A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 November 1, 1990

JUNE 1990 DIOXIN TEST EMISSIONS ARE 8 TIMES HIGHER THAN ALLOWABLE DIOXIN PERMIT LIMIT, OR, 400 TIMES THE NEW DIOXIN EMISSION STANDARD FOR THE FEDERAL REPUBLIC OF GERMANY.

Waste Not comment: When Oneida-Herkimer officials caution that the dioxin measurements made during the testing period do not necessarily mean that residents are exposed to these levels on a daily basis, they are correct. Simply testing a facility for three days gives little indication of what the plant puts out for the other 362 days of the year. The only way one can satisfactorily monitor for persistent pollutants like dioxin, which have a very long half life in soil (12 years), plants, animal, and human tissues (7 years), is to monitor the environment, i.e., the uptake in the soil, pine needles, or mothers breast milk, etc. This is the only way to truly establish the cumulative impact of dioxin emissions in the area. Rather than adopt this rational policy Oneida-Herkimer officials continue to waste money on stack tests which, when results are under permit limits, they accept, but when the limits are exceeded, more testing is called for. This is a case of heads-they-win and tails-the-residents-lose. If that strategy doesn’t work, then they will call in a consultant, in this case Ned Holstein, of Environmental Health Assoc., ‘to prove’ the emission levels are ‘safe’. Before the citizens fall for this pseudo-scientific exercise, they should check Ned Holstein’s record on these matters. In particular they should look at his assessment performed for the then-proposed Claremont, NH, incinerator in which Holstein calculated the projected dioxin dose through cows milk. Holstein, together with J. Gronemeyer, considered two possible routes cows could be exposed to dioxin from the incinerator: from the soil or from the plants (fodder or forage). Holstein dismissed the route through ingestion of contaminated plants using the following argument:

Using this argument, Holstein conveniently ignored the more obvious and important route of dioxin exposure to cows, namely the deposition of dioxin from the air directly onto the plant surfaces. It is hard to believe a professional (Holstein’s fee for this work was $23,000) could unwittingly make such an elementary mistake. The result of the ‘mistake’ was to grossly underestimate the dioxin dose to the cow, and hence the dioxin dose to the humans consuming the cows milk. Rather than further time-wasting and pseudo-scientific exercises, the Rome incinerator should be closed down forthwith while the environment is monitored for heavy metal and dioxin contamination upwind and downwind of the facility. This would be a scientific way of pursuing this problem. An experiment has been carried out against the wishes of the population. It appears from the trash authority’s own measurements the experiment hasn’t worked very well. The very least the public should expect is that the data now be collected from that experiment and the damage assessed by independent authorities.

Dioxin tests at the Rome incinerator: The NY DEC required only one dioxin test for this incinerator, and that was performed by the NY DEC in 1985. One of the dioxin samples in 1985 was lost in the laboratory, and according to John Fitzgerald, president of the Rome-Floyd Residents Assoc. (RFRA), the incinerator has been running on limited and incomplete test results. In October 1989, three dioxin tests were run in three days. Out of the three dioxin tests, one day was in exceedance of the permit, but the average was under the 5 ng per cubic meter. There was no state requirement to test again for dioxins after the 1985 tests. Residents believe the reason why the trash authority performed further tests was to justify their plans to expand the Rome incinerator from 200 tpd to an estimated 400 to 500 tpd. According to Marj Patrick, the public information officer for the Oneida-Herkimer Solid Waste Management Authority, the authority has determined that it will perform annual emission tests for a wide range of pollutants. According to John Fitzgerald of the RFRA the public has never been formally advised of the authority’s decision to do annual testing, even though the RFRA has continually asked for that over the years.

In 1985 the Rome incinerator had the second highest ‘test series average’ of mercury emissions in the EPA data base. According to Craig Volland, president of Spectrum Technologists, conservative mercury emissions for 1985 from the 200 tpd Rome incinerator would be between 1200 to 1500 pounds.

DUTCH UPDATE: Holland has closed down four of its 11 trash incinerators because of high dioxin emissions and build-up of dioxins in cows milk, according to Dutch scientists at the September Dioxin ‘90 conference held in Bayreuth, Germany. Plans are underway to retrofit the remaining Dutch incinerators with activated charcoal filters. With Holland, Germany and Austria putting on activated charcoal filters on incinerators, no manufacturer in the U.S. can now claim that their facilities are fitted with “best available control technology.” The art (experiment?) has moved on. An interesting comparison: In Europe when they find the dioxin emissions from incinerators are above permit levels they either shut the facility down or retrofit with activated charcoal filters. In the U.S. they either call for more measurements or perform a health risk assessment!