A publication of Work On Waste USA, Inc., 82 Judson, Canton, NY 13617 315-379-9200 SEPTEMBER 1994

EPA’S ‘Jekyl & Hyde’ Approach to Dioxin.

September 13, 1994.                          September 1, 1994.                           
EPA’s Dioxin Reassessment documents are      EPA reports that MSW incinerators are the    
expected to inform Americans that the        2nd largest source of dioxin entering the    
dioxin levels we have in our tissues are at  environment.  For 20 years, the EPA has      
a level where scientists are already seeing  tried to convince incinerator host           
effects in wildlife. According to Dr.        communities that MSW incinerators are safe.  
Barry Commoner:  “Dioxin and dioxin-like     Clearly, EPA’S incinerator policy has been   
substances represent the most perilous       an abysmal failure.  Yet, the EPA wants to   
chemical threat to the health and            continue to permit more incinerators.  It    
biological integrity of human beings and     is business as usual at the EPA.             
the environment.”                                                                         

EPA’S CALL FOR NEW MSW INCINERATOR REGULATIONS MISSES THE POINT. Are there no red faces at the EPA? In a few days they are about to release a report that not only confirms dioxin’s dangers but also indicates that the average person in the U.S. receives daily doses which are within one order of magnitude of those expected to give rise to dioxin’s most sensitive effects. Furthermore, this same report indicates that the major source of these dioxins entering our environment have come from incinerators that the EPA has promoted for the past 20 years as posing no significant health threat to their host communities. To rush in now at the eleventh hour and promise 99% reductions in future dioxin emissions is a feeble attempt to divert public attention from the abysmal failure of their pro-incineration policies. We provide ample evidence below that their past attempts to control dioxin emissions from incinerators, as well as the poor science used in monitoring the experiment, have not worked. There is no indication that they have learned anything from these failures. Instead they are planning to sanction a whole new phase of incinerator construction and retrofitting under the guise of “more stringent regulations.” There is nothing in these regulations that indicate that the public is going to be better protected, or the facilities better monitored than before, or that incinerator operators will be held accountable for anything. It is business as usual at the EPA. If we are not careful, billions more tax dollars are going to be wasted on a technology that takes us in the wrong direction from that of securing a sustainable future.

Based upon the failures listed below, and the positive experiences learned by those communities who have rejected incineration and have pioneered far safer alternatives, it is important that citizens are not diverted by the 99% reduction promise but instead use the opportunity created by the devastating dioxin reassessment documents to call for a complete ban on new incinerators and the rapid phase out of existing facilities. To argue about the details of the new proposed regulations is to miss the point of the dioxin reassessment. The current exposure to dioxin is too high. Exposure to new sources is unacceptable.

In the hands of the regulators the incinerator dioxin debate usually comes down to what level of dioxin exposure is considered acceptable. Seldom is much time given over to two far more important questions in a democratic society: to whom are these risks acceptable and who decides? However, over the past 10 years hundreds of communities have faced these questions and have performed their own simple risk assessment: no risk is acceptable if it is avoidable. Confronted with this devastating logic over 280 MSW incinerator proposals have been defeated or put on hold. In the meantime, numerous communities have clearly demonstrated that there are better alternatives which do not project dioxins and toxic metals into the air, water, soil or our food. If the EPA faces the same logic, it should realize that its future efforts, time and money should be put into promoting these alternatives and not into salvaging the remnants of its pro-incinerator policy. With these things said now let us look at EPA’s failed incinerator-dioxin experiment:

* EPA says they will reduce dioxin emissions by 99%. Unfortunately, the EPA does not have good data on how much dioxin is emitted from existing MSW incinerators. A 99% reduction sounds good, but 99% of what?? For example, in 1993 EPA’s top dioxin scientists stated with “high confidence” that the total amount of dioxin toxic equivalents (TEQs) from all operating MSW incinerators combined was between 60 to 200 grams and they ranked MSW incinerators as the 7th largest source of dioxins entering our environment. Yet in 1992, dioxin tests at the Columbus, Ohio, incinerator indicated that this one incinerator was emitting 984 grams of dioxin TEQs -- nearly five times the total dioxin TEQs estimated for all U.S. MSW incinerators combined. Now, in September 1994, the EPA ranks MSW incinerators as the 2nd largest source for dioxin air emissions. Let’s assume (because of the lack of good scientific data) that the total dioxin air emissions from all operating MSW incinerators in the U.S. is 30,000 grams dioxin TEQ. A 99% reduction would lead to 300 grams of dioxin TEQs. Acceptable?

* The dioxin emission data that has been collected has been made under artificial (i.e. ideal) conditions; usually tests are made when the plant is brand new or the company gets at least a month’s warning that tests are going to be made. How many scientists at the EPA truly believe that this test data gives a handle on day-to-day emissions for a facility burning waste 24 hours a day, 365 days a year?

