A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 June 20, 1991

Note to our readers: Our apologies for not informing you ahead of time of a three week vacation by Waste Not. This break allowed Waste Not time to move to two large new offices, at the same address, while Paul was in Spain, Belgium, Norway, Ireland, and England, for the last month on incineration issues.

MINNESOTA: FAILURE EQUIPMENT SHUTS DOWN MINNEAPOLIS’ 1,000 TPD GARBAGE BURNER. “Equipment failure or possibly an explosion in a boiler caused Hennepin County’s garbage burner to be shut down [on 5-22-91], its first major malfunction since it began operating in late 1989. Garbage kept smoldering after the plant was shut down, sending dense smoke pouring out of the building and triggering fears of a fire in the plant. Hampered by the fact that the boiler was too hot to inspect until sometime today, county officials said they couldn’t be sure what triggered the shutdown at about 10:15 a.m...The 1,000 tons of waste burned every day -about one-third of the garbage produced in the county- will temporarily be hauled to incinerators in Elk River and Newport, said county engineer Vern Genzlinger...Pressure rapidly built up inside one of the plant’s two boilers...after the pressure in the boiler spiked, electricity supplying the plant was automatically cut off, shutting down the boilers, fans and other equipment throughout the incinerator. Without fans to draw the smoke out of the dying fire in the boiler smoke filled the building...Two companies of firefighters had to work in the plant in shifts, hosing down equipment because of the intense heat...The incinerator was controversial even before it was built, and the shutdown comes on the heels of a recent failure to satisfy state air quality rules...for emitting more mercury from the plant than is allowed.” Star Tribune, May 23, 1991. The shut-down lasted approx. one week.

MINNESOTA: MINNEAPOLIS’ 1,000 TPD GARBAGE INCINERATOR EXCEEDS MERCURY PERMIT. Blount was the original owner and operator of the Minneapolis incinerator which went on line in October 1989. General Electric had bought out Blount’s equity interest in the incinerator and as of May 24th Ogden Projects became the official owner of the operations contract. But it is Blount, who operated the incinerator during its second violation of the mercury permit, which will receive a civil fine for the violation. The Minnesota Pollution Control Authority (MPCA) has permitted the incinerator to emit .002 pounds of mercury for every ton of garbage burned, or two pounds a day. The most recent three samples had an average of .0028. In the initial permit Blount had to shut down the incinerator within 72 hours if a problem with meeting permit standards could not be corrected. But the Minnesota State Legislature changed that stipulation to 30 days for a problem to be corrected after the first mercury permit violation.

April 27, 1989: Hennepin County Commissioner Mark Andrew, an incinerator proponent, thought that the Minneapolis incinerator would meet the mercury standard, but stated that if it failed “We will have to shut the facility down.” St. Paul Pioneer Press.

May 8, 1991: Hennepin County Commissioner Mark Andrew said “...‘there is not a whole lot we can do’ about the mercury violations as long as there is mercury in batteries, which end up in the incinerator...” Lisa Thorvig, acting director of the MPCA’s air quality division “said the agency does not shut down any facility unless it never complies with its permit, and the incinerator is nowhere near that point.” St. Paul Pioneer Press.

“Playing with Fire” A new Greenpeace report written by Pat Costner and Joe Thornton $24 for Individuals & Non-profits and $100 for Industry from Greenpeace, 1436 U Street, NW, Washington, DC 20009

Well-written, comprehensive, and packed with information this report is critical to anyone fighting a hazardous waste incinerator. Greenpeace, Costner and Thornton have done it again: this is truly a must-read report. Because each of the 63 pages in this report contains such important information, we will concentrate on one area only, and leave the rest for you to read in the full report itself.

