must be the elimination of PCBs, not the end of breast-feeding.
What we need to know:
12. How much PCB exposure may come through non-dietary routes, such as inhalation and dermal absorption.
13. More about the structure-function activity of congeners.
14. What are the synergistic effects of PCBs with other substances and pathogens, nutritional status and health conditions.
15. More about the importance of timing in relation to exposure in the developing fetus.
16. More about PCB volatilization from soil, sediment and water. [This statement was accepted, but only with sense that we don't want to imply there is any doubt about volatilization taking place.]
17. More about patterns of air deposition and global air transport and body burdens worldwide.
18. More about the effects of PCBs in breast milk.
III. Inventorying PCBs
1. Fifteen years-plus after the ban of PCBs, there are still levels of serious concern in human beings and the environment. Therefore we need to conduct assessments of possible sources, contaminated sites and stockpiles.
2. A comprehensive list of all potential and known sources and places of use and of all sources of PCBs that are created and released (and added to products) as a by-product of industrial processes is needed. Disposal sites, sediments and other contaminated sites and information about releases from them will be compiled and distributed. This will include country-specific information on non-traditional uses.
3. Manufacturers of PCBs will be required to publish lists of all sales, all consumers, and information on any releases.
4. Users of PCBs will be required to publish lists of quantities of PCB purchases and information on any releases.
5. Companies and institutions with PCBs still in use or in storage will be required to report comprehensively on equipment still in use or in storage, quantities still in use or in storage, and overall management practices.
6. In all countries existing legislation will be invoked or new legislation will be created to get this information, including human body burden, wildlife, fish, and ecosystem data.
7. In the case of US and other bases overseas and on foreign soil, we will work together to make all responsible governments accountable in providing the above information.
8. All information/data generated will be distributed widely to government, non- governmental, scientific, and citizens' organizations. It should be used for official policy- and priority-setting initiatives globally.
9. It is crucial that we use standard methodology and design for inventory projects.
10. Citizen groups play an instrumental role in locating unknown stockpiles and gathering historical information on PCB use and disposal.
11. Work still needs to be done on quality control of data collection and analysis, and on how to correlate human exposure assessment with environmental data and materials data in overall inventories
12. Each country should have a focal point for collection and analysis of inventory data.
13. There must be publicly available data on all transport/movement of PCB waste.
IV. Regulatory and Community Structures
1. Most current regulatory systems in place are not adequate to deploy alternative (non-incineration) treatment technologies. We need new systems.
2. The current requirements for community participation in siting, oversights, regulation, and permitting of technologies are inadequate.
3. There is an inherent industry and government bias against innovative non- incineration technologies (engineering curricula, regulatory training and research all focus on building better burners and landfills.)
4. In an attempt to solve some of the serious problems in the siting, permitting and oversight of these technologies, and in an attempt to respond to the importance of spiritual and cultural values, there must be the following key elements to a regulatory structure:
a) Pre-notification and pre-hearing of any proposal.
b) Funding for technical assistance to community and public interest participants.
c) NGO and community capacity for effective and genuine oversight must exist in every community prior to siting.
d) Communities must be meaningfully involved from the beginning of the process.
V. Technical Criteria for Treatment Technologies
1. Bases for comparing treatment technologies should include:
i. Destruction efficiency
ii. Residuals collected and analyzed (gaseous, liquid and solid)
iii. Capacity to re-process residuals
iv. Potential for uncontrolled releases
v. Ability to decommission
vi. Track record and reliability down time and maintenance issues
vii. Safety
viii. Scalability
ix. Possibility of vessel containment failure
x. Potential for catastrophic release
xi. Transportation/mobility of the technology
xii. Availability of key resources, including trained personnel, water, electricity
xiii. Environmental efficiency
xiv. Capability for community/external monitoring
xv. Business factors cost, management, insurance, regulation and oversight
xvi. Complete access to information about the technology
xvii. Amount of time until implementation
xviii. Amount of time for project deployment and project completion
xix. Public acceptance
xx. Whether dangerous products were produced
xxi. Community monitoring throughout the life of the project
2. Information on the performance of full-scale conventional and alternative facilities should be collected and widely disseminated.
3. Likely cumulative release to the environment needs to be considered. Site-specific technology evaluation should consider the urgency of need to eliminate PCBs in the environment.
VI. Statement of Developing Countries Group
This statement was prepared by representatives of developing countries at the meeting to highlight general points related to differences in perspective on key issues:
We have many issues and problems in common; for example, our concerns about toxic emissions and the effects on our health and the environment. Global issues such as the POPs issue gives us the opportunity to share our experience and to learn from each other.
But when we approach the solutions to these common problems, we have to recognize that these solutions may differ from country to country, and even from region to region within a country. We have differences of history in our struggles both in the environmental movement and in our political struggles. The two are frequently closely related. We have different traditions of organization and ways of organizing; different ways of conducting meetings, for example. We have different relationships between government, the industry and environmental and community groups. Stakeholder or multi-party groups are very different, and regulatory frameworks are very different, or even nonexistent. Access to technical resources and funding is very different.
Perhaps most important is that the social and environmental priorities and the political setting are different. Finally, there are differences with respect to access to information.
The problem is common, but the solutions may well be quite different. In organizing international dialogues, more consideration should be given to providing opportunities for discussing the specific problems of developing and marginalized countries.
VII. Clarifying Language Circulated After the Meeting
We do not think it is a good idea to put PCBs into landfills or to permanently landfill or permanently cap soils or sediments that are substantially contaminated with PCBs.
We are concerned about growing pressure to incinerate PCBs without serious consideration being given to other options. One option that needs more consideration is the implementation of non-incineration, alternative destruction technologies that better meet the criteria matrix proposed at our meeting. Another option may be implementation of safe and secure, temporary storage to permit more time for implementation of appropriate destruction technologies.
We support the action statement in IPEN's POPs Elimination Platform that most directly addresses PCBs. This statement details the demands IPEN Participating Organizations make on governments to take action with regard to various categories of POPs. It says: ' for obsolete POPs stocks and environmental POPs reservoirs, identify, collect and destroy the POPs by means that do not, themselves, cause hazards, generate POPs or otherwise threaten or injure health and/or the environment.
Main Contacts: Lin Kaatz Chary <[email protected]>, Larry Yates<[email protected]>, and Karen Perry <[email protected]>