* There has been little or no attempt to collect dioxin emission data over an extended period of time to check for seasonal and other variations with the waste stream.

* There has been little or no attempt to validate emission data and dispersion models with environmental monitoring of soil, leaves and animal tissue levels over an extended period of time.

* There has been little or no attempt to validate health risk assessments by performing health surveys of host communities.

* Even though it is well known that dioxin is synthesized on fly ash particles there have been no federal regulations established to protect and monitor workers handling this ash.

* Even when dioxin emissions are found to be abysmally high, as in the case of Columbus, Ohio, the EPA has not stepped in to shut down the facility.

* Even when dioxin emission tests have been shown to be rigged, as in March 1994 in Columbus, Ohio, the EPA refused to pursue violations of federal environmental law.

* The EPA has failed to warn communities that there is currently no device available which can monitor dioxin emissions on a continuous basis, thus there is no way to ensure that an incinerator keeps to any dioxin removal level.

* The EPA, while claiming that MSW incineration is safe, has failed to acknowledge that there is not one published health study of the people who live in MSW incinerator communities.

* Startup, shutdown and malfunctions at MSW incinerators are unavoidable and it is exactly during these periods that the maximum amount of dioxins and other toxins will be emitted into the environment. In Jan. 1991 the EPA enacted regulations that exempted MSW incinerators from regulation for up to 3 hours per occurrence of startup, shutdown and malfunction.

* The EPA and public health officials have never considered the synergistic effects of the multiple toxics emitted by incinerators on the public health.

* The EPA have never taken into account the background levels of cancer, respiratory problems or infectious diseases like AIDS in communities targeted for MSW incinerators.

* The EPA and public health officials have never even shared with the public the potential for the formulation of new toxics, in addition to dioxins and furans, created by MSW incinerators. It would be a chemical miracle if other toxic compounds were not being created.

* In Health Risk Assessments the uptake of dioxins in the food chain is considered. Many incinerators are operating in major agricultural areas. Health Risk studies sometimes assess the risk of consuming locally grown produce (milk, meat, cheese, fish, grains, etc.) by the residents of the county or community in question, but they do not assess the risk for food that is exported out of the county. (Generally in agricultural areas, the majority of the food is exported.)

Based on their track record it is unlikely that in the future the EPA will be able to adequately monitor any incinerator for its dioxin emissions or its threat to the public health. This is bad policy backed up with bad science. Thus the promise of a 99% reduction in dioxin may look like progress to some, but to us it looks like business as usual: more regulation at the back end of a problem rather than moving to the front end. It’s more voodoo science rather than a vision of what the future requires. EPA must desist from promoting the use of tax payers money to perfect the art of destroying our resources. EPA should, instead, direct tax payers money into efforts that perfect the art of recovering resources. It is time someone told the bureaucrats at the EPA that we do not have another planet to go to after this one has been used up.

EPA’s Proposed Numerical Limits Dioxins/Furans (total) Dioxins/Furans Lead Cadmium

Per incinerator stack: ng/dscm Toxic Equivalents mg/dscm mg/dscm

Small Existing Incinerators, 40-250 tpd 60 1.0 1.6 0.10

Large Existing Incinerators, over 250 tpd 30 0.5 0.50 0.04

All New Incinerators (exempt under 40 tpd) 13 0.2 0.10 0.01

(The old standards for dioxin were: New incinerators = 30 ng/dscm; 250-1100 tpd = 125 ng/dscm; Over 1100 tpd = 60 ng/dscm.)

(ng= nanogram; dscm= dry standard cubic meter @ 7% Oxygen; mg= micrograms.)

Mercury = all incinerators (except those below 40 tpd) = 0.08 mg/dscm or 85% reduction. Only 3 heavy metals have new standards. According to EPA’s Walt Stevenson the EPA had no standards for these 3 heavy metals. New standards have also been proposed for acid gases and particulates. Since 1989 the EPA has used the international NATO toxic equivalent standards. Incinerators will have to come into compliance with the new regulations within 1 to 3 years after EPA finalizes the regulations. After an incinerator is in compliance with the regulations, annual emission tests will be required for the lifetime of the incinerator


We need to form a Citizens’ Task Force on MSW Incinerators and become highly involved with EPA’S DIOXIN REASSESSMENT HEARINGS and EPA’s proposed MSW incinerator regulations. At this critical juncture we must coordinate our efforts. This may be the only real opportunity citizen activists will have to influence EPA’s policy. If you or your group is interested in being part of the team to organize the Task Force, contact W.N.

WASTE NOT # 300. 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 $US50; Overseas $65.

Editors: Ellen & Paul Connett, 82 Judson Street, Canton, New York 13617. Tel: 315-379-9200. Fax: 315-379-0448.