TL: A REPORT ON THE HAZARDOUS WASTE INCINERATION CRISIS (GP)

WARNING: Incineration Can Seriously Damage Your Health
SO: Greenpeace International
DT: 1991
Keywords: toxics incineration reports greenpeace human health
risks groups gp /
[part 1 of 8]

for more information contact:

Lisa Finaldi
Greenpeace International
Keizersgracht 176
1016 DW Amsterdam
The Netherlands

Tel: (31 20) 523 6555

June 1991


acknowledgement:

We gratefully acknowledge Pat Costner and Joe Thornton for their
substantial contribution to this report, large parts of which
have been drawn from "Playing With Fire - Incineration of
Hazardous Waste" (Greenpeace USA Toxics Research and Information
Unit, May 1991).

edited by Lisa Lark 
cover layout: Maurice van der Molen 
desktop publishing: Lisa Lark 
printed on chlorine-free paper by: Grafisch Centrum Amsterdam


TABLE OF CONTENTS

1. INTRODUCTION

2. INCINERATION: THE THEORY VS THE PRACTICE

3. INCINERATOR PERFORMANCE

     Trial Burns

          - Combustion Efficiency (CE) 
          - Destruction and Removal Efficiency (DRE)

     Propagation of Error
     Hysteresis Effect
     Monitoring Daily Incinerator Operations

4. INCINERATOR EMISSIONS

     Releases of Unburned Wastes

          - Air Emissions of Unburned Wastes
          - Unburned Wastes in Incinerator Residues
          - Unburned Wastes in Residues From Pollution
          - Control Devices
          - Fugitive Emissions
          - Release During Waste Transport

     Products of Incomplete Combustion (PlCs)

          - PlCs in Air Emissions 
          - PlCs in Ash Residues 
          - PlCs in Wastewater Effluents 
          - Dioxins and Other Organohalogens

     Incineration of Metal-Containing Wastes.

          - Metal Partitioning and the Role of Chlorine 
          - Air Emissions of Metals 
          - Metals in Incinerator Residuals

5. HEALTH AND ENVIRONMENTAL IMPACTS OF HAZARDOUS WASTE         
   INCINERATION

     Toxicity
     Dioxins and Other Organohalogens
     Non-halogenated PlCs
     Heavy Metals
     Routes of Human Exposure to Incinerator Pollutants

          - Exposure Via Fish Consumption 
          - Exposure to Pollutants Via Crops 
          - Exposure Via Milk, Meat and Eggs

     Role of Incinerators in Global Organohalogen
     Contamination

6. CONCLUSION

7. NATIONAL PROFILES

     Introduction
     Australia
     Austria
     Belgium
     Canada
     Denmark
     France
     Germany
     Greece
     Ireland, Republic of
     Italy
     Luxembourg
     Netherlands
     Norway
     Portugal
     Spain
     Sweden
     Switzerland
     United Kingdom

FOOTNOTES

REFERENCES

APPENDIX: Clean Production - Principles and Criteria

ACRONYMS/GLOSSARY


LIST OF TABLES

TABLE 1: Partial Catalogue of Known Errors in DRE Measurement

TABLE 2: Products of Incomplete Combustion from Hazardous Waste 
         Incineration

TABLE 3: Contaminants Identified in Bottom Ash From Hazardous  
         Waste Incinerators

TABLE 4: Pollutants Found in Scrubber Effluents From Hazardous 
         Waste Incinerators

TABLE 5: Metals Detected in Wastefeed or Emissions at Hazardous 
         Waste Incinerators

TABLE 6: Metals Partitioning in a Hazardous Waste Incinerator

TABLE 7: Metals in Hazardous Waste Incinerator Ash

TABLE 8: Metals in Incinerator Scrubber Effluent and Treatment 
         Sludge in Parts Per Billion

TABLE 9: Bioconcentration Factors for Selected Heavy Metals

TABLE 10: Rate of Heavy Metal Uptake Into Crops

TABLE 11: Exposure Routes For Emissions From a Rural Waste     
          Combustion Facility 


1. INTRODUCTION

Waste incineration threatens to become the leading contributor
to the degradation of human and environmental health.
Incineration is proposed, advocated and mandated because it
frees waste generators of their responsibility for the effects
of these wastes. If its proliferation is not immediately
stopped, the dispersal of toxic and persistent poisons will have
a dramatic impact on the global environment and human health.

Yet the European Community is now considering a directive to set
standards for construction and emissions for hazardous waste
incinerators. This directive, while originally put forth as a
temporary measure to bridge the gap between the current waste
crisis and the implementation of a waste avoidance policy,
eliminates all discussion of prevention as an alternative to
disposal by incineration.

In effect, the EC is embracing incineration as a safe, desirable
technology, requiring regulation rather than deterrence. The
passage of this directive will set the stage for an EC-wide
proliferation of incinerators, operated by large waste
management companies, waste-generating industries and
governments.

Within the EC countries, at least 1,755,000 tonnes of toxic
waste were burned in incinerators during 1988. More toxic waste
incinerators are being proposed and sited in rural and urban
areas across the globe. Outside the EC, many countries searching
for solutions to their own toxic waste problems will undoubtedly
look for direction from the EC.

The emergence of incineration as an accepted method of toxic
waste disposal is based not on scientific proof that
incinerators are harmless to public health and the environment,
but on the myth that incineration makes waste disappear. On the
contrary, incinerators create toxic waste and pose significant
threats to public health and the environment:

ù No methods have been developed for continuous identification
of all stack gases. Furthermore, current indicators of
incinerator performance have not been shown to be reliable.

ù Even under the strictest of standards, "state-of-the-art"
incinerators emit chemicals that have escaped combustion as well
as newly-formed "products of incomplete combustion" - thousands
of different chemicals of which only a small fraction have been
identified;

ù Dispersal into the air of the persistent, bioaccumulative
pollutants from incinerator emissions is as ineffective in
protecting public health and the environment as discharging such
substances into water resources;

Continued investment in incineration will inhibit the
exploration and development of products and processes that do
not use toxic chemicals in the first place.

Incineration relies upon the continued generation of waste to
support profitable operations. Pressure to pay back the high
cost of building incinerators has had the effect of encouraging
and perpetuating waste generation.

Governments charged with managing industrial waste stand at a
critical juncture. They can continue to approve and promote
incineration, or they can encourage the development and use of
clean production methods that eliminate toxic processes,
products and waste.


This report details the fallacies of "predicting" and
"monitoring" incinerator performance and demonstrates the
threats posed to surrounding Communities and the greater
environment. Further, Greenpeace advocates an alternative
approach to the incineration crisis: rather than waste
management, waste prevention through clean production.

2. INCINERATION: THE THEORY VS THE PRACTICE

In theory, a properly designed incinerator should convert simple
hydrocarbons into nothing other than carbon dioxide and water.
Practical experience, however, has shown that even the best of
combustion systems cannot take this reaction to completion:

The complete combustion of an hydrocarbons to produce only water
and carbon dioxide is theoretical and could occur one under
ideal conditions ... Real-world combustion systems (e.g.,
incinerators...), however, virtually always produce PICs
[products of incomplete combustion], some of which have been
determined to be highs toxic.1

Incinerated wastes commonly contain complex mixtures of metals,
halogenated chemicals - those containing chlorine, fluorine, and
bromine - that are known to form "undesirable combustion
products", as well as other compounds and elements that are
difficult to burn.2 During incineration and post-combustion
cooling, waste components recombine, forming hundreds, even
thousands, of new substances called products of incomplete
combustion (PICs).3 Metals, of course, are not destroyed. They
are distributed among air emissions, ashes and in the residues
of pollution control devices, along with the PICs and portions
of the wastes that escape burning or capture.

As yet, no methods have been developed to directly monitor of
incinerator performance the extent to which an incinerator
converts hazardous wastes into harmless materials during routine
operations. No methods exist to fully identify and quantify the
unburned wastes and PICs in stack gases either during trial
burns or during routine operation:

[S]ampling and analysis techniques are not available to identify
or quantify many of the potential compounds emitted ... It is at
present impractical to design a monitoring scheme to identify
and quantify the individual toxic compounds in incinerator stack
emissions.4

Due to this lack of direct measurements, the operation and
regulation of hazardous waste incinerators is currently based on
a series of assumptions and subsequent calculations about the
relationship of indirect indicators of incinerator performance.
The validity of these assumptions is questionable at best.

3. INCINERATOR PERFORMANCE

The monitoring and measuring of incinerator performance is
conducted in various ways and on various levels in different
countries.

Actual incinerator performance deviates from trial burn "ideal". Such
deviations are called "combustion upsets". Many factors may
contribute to the occurrence of incinerator upsets,
particularly: equipment failure, human error and rapid changes
in the waste fed to an incinerator. In an analysis of
incinerator upsets the following types of events are listed as
being among "those that can be expected to produce above-normal
releases":

1. Loss of the air pollution control system, loss of combustion
air, loss of fuel, loss of atomization, loss of flame, etc.; 

2. Overfeed conditions; 

3. Fuel explosions from failure to safely shut down incinerator;
and 

4. Fuel leakage failure resulting in an explosion external to
the incinerator combustion chamber.5

Combustion upsets increase the emissions of toxics from
incinerators. Even a small deviation can impair incinerator
efficiency. According to the United States Environmental
Protection Agency (USEPA):

Only a small fraction of the total volume of waste needs to
experience ... less than optimum conditions to result in
significant deviations from the targeted destruction
efficiencies.6

Trial Burns

An initial trial burn is conducted in an attempt to ascertain
the efficiency of a new system before an incinerator becomes
operational. Thereafter, a similar test may be conducted
periodically. During a trial burn, calculations are made in an
effort to determine the efficiency of the incineration process.

There has been considerable debate and criticism about the use
of trial burns and the methodology employed in monitoring them.7
A trial burn records only a single moment in time, and is most
often performed under optimum conditions:

[I]t is reasonable to assume that during the trial burn,
incinerator conditions ... will be optimized, that operator
attention will be at its best, and that waste feed composition
and characterization will be carefully attended to.8

There are two measures of an incinerator's performance:
combustion efficiency (CE) and destruction and removal
efficiency (DRE). It must be emphasised that these formulae are
designed to assess the performance of the system, and not the
contents or toxicity of emissions.