Destruction and Removal Efficiency or DRE. “An incinerator’s DRE is the ratio of the quantity of a preselected chemical - a POHC [principal organic hazardous constituents] - released into the air after passage through the incinerator and its pollution control system to the quantity of the POHC that was originally fed into the incinerator. POHCs chosen for trial burns are presumed to be those chemicals that will be in highest concentrations in the wastes to be burned during routine operation and/or those waste chemicals that will be most difficult to destroy. Achieving a DRE of 99.99 percent means that 0.01 percent 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 percent of the POHC was actually destroyed. The above [DRE-based] P>standards only address the POHC residues at the stack and fail to address other possible effluents such as products of incomplete combustion (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 all possible effluents and to provide engineering data for regulatory support. (Trenholm 1987). 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 often buried in landfills, from which pollutants eventually will escape and enter groundwater or surface water (U.S. EPA 1982). Liquid residues are treated -leading to the partial removal of some toxic constituents- and then discharged to lakes, rivers, or streams. DREs do not reflect the toxicity of incinerator air emissions. For example, in one series of tests, the POHC mixture with which the highest destruction efficiency was achieved also yielded the highest levels of one PIC, benzene. Researchers concluded, ‘High DREs are not always indicative of PIC emissions.’ (Chang 1988). Several other studies have also documented the simultaneous occurrence of high DREs and high PIC emissions. One group of reviewers summarized their findings as follows: [A]chieving 99.99% DRE does not necessarily guarantee that emissions are minimized. (Huffman 1985). DRE measurements have also proven to be highly inconsistent and unpredictable over time. One team of scientists found variations in destruction efficiency of up to ‘an order of magnitude’ with no correlation with operational parameters or surrogate indicators, such as carbon monoxide emissions (Mason 1988). The Science Advisory Board of the U.S. EPA offered the following caveat on reliance on DREs as criteria for protecting public health and the environment from the impacts of hazardous waste incinerators. [T]he current 4-nine (99.99%) DRE standard could theoretically allow PICs emission levels which could present significant human health risks. (U.S. EPA 1989a)...In summary, there is no sound basis for assuming that the demonstration of a DRE of 99.99 percent during a trial burn of one or more POHCs proves that this level of destruction will be achieved during the daily incineration of complex waste mixtures over years or even decades. Furthermore, POHCs presumed to be relatively easy to destroy may produce PICs that are extremely difficult to incinerate (Staley 1986)...” Products of Incomplete Combustion or PICs: “The first and largest category of PICs has been characterized as containing species that are ‘more difficult to destroy and...more toxic than the present compound.’ (U.S. EPA 1985).”

Propagation of Error: “Ignoring the propagation of errors in the computation of a DRE can lead to the derivation of a nominal DRE that deviates radically from the actual DRE. At present, DREs are calculated through a multi-step process using data gathered from numerous sources by a variety of techniques. There is inherent imprecision and inaccuracy 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 the accuracy of the devices in trapping POHCs for DRE determination to vary by +/- 50 percent or more (Jakanty 1989)....”

Hysteresis Effect: “Another major flaw in the current method of determining DREs became evident with the discovery of an hysteresis effect: the retention of POHCs within the combustion system leading to their continued appearance in stack gases for prolonged periods of time after their flow into the combustion system has been stopped. In one of the first reported cases, scientists observed that ‘stack concentrations of waste species continued for several hours after waste firing was curtailed’ during trial burns of a boiler (Mason 1988)...Another study confirmed that the hysteresis effect in boilers was ‘both real and measurable.’ The authors noted that POHC emissions were continuing as long as 65 hours after waste co-firing ceased. Delayed emissions were observed in both vaporous and particle-bound forms. The authors wrote that ‘it appears possible that a DRE could be measurably affected under some conditions’...”

WASTE NOT # 153 A publication of Work on Waste USA, published 48 times a year. Annual rates are: Groups & Non-Profits $50; Students & Seniors $35; Individual $40; Consultants & For-Profits $125; Canadian $US45; Overseas $65. Editors: Ellen & Paul Connett, 82 Judson Street, Canton, NY 13617. Tel: 315-379-9200. Fax: 315-379-0448.