Combustion Efficiency (CE)

CE is the measuring of the carbon monoxide and carbon dioxide
content of the stack gases. Incineration proponents claim that
the presence of readily monitorable carbon monoxide indicates
incomplete combustion and therefore the absence of carbon
monoxide is a good indicator of combustion efficiency. However,
no firm relationship has been demonstrated between carbon
monoxide and emissions of unburned chemicals or chemicals newly
formed during combustion. Consequently, CE has very little
meaning as an evaluator of incinerator performance.

Destruction and Removal Efficiency (DRE) During Trial Burns

The DRE is the most frequently used measurement of an
incinerator's performance during a trial burn, and is achieved
by sampling and analysing a few preselected compounds called
principal organic hazardous constituents (POHCs). An
incinerator's DRE is the ratio of the quantity of a POHC
released into the air after passage through the incinerator and
its pollution control system to the quantity of the POHC
originally fed into the incinerator. If no POHCs are detected in
emission samples after incineration, the combustion is judged to
be efficient.9

This procedure has been extensively criticised by scientists on
all sides of the debate. Destruction of the POHCs does not mean
that all compounds in the feed stock have been destroyed, since
usually DRE is calculated for only a few selected chemical
compounds, despite the presence of hundreds of chemicals often
contained in waste streams.10

Thus, achieving the required DRE of 99.99% means that 0.01% of
the POHC is detected in stack gases after passage through the
incinerator and its pollution control system. It does not mean
that 99.99% of the POHC was actually destroyed:

The above [DRE-based] standards only address the POHC residues
at the stack and fail to address other possible effluents such
as PICs associated with stack gases, and POHC residues, trace
metals, and other chemicals associated with incinerator ash,
spent water, and particulates. Because these effluents may be
equally or more hazardous than POHCs themselves, research is
needed to qualitatively and quantitatively study the
characteristics of an possible effluents and to provide
engineering data for regulatory support.11

The USEPA's Science Advisory Board concluded in its 1985 report
that relying on DRE, even to simply estimate both the quality
and quantity of chemicals emitted from incinerators, is
"scientifically inadequate.12


In summary, there is no sound basis for assuming that the
demonstration of a DRE of 99.99% of one or more POHCs guarantees
that this level of destruction will be regularly achieved with
complex waste mixtures. Further, POHCs presumed to be relatively
easy to destroy may produce PICs which are extremely difficult
to incinerate.13

DRE is the standard by which incinerators are advocated and
regulated. It is, at best, a remote and tenuous indicator of the
releases of the target chemicals that take place during routine
operations. DRE is a weak indicator of releases of other waste
chemicals, and is no indicator at all for products of incomplete
combustion and heavy metals. Thus, the DRE of an incinerator's
trial burn has no relationship to that incinerator's impact on
public health and the environment during on-going, routine
operations.

Furthermore, in the long run, the removal of pollutants from
stack gases by pollution control devices has little impact on
the total pollutant burden to the environment. Such trapped
pollutants are not destroyed but remain in the solid or liquid
residues of the devices. Solid residues - fly ash, bottom ash
and slag - are commonly buried in landfills from which they will
eventually escape and enter ground or surface water.

Propagation of Error

A DRE is calculated via a multi-step process using data gathered
from numerous sources by a variety of techniques. There is
imprecision and inaccuracy inherent in each step of this process
ranging from sampling and analytical procedures to experimental
design and human implementation of that design.

For example, one survey of the sampling trains commonly used to
collect stack gas during trial burns found that the accuracy of
the devices in trapping POHCs for DRE determinations varied by
+ 50% or more.14 In another study, researchers found that:

recovery efficiencies of selected POHCs from the VOST [sampling
train] ranged from ... 37.82% ... for methyl vinyl ketone ... to
118.15% for chloroform. 15

Table 1 lists some of the known errors in DRE measurement. Using
the incineration of chloroform as an example, an examination of
this partial list of relative errors has shown that a nominal
DRE of 99.99% may actually be as low as 79%.16 The analysts who
performed these calculations noted as follows:

The DRE may not be the most appropriate method for
characterizing the proper operation of an incinerator. A
statement relative to the performance of a piece of equipment is
not complete until the uncertainty in the measure of performance
is specified, together with the method used to estimate the
uncertainty. 17


TABLE 1. Partial Catalogue of Known Errors UIDRE Measurement.18

Parameter                                 Percent Error

Volumetric flow of mixture                    5.0%
Concentration of POHC species                 4.5%
Specific gravity of POHC                      0.7%
Density of water                              0.2%

Temperature of stack gas                      3.3%
Pressure of stack gas                         0.3%
Volumetric flow of stack gas                  1.5%
Concentration of POHC in stack gas           20.0%


Hysteresis Effect

Another major flaw in the current method of determining DREs is
the recently discovered "hysteresis effect". This may be defined
as:

retention within the combustion system of POHCs coupled with
their continued appearance in stack gases for prolonged periods
of time after their flow into the combustion system has been
stopped.19

In one of the first reported cases, scientists observed that
"stack concentrations of waste species continued for several
hours after waste firing was curtailed".20

The hysteresis effect was corroborated by a subsequent study.
Two hours after stopping the flow of carbon tetrachloride and
chlorobenzene into a pilot-scale boiler, researchers found these
two POHCs still present in stack gases at concentrations that
were 121% and 388%, respectively, of their concentrations in the
stack gas samples taken while the POHCs were being fed into the
boiler. During 13 runs in which wastes were co-fired with gas
and three with waste co-fired with oil, "around 50% of the
original concentrations measured [were] still being emitted ...
43 hours (after cessation of co-firing)". No consistent trend
was found between hysteresis and furnace temperature, which
ranged from 1,000-1,150øC. 21

The failure to address hysteresis effects may lead to unburned
waste releases which are orders of magnitude larger than those
reported.

Monitoring Daily Incinerator Operations

There are no methods for continuous sampling and complete
analysis of incinerator emissions during either trial burns or
routine operations. For example, there are no methods for fully
identifying and quantifying the unburned wastes and PICs in
stack gases either during trial burns or during routine
operation.


Moreover, there has been very little research carried out
towards such identification and quantification:

PIC emissions are composed of thousands of different compounds,
some of which are in very minute quantities and cannot be
detected and quantified without very elaborate and expensive
sampling and analytical [S&A] techniques. Such elaborate S&A
work is not feasible in 23 trial burns for permitting purposes
and can one be done in research tests. Very few research tests
have been conducted to date to identify and quantify all the
PICs in a typical emissions sample, and whenever done were
unsuccessful because sampling and analysis techniques are not
available to identify or quantify many of the potential
compounds emitted, nor are toxicity data available for all the
compounds.22

From an environmental and public health point of view, the only
meaningful measures are the quantities and identities of the
chemicals released into the environment during the daily
incineration of wastes. However, attempts to monitor routine
operations are based on observations of variations in certain
"surrogate indicators" and operating parameters. Those most
commonly used include: incinerator temperature, carbon monoxide
emissions and total hydrocarbon emissions. There is no agreement
within the scientific community, however, that any of these
measures is a reliable indicator of incinerator performance:

It is not yet possible to specify absolute levels of process
operating parameters that will guarantee in advance that an
incinerator will meet the 99.99% DRE standard for a particular
waste ... [C]ontinuous monitoring for specific absolute levels
of emissions of carbon monoxide, oxygen, and total halogenated
organic carbon cannot guarantee that a 99.99% DRE is being
attained.23

Furthermore, operating parameters usually considered indicative
of good combustion - high temperature and oxygen availability -
have both been associated with increased PIC and POHC emissions
for certain waste chemicals.24

[] TL: A REPORT ON THE HAZARDOUS WASTE INCINERATION CRISIS (GP)
WARNING: Incineration Can Seriously Damage Your Health
SO: Greenpeace International
DT: 1991
Keywords: toxics incineration reports greenpeace human health
risks groups gp /
[part 2 of 8]

4. INCINERATOR EMISSIONS

Proponents of hazardous waste incineration refer to it as a
proven technology. However, existing data demonstrates that
hazardous waste incinerators release three dangerous groups of
emissions to the environment, via air emissions, and solid and
liquid residues:

ù unburned toxic chemicals released to the air and through ash
ù products of incomplete combustion (PICs)
ù metals.

Releases of Unburned Wastes

Unburned wastes are released into the environment as part of the
incineration process. They are also released during routine
storage, handling and transport.

Air Emissions of Unburned Wastes

No incinerator process operates with an efficiency of 100%. In
1990 it was estimated that commercial incinerators in the US
were burning hazardous waste at a rate of 589,000 tonnes per
year.25 Within EC countries in 1988 the figure was 1,755,000
tonnes.26 Even if all these incinerators achieved 99.99% DRE at
all times, their air emissions of unburned hazardous wastes
would total at least 234 tonnes per year. Taking into account
hysteresis effects and propagation of error, this figure can be
expected to be considerably higher. Air emissions of unburned
waste can be expected to increase during combustion upsets.

Unburned Wastes in Incinerator Residues

Incinerators are designed to burn wastes, but they also produce
them in the form of bottom ash, fly ash captured in pollution
control devices, and effluents from wet scrubbers and/or cooling
processes. When liquid hazardous waste is burned, as much as 9%
of the original volume remains as ash; when solid hazardous
wastes are burned, as much as 29% remains as ash. This ash can
be expected to carry many of the same pollutants emitted in
stack gases. Ash is commonly buried in landfills; effluents are
usually treated and then discharged into rivers or lakes.

Studies have identified as many as 43 different semi-volatile
organic chemicals in ashes from incinerators and at least 16
organic chemicals in scrubber water from hazardous waste
incinerators.27

Unburned Wastes in Residues from Pollution Control Devices

Some pollution control systems are estimated to capture more
than 90% of the quantity of pollutants present in stack gases.
The most effective are reported to reduce pollutant emissions by
more than 99%.28 However, even if a pollution control device
(PCD) captures 90% of the unburned wastes in an incinerator's
air emissions, the quantity of unburned wastes in the residue
from the PCD will be nine times greater than the quantity that
escapes into the air. Thus, the PCD's residues would be expected
to contain 0.09% of the wastes fed into an incinerator that is
achieving 99.99% DRE.

For example, at an average sized incinerator burning 32,000
tonnes per year of wastes with a DRE of 99.99% and PCD
efficiency of 90%, the PCD residues can be expected to contain
approximately 30 tonnes per year of unburned wastes. Taking into
account the hysteresis effect and propagation of error, this
quantity may be many times higher.

Fugitive Emissions


Some waste constituents are accidentally released during storage
and handling. On this subject the Science Advisory Board of the
USEPA has advised:

Fugitive emissions and accidental spills may release as much or
more toxic material to the environment than direct emissions
from incomplete waste incineration ... A potential exists for
environmental and human exposures as chemicals are removed from
storage containers at the generator site, moved to
transportation vehicles, shipped to the incinerator, and moved
about within the incineration facility.29

For example, at one large US commercial incinerator burning
pesticide-related wastes, gross fugitive emissions were
estimated at 4.5 tonnes per year. Ninety-three percent of the
chloroform and 62% of the toluene in the air at this incinerator
were identified as fugitive emissions.30

Also to be considered in this context are catastrophic releases
through fires and explosions:

Catastrophic accidents, especially near incineration sites where
large quantities of liquid hazardous wastes are stored and
burned, require the ability to mount rapid emergency responses
... Typically, an emergency plan will need to consider the
probability of chemical spills, fires and explosions, and
atmospheric dispersion and exposures of chemicals, and
incidences of poisonings and injuries. These plans should also
include the development of population evacuation procedures.31

Release During Waste Transport

Hazardous wastes may also be released into the environment
during transport between waste generators or treatment
facilities, and incinerators. An average incinerator burning
32,000 tonnes of waste per year will receive over 1500 tanker-
truck shipments of wastes per year, or more than 28 trucks per
week. According to the USE PA's Science Advisory Board:

The greater the traffic between a source and an incinerator, the
more likely is the incidence of spills ... The likelihood of
exposure ... will be influenced by the total annual amount of
material incinerated in a region and the capacity of the
transport vehicles.32

The US Office of Technology Assessment (USOTA) reported more
than 78,000 incidents involving the release of hazardous
materials during transport in the years 1976-1984.33

Products of Incomplete Combustion (PlCs)

A product of incomplete combustion can be defined as:

any compound which was not identified from the analysis of the
incinerator feed stream but is found in the incinerator off-
gas.34

PICs occur when fragments of partially burned waste chemicals
recombine within incinerator furnaces, smokestacks, and/or
pollution control devices. Hundreds and even thousands of new
chemicals are formed in incinerators, both during upsets and
under normal operating conditions. They are distributed into the
environment among incinerator stack gases, bottom ash, fly ash
and effluents of pollution control devices.

For an average-sized commercial incinerator, total PIC emissions
are estimated to range from 2.65 to 2,230 tonnes per year,
depending on waste contents and operating conditions. Of the
thousands of PICs that may be formed, approximately 100 only
have been fully identified. Among these are the polyhalogenated
dioxins and dibenzofurans, PCBs and hexachlorobenzene, which are
formed during the burning of halogenated wastes.35

PICs can be placed into three categories:

1. Compounds which are produced by combustion of the original
wastes (the largest group);

2. Compounds introduced from sources other than the waste (that
is, in the combustion air or auxiliary fuel); and

3. Compounds present in the wastes but not identified - thought
to be a small percentage of the total PICs observed.36

The first category of PICs has been characterised as containing
species that are "more difficult to destroy and ... more toxic
than the parent compound".37

PlCs in Air Emissions

In laboratory incineration tests based on PICs which were
positively identified, the ratio of (identified) PICs to POHCs
in air emissions was found to vary from 0.5 to 7,38 depending on
oxygen availability. Based on the fact that available emissions
analyses have identified from 1 to 60% of the total mass of PICs
present, the ratio of total PICs to POHCs may range from .83 to
700.

Based on these ratios, if an incinerator were actually able to
achieve 99.99% DRE for all wastes burned at all times, unburned
POHCs emissions would be 0.01%, and identified PIC emissions
could be expected to range from 0.005 to 0.07% of the weight of
wastes burned. For an average-sized incinerator with a capacity
of 32,000 tonnes per year, identified PIC air emissions would be
16 to 23 tonnes per year, with combined air emissions of
identified PICs and unburned POHCs ranging from 4.8 to 25.5
tonnes per year.

An extensive review by the USEPA's Science Advisory Board led to
the following estimation of emissions of PICs and unburned
POHCs:

It is apparent that even with the uncertainties related to
sampling efficiencies and inadequate chemical analyses, as much
as 1 percent of the mass of waste feed could exit an incinerator
as compounds other than CO2 CO, H2O and HCI.39

Based on this estimate, an incinerator of average size can be
expected to emit 320 tonnes per year of total PICs and unburned
POHCs.

While the number of PICs produced and released by hazardous
waste incinerators is estimated to range into the thousands,40
even in laboratory conditions less than 70% of PICs have been
identified. Trial and research-burns have identified only 1 to
60% of the total mass of unburned hydrocarbons, both PICs and
POHCs, present in stack gases from full-scale incinerators.41 A
listing of the chemicals identified in stack gases of hazardous
waste incinerators is presented in Table 2.

TABLE 2. Products of Incomplete Combustion from Hazardous Waste
incineration

Acetone (1,3)
Acetonitrile (5)
Acetophenone (1)
Benzaldehyde (1,4)
Benzene (1,3,4,5)
Benzenedicarboxaldehyde (1)
Benzofuran (4)
Benzoic acid (1)
Bis(2-ethylhexyl)phthalate (1,5)
1-Bromodecane (4)
Bromofluorobenzene (4)
Bromoform (3)
Bromomethane (5)
Butylbenzylpmhalate (1)
Carbon tetrachloride (1,2,3,4,5)
Chlorobenzene (1,3,4)
1-Chlorobutane (4)
Chlorocyclohexanol (1)
1-Chlorodecane (4)
Chlorodibromomethane (3)
2-Chloroethyl vinyl ether (3)
Chloroform (1.23.4.5)
1-Chloromothane (3,5)
1-Chlorononane (4)
1-Chloropentane (4)
Cyclohexane (1)
Cyclohexanol (1)
Cyclohexene (1)
1-Decene (4)
Dibutylphthalate (1)
Dichloroacetylene (2)
Dichlorobromomethane (3)
1,2-Dichlorobenzene (4,5)
1,4-Dichlorobenzene (4,5)
1,1-Dichloroethane (5)
1,2-Dichloroethane (3,4,5)
1,1-Dichloroethylene (3,5)
Dichlorodifluoromethane
Dichloromethane (1,3,4,5)
2,4-Dichlorophenol (5)
Diethylphthalate (1)
Dimethyl ether (3)
3,7-Dimethyloctanol (4)
Dioctyl adipate (1)
Ethenylethylbenzene (1)
Ethylbenzaldehyde (1)
Ethylbenzene (1,3)
Ethylbenzoic acid (1)
Ethylphenol (1)
(Ethylphenyl)ethanone (1)
Ethylnylbenzene (1)
Formaldehyde (5)
Freon 113 (4)
Heptane (4)
Hexachlorobenzene (2,5)
Hoxachlorobutadiene (2)
Hexanal (4)
1-Hexene (4)
Methane (3)
Methyl bromide (3)
Methylcyclohexane (4)
Methyl ethyl ketone (5)
2-Methyl hexane (4)
3-Methyleneheptane (4)
3-Methylhexane (4)
5,7-Methylundecane (4)
Naphthalene (1)
Nonane (4)
Nonanol (4)
4-Octene (4)
Phenol (5)
Polychlorinated biphenyls (PCBs) (2)
Polychlorinatod dibenzo-p-dioxins (PCDDs) (2,5,6)
Polychlorinated dibenzofurans (PCDFs) (4)
Pentanal (4)
Phenol (1,5)
Phenylacetylene (1)
Phenylbutenone (1)
1,1 (1,4 Phonylono) bisothanono (1)
Phenylpropenol (1)
Proponylmethylbenzene (1)
1,1,2,2-Tetrachloroethane
Tetrachloroethylene (1,2,3,4,5)
Tetradecane (4)
Tetramethyloxirane (1)
Toluene (11,3,4,5)
1,2,4-Trichlorobenzene (14,5)
1,1,1-Trichloroethane (1,3,5)
1,1,2-Trichloroethane (5)
Trichloroethylene (1,2,4,5)
Trichlorofluoromethane (3)
2,3,6-Trimethyldecane (4)
Trimethylhexane (1)
2,3,5-Trichlorophenol (5)
Vinyl chloride (3,5)

There is little information at all about PICs emitted during
combustion upsets:

Very few tests have been conducted to identify and quantify PICs
from hazardous waste combustors during non-optimum combustion
conditions ... Most full-scale studies which have monitored for
PICs have looked at PIC generation one under incinerator process
conditions in which good destruction of POHCs occurred. There is
insufficient data to know with certainty whether the types and
concentrations of PICs [under upset conditions] ... are similar
to the types and concentrations of PICs in the existing data
base.42

PICs in Ash Residues

PICs are found in incinerator ash residues.

One study of bottom ash identified 37 PICs, some of which were
chlorinated species. Concentrations ranged from 0.1 to 500 parts
per million (ppm).43

A later study of fly ash from various types of incinerators
identified 43 PICs. Concentrations ranged from less than 10 ppm
to 120 ppm. During an acid/water extraction test designed to
simulate landfill conditions, concentrations of some individual
PICs in ash leachate were greater than 1 ppm.44

A study of bottom ash from a hazardous waste incinerator burning
mixed solvent wastes with a chlorine content of 28% found 25
PICs. Concentrations of individual PICs ranged from 12 to 1,000
parts per billion (ppb). Total quantity of identified PICs in
the ash was greater than 0.23%.45

The generation of ash by hazardous waste incinerators is
reported to range from 9 to 29% of the weight of wastes
burned.46 At such rates, an incinerator of average capacity
(32,000 tonnes per year) can be expected to produce
approximately 2,850 to 9,230 tonnes of ash per year. If PICs are
present in quantities similar to those presented in the studies
above, this ash can be expected to carry from 6.5 to 21 tonnes
of PICs.

Table 3 lists some of the PICs that have been identified in
incinerator bottom ash, and their concentrations:47

TABLE 3. Contaminants identified in Bottom Ash From Hazardous  
          Waste Incinerators

Parameter                        Concentration (ppb)

Acetone                                20,000
Benzene                                    42
2-Butanone                              2,000
Chlorobenzene                              27
Chloroform                                 46
1,2-Dichloropropane                        32
Diethyl phthalate                     120,000
2,4-Dimethylphenol                     23,000
Dimethyl phthalate                     55,000
Ethylbenzene                              380
Methanol                              410,000
Methylene chloride                     38,000
4-methyl-2-pentanone                    2,300
Naphthalene                            24,000
2-Nitroaniline                        180,000
Nitrobenzene                           29,000
Phenol                                 40,000
Styrene                                   320
Tetrachloroethylene                 1,200,000
Toluene                                 2,500
1,1,1-Trichloroethane                      12
Trichloroethylene                         120
Xylenes                                 1,900

TOTAL                               2,308,679


PICs in Wastewater Effluents

At some hazardous waste incinerators, water is used as part of
wet scrubber pollution control devices or, less commonly, to
cool bottom ash. In some cases the used water is treated and
discharged, and in others it is fed back into the incinerator.

Significant concentrations of chemicals and groups of chemicals,
which may include both PICs and POHCs, have been identified in
scrubber effluents, as shown in Table 4.

TABLE 4. Pollutants Found In Scrubber Effluents From Hazardous 
         Waste Incinerators

Pollutant                             Scrubber Wastewater
                                    (micrograms per litre)

Acetone                                   32   (1)
Methylene Chloride                        <5   (1)
Naphthalene                              <20   (1)
Benzoic acid                             260   (2)
Bis (2-ethylhexyl)phthalate               32   (2)
Chloroform                             4,100   (2)
Chloromethane                          2,500   (2)
1,2-Dichloroethane                    32,000   (2)
Diethyl phthalate                         30   (2)
Di-n-butyl phthalate                      22   (2)
Phenol                                   100   (2)
Tetrachloroethane                      5,200   (2)
Toluene                                5,000   (2)
1,1,1-Trichloroethane                  6,800   (2)
Trichloroethene                       14,000   (2)
Total xylenes                          1,200   (2)
Dioxins and furans (total)                43   (3)

(1) Boegel 1987
(2) Van Buren 1987
(3) USEPA 1987b

Dioxins and Other Organohalogens

Organohalogens are chemicals containing at least one carbon atom
bonded to one or more of the halogens (chlorine, fluorine,
bromine or iodine). They include some of the most notorious of
the global pollution sources:

- polychlorinated biphenyls (PCBs)
- chlorofluorocarbons (CFCs)
- DDT
- hexachlorobenzene
- polychlorinated dibenzodioxins (PCDDs)
- polychlorinated dibenzofurans (PCDFs)
- mirex 
- chlordane 
- heptachlor 
- 2,3,7,8 tetrachlorodibenzo-p-dioxin (TCDD).

Many of this group of chemicals are extremely toxic, persistent
and bioaccumulative. For example, both dioxins and furans are
extremely lethal, powerful carcinogens. They resist breakdown in
the environment, accumulate in the fatty tissue of living
organisms and concentrate in increasing levels as they pass
through the food web.48

Since organohalogens can be formed by burning a substance or a
mixture of substances that contains the element carbon and one
or more of the halogens, organohalogens are commonly emitted as
PICs during the incineration of hazardous wastes.

In the US, 46% of the wastes currently burned in incinerators
are halogenated, with an average halogen content of 33.2%.49

In a discussion of incinerators and PCDDs, USEPA researchers
concluded:

the formation of dioxins is generals understood to occur as a
result of burning organic material with chlorine containing
material.50


Of the approximately 100 PICs identified in the literature on
operating hazardous waste incinerators, 46 are organohalogens.
In laboratory tests, more than 100 identified organohalogens
have been detected in emissions during the combustion of
chlorinated wastes.51

In the UK "Comprehensive tests have established that all waste
incinerators, independent of type of incinerator or waste
composition, are likely to produce all of the possible 75 PCDD
and 135 PCDF isomers and congeners as well as about 400 other
organic compounds."52

PCDDs and PCDFs have been detected in the air emissions, ash,
and liquid residues of many hazardous waste incinerators.53

The USEPA's National Dioxin Study listed hazardous waste
incinerators as important sources of PCDDs and PCDFs in the
environment. Total dioxin and fur an emissions were found to
average 80.9 ng/m3 at two rotary kiln hazardous waste
incinerators for which flue gas concentrations were available.54

The same study found one hazardous waste incinerator to be
emitting TCDD-equivalents at the rate of 7.4 ng/m3. Assuming an
average stack gas flow rate of 250 m3/minute,55 and an annual
operating time of 7,000 hours, that incinerator was releasing
TCDD-equivalent dioxins and furans at the rate of 778 million
ng/year. This quantity of TCDD exceeds USE PA's "acceptable"
lifetime dose for approximately 73 million humans.56

In 1983, tests at the Kommunekemi hazardous waste incinerator in
Denmark found total PCDD emissions at the rate of 51.5 ng/m3
from one of the facility's three incinerators. Dioxin emissions
from the entire facility were estimated at 61 grams per year.57

Greenpeace tests of fly ash from the Kommunekemi incinerator
found a total PCDD/PCDF content of 22 ppb.58

Little research has been carried out in quantifying PCDD/PCDF
concentrations in incinerator residues. However, the USEPA
National Dioxin Study mentioned above noted that PCDDs/PCDFs,
including TCDD, were detected in ash from several
incinerators.59

Incineration of Metal-Containing Wastes

Incineration cannot destroy metals - it can only redistribute
them. The same quantity of metals fed into an incinerator will
be released in air emissions, ash, or the effluents of pollution
control devices:

Any metals in the waste feed will be found in the stack
effluent, the captured fly ash, the scrubber water, and the
bottom ash (whichever apply to a given facility). Because many
of the heavy metals, even in trace amounts (for example, lead,
mercury, cadmium, chromium, etc.) are known toxicants, their
exposure to humans and the general environment is a matter of
some concern ... It is abundantly clear that avoiding the metals
input to incinerators is far superior to capture efforts
following.60

The USEPA has calculated that some hazardous waste incinerators
are emitting heavy metals into the air in quantities sufficient
to pose cancer risks as high as 5 per 1,000. These levels exceed
ambient concentrations associated with systemic toxic effects
for "most exposed individuals" living near the facilities.61 The
USEPA further concluded that:

[R]isks from the burning of metal-bearing hazardous wastes in
incinerators can be unacceptable under reasonable worst-case
circumstances ... Clearly, metals can pose significant health
risk.62

In the burning of hazardous wastes, all metals represent a
danger. At least 19 heavy metals have been identified in
emissions from hazardous waste incinerators or in commercial
waste streams intended for incineration in cement kilns. These
metals are listed in Table 5.

In some cases, incinerators will change the physical or chemical
form of metals. For example, elemental forms change to metallic
oxides or organometal complex. They can also change from a solid
physical state to a vaporous or fine-particle form. These
changes may result in increased toxicity. For instance, oxides
of chromium, iron and zinc and certain organometal forms of
mercury, manganese and nickel are more toxic than the elemental
metals.63

[] TL: A REPORT ON THE HAZARDOUS WASTE INCINERATION CRISIS (GP)
WARNING: Incineration Can Seriously Damage Your Health
SO: Greenpeace International
DT: 1991
Keywords: toxics incineration reports greenpeace human health
risks groups gp /
[part 3 of 8]

TABLE 5. Metals Detected in Wastefeed or Emissions at Hazardous 
         Waste Incinerators 64

Antimony
Arsenic
Barium
Beryllium
Bismuth
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Nickel
Mercury
Selenium
Silver
Thallium
Uranium
Zinc


Metal Partitioning and the Role of Chlorine

As noted above, metals from the waste feed will be found in the
incinerator's air emissions, in bottom ash and in residues
collected in pollution control devices. This distribution is
determined by factors such as temperature, chlorine content of
the waste and the efficiency of the pollution control devices.

At the temperatures found within incinerators, some metals such
as lead, mercury cadmium, molybdenum, nickel and zinc vaporise.
These vaporised metals leave the flame zone as gases and
partially condense onto particles as they move up the stack.
These volatile metals are eventually found in emitted and
captured fly ash and in emitted stack gases. Other less volatile
metals concentrate in incinerator bottom ash. These include
aluminium, chromium, copper, magnesium, manganese and
vanadium.65

Metals bound to chlorine tend to be more volatile than elemental
metals or metal oxides. For these metals, higher temperatures
lead to greater volatilisation, which results in higher metals
concentrations in stack gases and particulates.66

One detailed study of a hazardous waste rotary kiln incinerator
found heavy metals distributed in the air emissions and residues
of the incinerator, as shown in Table 6. Chlorine content of the
waste feed was the variable which exhibited the greatest impact
on the distribution of metals. With constant kiln and
afterburner temperatures and chlorine content raised from zero
to 8.3%, the "overall percentage of metals partitioning to the
kiln ash decreased from 81% to 63%." At the same time, air
releases of metals increased seven-fold.67

Moreover, kiln temperatures and chlorine content had negative
effects on the efficiency of pollution control devices. As
temperature and chlorine content increased, the fraction of
metals entering the scrubber which were captured by the device
decreased from a maximum of 56% to a minimum of 33%.68

TABLE 6. Metals Partitioning in a Hazardous Waste Incinerator 69

Percent of Total Metal Measured

Pollutant        Stack Gas     Ash    Scrubber Water

Arsenic           3.8-5.8      86.1     8.2
Barium              2.2        79.6    18.2
Bismuth            41.1        22.2    36.67
Cadmium           56-61       <10.7    27-31
Chromium            2.0        94.1     3.9
Copper             15.1        75.8     9.1
Lead               48.9        15.0    36.1
Magnesium           0.1        99.3     0.6
Strontium           1.7        93.0     5.3


MEAN               19.4        64.0    16.3

NOTE: Chlorine content 3.8%; Furnace exit temperature 877øC;
Afterburner exit temperature 1087øC.

Air Emissions of Metals

The quantities of heavy metals released from hazardous waste
incinerators vary directly with the quantity of metals fed into
it. There is, however, only limited information available to
quantify total releases. In a review of available literature,
the USEPA noted that:

insufficient testing for metals levels in incinerator emissions
has been conducted to determine the average, or reasonable
worst-case levels of metal emissions to be expected from
hazardous waste incinerators.70

In one study of eight incinerators, emissions of airborne lead
were as high as 10.5 kg per day at one incinerator - almost
2,700 kg per year at average operating rates. Cadmium emissions
were 30.5 kg per year, and the rate for nickel was as high as
205.5 kg per year at average operating rates. The authors noted
that:

All of these metals are known to be detrimental to human health
at extremes low concentrations.71

An average commercial hazardous waste incinerator (32,000 tonnes
per year), burning waste containing an average metal content of
1.50%,72 would release approximately 93 tonnes of heavy metals
in its stack gases annually. Such an incinerator would also
release 305.5 tonnes per year of metals in its ash residue and
78 tonnes of metals in its scrubber water.

While some metals will be released in the vapour phase, greater
amounts attach themselves to the surface of extremely fine
particles.73 A portion of these "enriched" particles are
released in air emissions and, due to their small size, are
easily inhaled by humans.74

Metals in Incinerator Residuals

One study of incinerator residuals has found average quantities
of metals in incinerator ash at 10,000 ppm, or a total of
approximately 1% of the total ash.75 Another study found an even
higher quantity of total metals, as shown in Table 7.

TABLE 7. Metals in Hazardous Waste Incinerator Ash 76

Metal                       Concentration (ppm)

Antimony                            8.0
Arsenic                            42.0
Barium                            150.0
Beryllium                          <0.2
Cadmium                             2.0
Chromium (hexavalent)               0.083
Chromium (total)                   71.0
Copper                         13,800.0
Lead                               30.0
Mercury                             0.2
Nickel                            190.0
Selenium                           <1.0
Silver                              0.4
Thallium                            2.0
Zinc                              280.0

TOTAL                          14,576.9

Effluents of pollution control devices are normally treated and
then discharged to surface waters. A large portion of effluent-
carried metals will be concentrated in the sludge produced at
the treatment facility; the rest will be released to surface
waters.77 Treatment sludges are commonly buried in landfills,
where they may leach into ground water. Table 8 shows results of
one study of metal concentrations in PCD effluents and effluent
treatment sludge from a hazardous waste incinerator.

TABLE 8. Metals in Incinerator Scrubber Effluent and Treatment 
         Sludge in Parts Per Billion 78

                             Scrubber     Effluent
                             Effluent     Treatment
                             (ppb)        Sludge (ppb)
Metal

Antimony                       4,000        313,000
Arsenic                          600        140,000
Barium                        <1,000        183,000
Cadmium                          700        400,000
Hexavalent Chromium              526            <10
Total Chromium                 1,400         55,000
Copper                        11,000      8,300,000
Lead                           2,000      1,600,000
Mercury                         <100         60,000
Nickel                         4,000      2,200,000
Silver                          <200            600
Thallium                      <1,000          3,000
Zinc                           8,000      3,100,000


5. HEALTH AND ENVIRONMENTAL IMPACTS OF HAZARDOUS WASTE         
   INCINERATION

Incinerators are sources of many toxic, persistent and
bioaccumulative pollutants, including the dioxins, furans, PCBs
and other less well-known organohalogens. These chemicals, which
are remarkably resistant to natural breakdown processes, are now
worldwide pollutants in the air, water, soil, food web, and
human population. These complex organohalogens are
extraordinarily toxic, causing cancer, birth defects,
neurological damage, immune suppression, and reproductive and
developmental impairment at extremely low doses. Primary routes
of human exposure to these chemicals include inhalation and
ingestion via contaminated fish, dairy products, meat, eggs, and
crops exposed to incinerator emissions.

Even a relatively small amount of toxic emission from
incinerator stacks can, over months and years, reach
concentrations in local ecosystems that are acutely and/or
chronically harmful to humans as well as many other species. If
1,000 tonnes of toxic and persistent organohalogen waste were
burned at a 99.9% efficiency, 1,000 kg of persistent, toxic
substances would be released into the environment - not
including new PICs, compounds formed in the incinerator. No
place is safe from such environmental contamination:
polychlorinated biphenyls (PCBs) and other organohalogens have
been found not only in industrialised areas such as the Great
Lakes of North America, but also in remote areas such as the
Pacific atolls and Antarctica.79

There has been little effort by regulatory agencies to assess
the actual public health and environmental impacts of the
routine operation of hazardous waste incinerators. The
following, however, are among those few cases where formal or
informal public health surveys have been conducted:

One recently reported British epidemiological study documented
a "marked concentration" of larynx cancer cases among adults in
a community within two kilometres of a commercial waste
incinerator.80 A study of the industrial waste incinerator at
Coppull, Lancaster, showed a correlation between proximity to
the incinerator and the incidence of cancer of the larynx. The
incinerator burned liquid wastes, solvents and oils and operated
from 1972 to 1980. There were frequent public protests about
irritant gases which were emitted from the plant.81

In 1985 the operators of an incinerator run by ReChem
International at Bonnybridge, Scotland, closed the plant for
economic reasons. Since then, a farmer near the incinerator sued
ReChem for loss of a large number of cattle. TCDD was detected
in the milk from the farm. The case has yet to be heard in
court. ReChem points to a small municipal incinerator next to
their plant as the source of dioxins.82

At the same incinerator in Scotland, a study found an increase
in the frequency of human baby twinning in the areas most at
risk from air pollution from chemical waste incineration at the
ReChem plant. For the same time and locations, a "dramatic
increase" in twinning among dairy cattle was documented.
Scientists conducting the study suggested that this effect was
linked with incinerator air emissions of "polychlorinated
hydrocarbons, some of which have oestrogenic properties".83


Newspapers have reported controversy over observed cases of eye
defects in children and calves born in the locality of the
ReChem Bonnybridge plant. In 1984 three babies were born with
defective or missing eyes, and twelve calves were born blind.84
TCDD, detected in farm milk near the plant, is suspected of
attacking the optic nerve.

In a legal decision in Ireland, damage has been attributed to an
industrial operation including an incineration plant, in the
Hanrahan case of contaminated cattle.85 In 1978 farmer Hanrahan
noticed health defects in his dairy herd. In 1976, about a mile
from his farm in Clonmel, County Tipperary, an incinerator had
started burning the waste generated by the factory, a US multi-
national pharmaceutical company Merck, Sharpe and Dohme. The
company and local and national authorities refused to accept
Hanrahan's claim that the plant was causing the problem. By
1985, when Hanrahan took Merck, Sharpe and Dohme to the High
Court in Ireland, over 220 of his once prized dairy herd had
died. He pointed to the incinerator as the most damaging source
of the problem. A Canadian pathologist testified on Hanrahan's
behalf that dioxins and PCBs had been found in soil and foliage
samples taken on the farm. Hanrahan lost in the High Court but
in 1988 the Supreme Court overturned the ruling, blaming
emissions from the factory, notably the incinerator, as the
cause of the pollution that destroyed his dairy herd.

After an investigation into ReChem hazardous waste incineration
at Pontypool in the UK, Welsh Affairs Select Committee of MPs
said that no more incinerators should be built in residential
areas. The committee recommended a monitoring program me and
said a public inquiry should be held if a serious health or
environmental risk is shown.86

A health survey in Alsen, Louisiana, USA, site of a hazardous
waste incinerator operated by Rollins, Inc., found three cancer
deaths in one block of nine houses, with two children in one
family suffering from cancer. A 1980 health survey found 80% of
the population suffering from headaches, respiratory ailments
and sinus problems. A more recent Burley found asthma in 20% of
the community as opposed to 7% in a control group.87

In Amelia, Louisiana, USA, where an aggregate kiln owned by
Marine Shale Processors burns commercial hazardous waste, five
cases of childhood neuroblastoma, a rare cancer of the neural
tissue, have been diagnosed in a small community in which near-
zero incidence would be expected. These cases have not been
definitively linked to the operation of the incinerator.88

A physician's survey in El Dorado, Arkansas, USA, site of
ENSCO's hazardous waste incinerator, found "a high rate of
cancer in the community". For example, the overall cancer rate
was 2.7 times higher than the normal rate for communities of
similar size. Further, there are six cases of Guillian-Barre
syndrome, a rare disease with a near-zero incidence expected in
a community of this size.89

It seems apparent that further public health and environmental
impacts from the incineration of hazardous waste would be
demonstrated if resources were devoted to such efforts. In the
absence of epidemiological studies of exposed populations,
however, toxicological data for the individual chemicals
identified in incinerator releases offer insight into the
impacts that can be expected from exposure to incinerator
pollutants. Many of the compounds released from incinerators are
extremely toxic; many of these compounds persist in the
environment for long periods and migrate through the food web.

Toxicity

At high or low doses, the chemicals found in incinerator
releases damage both public health and the environment. Certain
incinerator pollutants, such as the PCDDs and PCDFs, exert
multi-generational effects on multiple organ systems in multiple
species at extraordinarily low doses. For example, an exposure
level below which no effects occur - a so-called safe threshold
- has never been conclusively demonstrated for the
reproductive/developmental 90 and immunological 91 effects of
TCDD and for the neurotoxic and developmental effects of lead.92

Carcinogenic and mutagenic effects for any chemical are thought
to follow a no-threshold model by which even one molecule of a
carcinogen or mutagen can initiate mutations and replications
leading to disease.93 Some scientists have suggested a threshold
model for chemicals that are cancer promoters rather than direct
carcinogens.94 Others have suggested no-threshold models for
specific neurotoxic,95 developmental,96 and reproductive 97
effects associated with exposure to any synthetic chemical.

Responding to concerns about such low-dose effects, USEPA's
Science Advisory Board issued the following warning about the
potential impacts of incinerator air emissions on humans and
other species:

Detection of subtle effects can have significant consequences to
individuals and populations. Effects on behaviour and on
physiological functions often occur at exposures that are
significantly lower than those producing acute observable
effects.98

Regarding PICs, even for those which have been identified,
toxicological data are incomplete. According to the USOTA:

the human health risks associated with exposures to the vast
majority - 90 percent or more - of all chemicals found in
different wastes are unknown.99

Addressing the broader implications of hazardous waste
incineration and this lack of data, the USEPA Science Advisory
Board concluded as follows:


[T]he toxicities of emissions and effluents from land based and
ocean based incinerators are largely unknown.... [T]here exist
no relatively complete or reliable analyses of mass emissions
from either land or sea based incinerators on which to base
subsequent estimates of the potential for environmental
exposures.... Evaluations of potential effects on wildlife,
plants, and terrestrial ecosystems appear to be lacking. Data on
the toxicities of selected emitted mixtures likewise do not
exist.100

Even less is known of the impacts of chemical mixtures, which
may result in additive, synergistic, or inhibitory toxic
effects. Scientists at the US National Toxicology Program have
calculated that in order to study the effects of exposure to a
mixture of 25 common toxic chemicals, it would require
33,554,432 experiments at a cost of more than US $3 trillion,
using a "very conservative estimate.'101

With approximately 60,000 chemicals in circulation,102 and
"thousands" of PICs presumed present in incinerator
emissions,103 it is unlikely that the information necessary for
estimating the effects of exposure to incinerator emissions will
ever be gathered. Given these circumstances, governments must
adopt a precautionary approach, rather than wait for unequivocal
evidence that incineration is causing serious health and
environmental damage.

Dioxins and Other Organohalogens

Polychlorinated dioxins and furans are only one group among the
many complex halogenated PICs emitted by hazardous waste
incinerators that burn wastes containing chlorine, bromine,
fluorine, or iodine. However, this group of chemicals -
particularly TCDD - has been the subject of more scientific,
regulatory and public attention than any of the chemicals known
to occur as incinerator PICs. This focus is due, in part, to
widespread recognition that these extraordinarily toxic,
persistent, and bioaccumulative contaminants are now ubiquitous
in the environment and the human population.

At the lowest doses tested - in the low parts per trillion and
even quadrillion range - TCDD has caused cancer,104 birth
defects and reduced fertility,105 immune suppression,
and neurological/developmental/behavioral impairment 107 in
laboratory animals. One USEPA dioxin scientist has described
TCDD's biological interactions as being like those of hormones,
which can initiate a chain reaction within a cell when only one
molecule is present.108

A comprehensive USEPA review of dioxins 109 has stated that:

In terms of low dose potency, 2,3, 7,8-TCDD and the
hexachlorodibenzo-p-dioxin mixture are the two most potent
carcinogens evaluated by the USEPA's Carcinogen Assessment
Group.

In addition to its direct ability to cause cancer, TCDD also
enhances the carcinogenicity of other chemicals. According to
the former head of USEPA's Carcinogen Assessment Group:

There is no theoretical basis for making even ballpark estimates
of the risk posed by promoters and cocarcinogens to exposed
persons because the mechanism for promotion is not well
understood and the degree of total exposure of the human
population to the numerous carcinogens in the environment cannot
be well quantified. However, it is possible that TCDD could
significantly increase human cancer as a promoter or
cocarcinogen at exceedingly low levels of TCDD exposure.110

TCDD and similar halogenated PICs may have profound long-term
effects on behaviour and intellect. For example, when female
rhesus monkeys were fed TCDD at doses of 5 to 25 parts per
trillion (ppt), their infants exhibited neurological and
behavioral effects, including impaired response to visual
stimuli, impaired performance in learning tasks, increased
aggression in peer groups, and altered relationships with their
mothers.111

Structurally similar to the chlorinated dioxins and furans, PCBs
are also similar, though less potent, in their biological
effects. One study found statistically significant impairment of
cognitive functioning among human infants born to mothers
consuming Great Lakes fish contaminated with PCBs at levels
ubiquitous in that ecosystem. Effects included sluggish
emotional responses, impaired visual, verbal, and quantitative
memory function, and reduced birth weights and skull sizes.112
The degree of impairment increased with greater doses and was
primarily caused by cross-placental transfer of PCBs from the
mother to the child.113

A scientific task force reviewing the literature to date on
humans exposed to TCDD in Agent Orange has found conclusive
statistical associations between exposure to that herbicide and
its contaminants and elevated rates of non-Hodgkins lymphoma and
soft tissue sarcoma (forms of cancer), skin disorders, sub-
clinical toxicity to the liver, and porphyria cutanea tardia (a
metabolic disorder). The authors also found that a weight-of-
evidence evaluation favoured statistically significant
associations between exposure and Hodgkins' disease,
neurological effects and reproductive/developmental effects.
Finally, the authors found suggestive evidence which lacked
statistical significance that the exposed group exhibited
elevated rates of leukemia, cancer of seven different sites,
psychosocial effects, immunological abnormalities, and other
effects.114

The link between TCDD and cancer in humans has been further
corroborated by a study of 5,172 male chemical workers at twelve
facilities that manufactured TCDD-contaminated chemicals. In the
most-exposed subgroup of these workers, scientists from the US
National Institute of Safety and Health found a 1.5-fold
increase in all cancers, with a nine-fold increase in soft
tissue sarcoma and a 1.5-fold increase in respiratory cancer.115

Other halogenated aromatic compounds such as the other PCDDs,
PCDFs, chlorophenols, chlorobenzenes, polychlorinated biphenyls
(PCBs), polybrominated biphenyls (PBBs), and chloronaphthalenes,
appear to exert effects similar to those of TCDD, possibly by a
similar mechanism. However, these effects are generally
manifested at greater doses than those required for TCDD to
produce the same effects.116

Many halogenated PICs - ranging from carbon tetrachloride to the
PCDFs - are also known or suspected carcinogens.117 In few
cases, if any, has the ability of these compounds to act as
cancer promoters been investigated.

PCBs, chlorophenols, vinyl chloride, and trichloroethylene - all
identified as PICs in air emissions from hazardous waste
incinerators and other combustion systems - have all been
associated with adverse reproductive effects in humans.118 As
noted above, PCBs have been associated with birth defects and
impaired neurological development in humans.119

Non-halogenated PlCs

Non-halogenated PICs include hundreds of compounds of varying
toxicity. The simple chain hydrocarbons (ethane, methane,
propane, and acetylene) are of relatively low toxicity. The
simple aromatic hydrocarbons (benzene, toluene, and xylene) may
cause leukemia, birth defects, nervous system effects, and blood
disease.120 Of the polycyclic aromatic hydrocarbons (that is,
benzo-a-pyrene), many are carcinogens, and some are
teratogens.121 Exposure to phthalate esters may cause metabolic
disturbances, enlarged liver and kidneys, and cancer;122 other
reviewers have noted decreased sperm densities in male humans
exposed to phthalate esters.123

Many simple and complex hydrocarbons have been linked to
numerous short-term effects, including neurological, pulmonary,
and metabolic effects.

[] TL: A REPORT ON THE HAZARDOUS WASTE INCINERATION CRISIS (GP)
WARNING: Incineration Can Seriously Damage Your Health
SO: Greenpeace International
DT: 1991
Keywords: toxics incineration reports greenpeace human health
risks groups gp /
[part 4 of 8]

Heavy Metals

When metal compounds are contained in the waste stream, they are
not destroyed by the incineration process, but instead either
emitted in stack gases or remain in the ash or waste water.
Since ash and stack gas scrubber water remain as by-products of
incineration when they contain metals they are in need of
further handling. For example:

A 1990 Greenpeace investigation of the Danish national toxic
waste incinerator "Kommunekemi' often described as "one of the
world's best" - shows that toxic heavy metals are leaking from
the landfill area used by "Kommunekemi" to dump its ash. In the
adjacent Kattegat Sea, researchers found a 300% increase of
metals in mussels, since government tests were conducted in
1984.124

According to the USOTA:

Toxic metals are capable of inducing a variety of human health
effects - lethal and sublethal, acute and chronic.125

Even the most familiar of metals may have serious health and
environmental impacts: iron oxide fumes, for example, are
suspected carcinogens.126 The metals commonly regarded as most
problematic in waste incineration, however, are the known or
suspected carcinogens cadmium, chromium, arsenic, and
beryllium.127

These metals, along with lead, mercury and zinc, which are also
frequently found in incinerated wastes, are known to cause
neurological and pulmonary damage in humans.128 Others cause
damage to liver, kidneys, and pancreas.129 Many of these metals
are also reproductive toxicants, affecting human fertility,
genetic tissue, and the development of embryos.130

Developing infants and children are especially vulnerable to
neurological damage from these metals.131 Exposure to lead is
thought to have caused widespread subtle deficits in
intellectual functioning among the majority of American
children. Increased doses are presumed to lead to increased
impairment.132

Routes of Human Exposure to Incinerator Pollutants

Human exposure to incinerator pollutants may occur through
inhalation or ingestion of contaminated food products and
drinking water. Many incinerator pollutants are known to be
taken up by or deposited on food crops, and to accumulate in
fish and animal tissues, including meat, milk, and eggs. Local
exposures for each pollutant will vary with the persistence of
each chemical and meteorological conditions.

Pollutants may be dispersed over long distances, leading to
exposures far beyond local areas. PICs and metals emitted from
incinerators are known "to be dispersed across the
hemisphere".133 Once dispersed in air, water, and soils, many of
these substances bioaccumulate: that is, they are selectively
filtered from the ambient environment by the tissues of living
organisms. Further, they may also biomagnify, building to higher
and higher concentrations at successive trophic levels of the
food web.

Organisms at the highest trophic levels, such as humans and
other predatory species, serve as the ultimate living reservoirs
for these persistent, bioaccumulative pollutants. Even though
ambient concentrations of such substances in air, water or soil
may be low, bioaccumulation and biomagnification can result in
significant doses for humans and other organisms.

Exposure Via Fish Consumption

Bioaccumulation in aquatic ecosystems has been demonstrated for
many of the chemicals and metals found in incinerator emissions
and residues. For example, one species of fish has been shown to
accumulate TCDD at concentrations as much as 159,000 times
greater than concentrations in ambient water.134 A human who
eats about 225 grams of such a fish will receive a TCDD dose
equal to drinking almost 48,000 litres of the water in which the
fish swam. Other halogenated PICs also exhibit significant
biomagnification, including PCBs, hexachlorobenzene, and
polychlorinated phenols.135

Extensive organohalogen accumulation has been well documented in
aquatic ecosystems including the Great Lakes and the St Lawrence
River,136 the Mississippi River,137 and the Baltic Sea.138 In
some cases, it is obvious that the levels of such pollutants are
already severe enough to threaten species at upper levels of the
food web.

Marine organisms have shown a tendency - though with lesser
biomagnification factors - to accumulate non-halogenated
hydrocarbons, including PAHs and phthalates, which are found in
incinerator emissions.139

Some metals emitted by incinerators may also accumulate in fish
and other aquatic organisms. Bioconcentration factors for
selected heavy metals are summarised in Table 9. In addition to
the metals listed, selenium has shown a tendency to biomagnify
in aquatic food webs.140

Furthermore, "waste incineration is becoming one of the major
sources of mercury releases to the atmosphere in many
industrialized countries."141 Mercury contamination of aquatic
ecosystems is a problem throughout "the industrialized countries
in the northern hemisphere[;]... certain fresh water fish
accumulated mercury to such amounts that it cannot be used
unrestrictedly as food.... Anthropogenic mercury emissions have
caused severe environmental effects in large areas of the
Northern Hemisphere. The problems are of long-term
character."142

TABLE 9. Bioconcentration Factors for Selected Heavy Metals

Metal                 Bioconcentration Factor

Arsenic                         44
Beryllium                       19
Cadmium                         81
Chromium                        16
Lead                            49
Mercury                     63,000 (1)
Zinc                   85 - 16,700 (2)

Sources: Bioconcentration factors (BCF) for freshwater fish,
adapted from USEPA 1979 as quoted in Stein 1990, except the
following: (1) BCF for freshwater fish as given in Hazardous
Substances Databank, Medlars on-line Database, National Library
of Medicine, Bethesda, MD, 1990. (2) Range of BCFs for
freshwater shellfish as given in Hazardous Substances Databank,
op cit.

Exposure to Pollutants Via Crops

Many pollutants released in incinerator air emissions have been
shown to accumulate in and on food crops. For airborne
pollutants the greatest exposures occur with those crops where
the edible portion is exposed (for example, spinach as opposed
to avocados).143 While thorough washing of produce may remove a
portion of those pollutants deposited on crop surfaces, a
significant amount (typically from 15% to 50%) will remain.144
Deposition can also be expected to occur for PICs, including
organohalogens.

Metals can also be transported from contaminated soils into
plant tissues themselves. Rates of uptake vary significantly for
different metals and different crop types. Average rates of
uptake have been summarised and are presented in Table 10.

Only very limited information is available to assess the uptake
of PICs into crops. As with metals, both deposition of PICs onto
the surfaces of edible vegetation and their uptake from soil and
water play significant roles in human exposure.

Dioxins have shown some limited tendency to enter crops from
soils. One review of available literature offered the following
assessment:

There is evidence that 2,3,7,8-TCDD is taken up by plants
growing in contaminated soils, but the amount taken up, or
subsequent transport within the plant itself (say to edible
portions) is very uncertain. The worst-case calculations (using
the highest plant-to-soil ratio from the literature) result in
very high exposures, at least as high as all other pathways.145

TABLE 10. Rate of Heavy Metal Uptake Into Crops

Metal               Percent uptake           Percent uptake 
                  vegetative portion      reproductive portion

Arsenic                   4                       0.6
Cadmium                  55                      15
Chromium                  0.75                    0.45
Mercury                  90                      20
Lead                      4.5                     0.9
Nickel                    6                       6
Beryllium                 1                       0.15


Source: Baes 1984 as presented in Stein 1990. 
Percent uptake = 
concentration in crop/concentration in soil x 100.

An exposure assessment for a cement kiln burning hazardous waste
reviewed available evidence on dioxin uptake into crops and
concluded that crops could be conservatively estimated to
contain dioxins and furans at concentrations approximately 10%
of the levels present in the soil.146

Uptake into plants appears to occur for other PICs as well. The
waste-burning kiln assessment argued that "there may be active
mechanisms for transport within plants" of polynuclear aromatic
hydrocarbons (PAHs). That assessment noted that "one study
reported the uptake of 17 PAH species in onions, beets and
tomatoes", and that another "found consistently higher levels of
PAHs in crops grown in compost or sewage sludge amended soil",
although the accumulation in crops in that study may have been
associated with atmospheric deposition rather than uptake. The
authors concluded that a conservative estimate of PAH
accumulation in crops at 10% of the levels present in soil was
appropriate. That study found that pollutant ingestion via crops
contaminated by uptake or surface deposition accounted for 46%
of total exposure to incinerator-related PAHs.147

Exposure Via Milk, Meat and Eggs

In Europe and the US, ingestion of dairy products is considered
a primary route of human exposure to PCDDs/PCDFs, with daily
doses approximately 12 times higher than those associated with
inhalation.148

According to a review of available literature on dioxin
exposure:

Beef and dairy cattle have been shown to accumulate significant
levels of 2,3,7,8-TCDD and compounds with generally related
structures such as PCBs, DDT, and PBBs, following administration
in the diet or ingestion of contaminated soils.149

Because dioxins and furans concentrate in fatty tissues,
detectable quantities of these pollutants can be expected in
both milk and meat from cows grazing in contaminated areas.150

According to a Canadian study, 93.1% of dioxin intake among
Canadians is via food ingestion. In the accompanying market
basket study, animal products were found to contribute more than
98% of dietary intake of dioxin, with specific contributions as
follows: milk products, 53.3%; eggs, 18.4%; beef, 17.8%; and
poultry, 8.6%. This same report identified air inhalation as the
second most important pathway of dioxin exposure, contributing
4.3% of total exposure.151

Metals, too, may enter dairy products, but usually in lower
ratios than those associated with complex organohalogens. The
exposure assessment for a waste-burning cement kiln in a rural
area found that milk and meat ingestion would account for
approximately 14% of total exposure for mercury and thallium,
and 121% of total exposure for selenium and iron.152

Table 11 summarises estimated routes of exposure for the area
surrounding that facility. It should be noted that this exposure
assessment was in an area with few freshwater ecosystems,
resulting in very low estimates for intake via fish consumption.

TABLE 11. Exposure Routes For Emissions From a Rural Waste     
          Combustion Facility

                        Percent of Total Exposure

Pollutant         Soil                                 Meat/
              Inhalation   Ingestion   Crops   Fish    Dairy 

Arsenic           71           4         20      4       2
Barium            17           7         73      4       1
Beryllium         53          25         19      1      <1
Cadmium           44          <1         55     <1      <1
Chromium          85           2         11      1      <1
Iron              47          18         12     11      12
Mercury            4          <1         55     26      14
Nickel            38           2         59     <1      <1
Lead              51          22         25      3      <1
Selenium          62           3         23     <1      12
Thallium          38          19         20      9      14
Zinc               2          <1         94     <1       3
MEAN              43           9         39      5       5

PCDDs/PCDFs      140                      4     49      34
PCBs               0           0          0     97       1
PAHs              36          10         46      1       4

Source: Stein 1990, exposure assessment for plausible-case
scenario at 16% waste-fuel use.


Role of Incinerators in Global Organohalogen Contamination

[C]ombustion is the one source of sufficient size and ubiquity
to account for the PCDD and PCDF in human adipose tissue.153

Because of their persistence, PCDDs/PCDFs are now ubiquitous in
the world's air, water and soil, even in areas remote from
potential sources of these pollutants. Once dispersed into the
environment, these and other persistent pollutants may remain
intact and fully toxic for years. For example, one study has
estimated the half-life of TCDD in soil to be about 29 years.154
Further, PCDDs/PCDFs are also ubiquitous in the food web and in
many species, including humans, around the entire planet.155

PCDDs, PCDFs, PCBs, chlorobenzenes, chlorophenols, and a range
of chlorinated methanes, ethanes, and ethylenes found in
incinerator emissions have been identified as ubiquitous
contaminants in the tissues of the US population.156 Samples of
human adipose tissue in Sweden 157 and Southern Vietnam 158 have
also been found to carry a full spectrum of PCDDs and PCDFs. The
average US citizen now carries 1,178 ppt of dioxins and furans
in his or her fatty tissues,159 including at least 6 ppt of
TCDD.160

Calculated average exposures suggest that humans in
industrialized nations are ingesting PCDDs and PCDFs in
quantities that are the toxic equivalent of 98 picograms per day
of TCDD.161 This quantify of TCDD, other PCDDs and PCDFs poses
calculated cancer risks of one per 10,000 - that is, 100 times
the de minimis regulatory standard in the United States.162
Further, it raises the possibility of subtle but widespread
occurrence of birth defects, immune suppression and
developmental impairment.

Nursing infants who ingest PCDDs/PCDFs and other complex
organohalogens with their mothers' milk suffer perhaps the
highest levels of exposure to these substances. It has been
estimated that in just one year of breast feeding, an average
infant in the US will accumulate 189 times the lifetime
PCDD/PCDF dose associated with a one per million cancer risk.163
Mother's milk samples from the general population have shown
significant levels of other organohalogens emitted from
incinerators, including PCBs and hexachlorobenzene.164

Hazardous waste incinerators are important sources of complex
organohalogens to the environment. Combustion of organohalogens
and/or carbon-based substances with halogen sources - in garbage
and hazardous incinerators, industrial furnaces and metal
smelters burning chlorinated compounds, and automobiles burning
fuels with chlorinated additives - may be the primary source of
one subset of the complex organohalogens, the PCDDs and PCDFs.
Other major sources include pulp and paper mills which use
chlorine and chlorine compounds as bleaching agents, and the
manufacture of a variety of chlorinated pesticides and
industrial chemicals.165

Because data on dioxin emissions from hazardous waste
incinerators and other combustion devices are incomplete, it is
not possible to evaluate precisely the role of different types
of incinerators as global organohalogen sources. However,
incineration is clearly an identifiable source of such
contamination. A study of dioxins and furans in Denmark found
that incineration - comprised mostly of garbage incineration -
was "regarded as the chief source of dioxin pollution" in that
nation.166 Canada's Ministry of the Environment came to a
similar conclusion about the sources of PCDD/PCDF in the
Canadian environment.167

A study of the types of dioxins and furans which have
accumulated in the North American environment found that the
distribution patterns of different dioxin and fur an congeners
suggests that incineration of chlorinated wastes is the major
source of these compounds in the environment and in human
tissues:

The US pattern is probably derived from combustion of
chlorine-containing fuels, followed by the preferential
degradation of the less-chlorinated homologues in the
atmosphere. This suggests that exposure in South Vietnam is due
to similar combustion sources, with 2,3,7,8-TCDD from Agent
Orange superimposed ... It would appear that the sources
responsible for the PCDD/PCDF in US adipose tissue originate in
the combustion of chlorine containing fuels. This conclusion is
confirmed by observations of the PCDD/PCDF content of dated
sedimentary layers in the Great Lakes.168

The similar PCDD/PCDF congener "fingerprint" in Great Lakes
sediment -which is only evident in sediments dating after 1940,
when large-scale production and incineration of chlorinated
chemicals began 169 confirms this hypothesis. A 1986 study of
these sediments found that:

atmospheric transport of combustion-derived particulates has
made PCDD and PCDF ubiquitous in the environment ... The most
significant source of PCDD and PCDF veto the atmosphere is
probably the combustion of wastes that contain chlorinated
compounds.170

The role of hazardous waste incinerators in global loadings of
PCDD/PCDF has not been quantified, and controversy about
relative inputs by various sources continues.171

Incinerators also appear to play a primary role in the continued
dispersion of the banned organohalogens PCBs,172 and may be a
major source in the global distribution of hexachlorobenzene and
other dioxin-related compounds. No thorough attempt has been
made, however, to quantify incineration's role in the global
dispersal of these pollutants.


6. CONCLUSION

Incineration is often described as the "preferred alternative",
a "proven technology" or the "only feasible answer" to the toxic
waste crisis. In reality, it merely provides an opportunity for
industries to avoid responsibility for their wasteful practices.
Incineration provides a way for industry to dilute its waste
with large quantities of air and disperse it into the
environment. Thus, it offers a convenient and liability-free way
to mask today's problems and pass them onto future generations.

Incinerator Performance

Both the waste management industry and its government regulators
claim to be able to evaluate and control waste-burners well
enough to guarantee that the pollutants released will cause no
harm. These claims are contradicted by numerous scientific
reports assembled by and for regulatory agencies.

No large-scale combustion system that routinely burns hazardous
waste has ever been fully evaluated.

At present, there is no method for continuously monitoring all
unburned and newly-formed chemicals and metals emitted in stack
gases.

Even in trial burns, only 1 to 60 percent of total mass of
unburned chemicals emitted from an incinerator have been
chemically identified. As a result, the bulk of the chemicals
released from incinerators, even under carefully controlled and
monitored conditions, remain uncharacterised.

Without identification and quantification of all stack
emissions, an incinerators performance cannot, in fact, be
determined.

Operators and regulators contend that they can predict an
incinerator's ability to burn highly variable and diverse
chemical mixtures throughout 20 years of routine operation based
on measurements taken during a trial burn of one or two
individual chemicals over a period of a few hours. Even during
these brief, carefully controlled trial burns, incinerator
operators rely on partial and surrogate measurements of
performance, because only a fraction of the chemicals emitted
can be identified.

Emissions

Burning hazardous waste, even in "state-of-the-art"
incinerators, releases heavy metals, unburned wastes and
products of incomplete combustion (PICs) - new chemicals formed
during the incineration process.

Metals are not destroyed during incineration and are often
released in forms that are more dangerous than the original
wastes.

At least 19 metals have been identified in the air emissions of
hazardous waste incinerators.

An average-sized commercial incinerator (32,000 tonnes per year)
burning hazardous waste with an average metals content emits
these metals into the air at the rate of 92 tonnes per year and
deposits another 304 tonnes per year of metals in its residual
ashes and liquids.

Unburned chemicals are emitted in the stack gases of all
hazardous waste combustion systems. These chemicals also escape
into the air as fugitive emissions during storage, transfer and
handling.

Even if an average-sized commercial incinerator achieves 99.99%
destruction and removal efficiency (DRE) during every second of
operation with every chemical in every mixture burned, it
releases unburned chemicals at the rate of 3 tonnes per year.

The methods used to calculate DRE greatly underestimate actual
emissions. With corrections for errors and omissions, releases
of unburned chemicals for a commercial incinerator of average
capacity may actually be as high as 318 tonnes per year.

Fugitive emissions escape from waste-burning facilities in
quantities equal to or greater than those of unburned chemicals
released in stack gases.

Products of incomplete combustion (PICs) - chemicals formed
during the incineration process - are emitted in the stack gases
and deposited in the residual ashes and liquids of all hazardous
waste incinerators.

Hazardous waste incinerators release "thousands" of PICs.

Some PICs are far more dangerous than the original wastes.
Dioxins, furans, PCBs and other complex organochlorines are
among the most toxic of the persistent, bioaccumulative toxic
PICs emitted by waste-burning facilities.

As much as 1% of the weight of hazardous waste burned is emitted
as substances other than carbon dioxide, water and other simple
combustion products. Based on this estimate, an average
commercial incinerator releases approximately 318 tonnes of PICs
per year into the air. Total emissions from all waste burned in
the EC in 1988 can be estimated at 17,550 tonnes.

Health and Environmental Impacts

Cancer, birth defects, reproductive dysfunction, neurological
damage and other health effects are known to occur at very low
exposures to many of the metals, organochlorines and other
pollutants released by waste-burning facilities.

Increased cancer rates, respiratory ailments, reproductive
abnormalities and other health effects have been noted among
people living near some waste-burning facilities, according to
scientific studies, surveys by community groups and local
physicians.

Touted as an alternative to land filling, incineration
perpetuates the dangers of land disposal. Incinerator ashes,
which are buried in landfills, are contaminated by PICs, many of
which are more toxic than the original waste chemicals. The
ashes also contain increased concentrations of heavy metals,
often in more leachable forms than in the original wastes.

[] TL: A REPORT ON THE HAZARDOUS WASTE INCINERATION CRISIS (GP)
WARNING: Incineration Can Seriously Damage Your Health
SO: Greenpeace International
DT: 1991
Keywords: toxics incineration reports greenpeace human health
risks groups gp /
[part 5 of 8]

The Clean Production Alternative

Given these serious problems with incineration, the only
sensible and permanent approach is to eliminate those processes
and products which create toxic waste that is currently disposed
of by incineration.

Because incineration leads to serious environmental and health
problems, Greenpeace demands that immediate steps be taken to
stop its use. Rather than seeking to refine regulations,
national governments should implement the following policies:

1. Adopt a moratorium on the construction of new hazardous waste
incinerators and the expansion of existing ones;

2. Establish a rapid schedule for phase-out of all existing
incinerators;

3. Immediately prohibit the incineration of wastes containing
metals, chlorine or other organohalogens;

4. Develop clean production programmes to eliminate toxic
processes, products and waste by taking the following steps:

Assess all products and processes to identify and quantify all
toxic substances used, emitted, discharged or otherwise released
from each facility;

Discontinue the use and generation, both deliberate and
unintentional, of all chemicals which are highly persistent or
bioaccumulative or are associated with persistent or
bioaccumulative by-products;

Prepare a detailed plan for phasing out the manufacture, use,
emission and discharge of all toxic substances with a specific
time line. 


7. NATIONAL PROFILES

Introduction

Information about hazardous waste incineration in many countries
has been extremely difficult to ascertain. Many countries do not
publish for public use any information about hazardous waste
incineration - for example, where incinerators are located or
what is contained in any permit required to operate an
incinerator. In fact, some countries have a very lax permit
system. Another serious problem is that many countries define
toxic and hazardous waste differently, and some have no
definition.

Given the fact that access to information is burdensome to
obtain, Greenpeace campaigners in western Europe, Canada and
Australia have attempted to piece together a picture of the
state of hazardous waste incineration today and what is planned
for the future in each country.

Much of the data is incomplete, we cannot attest to its
reliability and we regard what has been found to be only a
partial view of the incineration projects in each country.
However, we believe it is useful to see not only the available
though incomplete information, but also how much information is
unavailable because there is little public access to
information, and/or the information has not been collected by
the government agency which oversees hazardous waste management.

In the following pages is presented the information which we
been able to gather for 18 countries.

******


AUSTRALIA

Under the Australian Constitution, the individual States have
responsibility for incineration of hazardous waste. Therefore
criteria and classifications are not uniform for all States.

Information can generally be accessed by the public, but it
requires a large amount of effort, and needs to be "assembled"
from the various States.

AMOUNT OF WASTE GENERATED:

Precise information not available

AMOUNT OF WASTE INCINERATED:

Precise information not available.

MAJOR CATEGORIES OF INCINERATED WASTE:

Information generally not available, but none of the existing
incinerators are permitted to handle PCB's, organochlorines or
pesticides.

EXISTING INCINERATORS:

- 3 in Melbourne, Victoria 
- 1 in Sydney, New South Wales (NSW) 
- 1 in Adelaide, South Australia

MAJOR INDIGENOUS WASTE GENERATORS:

General source of hazardous waste indigenous. 
No imported waste.

PROPOSED INCINERATORS:

A national facility proposed for construction in New South