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

__ PART 2 of 3-Part Series: The Background:__ In March
1992 residents living close to the Columbus MSW incinerator became
alarmed about the number of health problems in their community.
They began their own investigation of the possible sources of
the tumors, cancers and respiratory problems that they and their
children were experiencing. At this point they learned that
the Columbus trash incinerator was operating with only one pollution
control device: an

__ Our Response:__ We would like to begin our response
to the letters from Dr. Rigo and Mr. Diamant by apologizing to
Dr. Rigo for stating in

What we should have said was that **“we assume that
Dr. Rigo knew that the Ohio EPA calculations for the 1992 dioxin
test ( published in February 19944) showed that the Columbus incinerator
was yielding 984 grams of dioxin TEQ per year.”**

More precisely, we had assumed that Dr. Rigo, a professional consultant
dealing with incineration and dioxin issues, hired by the Columbus
Department of Health because of high dioxin emissions from the
Columbus incinerator, would have reviewed all the documents dealing
with the dioxin emissions from that facility. In particular,
we had assumed that he would have reviewed the Health Risk Assessment**4**
prepared by the Ohio EPA and published on February 28, 1994.
We had assumed, therefore, that Dr. Rigo knew that this agency
had stated that the dioxin emissions from the one boiler that
was tested (based upon an average of five tests) were **7.397
x 10-6** grams per second**5.** We further assumed that
armed with the knowledge that the Ohio EPA had calculated the
average boiler usage was 4.22 boilers**6** (the incinerator
has 6 boilers), that he, like us, could have made the simple extrapolation
to an annual emission rate of 984 grams per year, using this calculation:

We further assumed that if Dr. Rigo had reviewed these emission
levels prepared by the Ohio EPA (and reviewed by the U.S. EPA)
and disagreed with them, he would have made that disagreement
public at the August 18, 1994, Press Conference. Finally, we
assumed that if Dr. Rigo had known the 984 grams per year figure,
extrapolated from the Ohio EPA calculations, that he would have
realized that this invalidated his estimate that all U.S. trash
incinerators combined were only yielding an annual emission of
850 grams. However, despite what we consider elementary and reasonable
deductions on our part, we have to admit that we were not privy
to what Dr. Rigo actually __knew__ on August 18, 1994, and
so we apologize to Dr. Rigo.

Having apologized, we must say that we are very puzzled by some
other comments made by Dr. Rigo and his lawyer, Mr. Diamant.
We are going to address these issues, but in the interest of fairness
we are going to offer Dr. Rigo a chance to reply before we go
to press so that we can include his comments in this *Waste
Not* series. (See *Waste Not # 305.)*

In Dr. Rigo’s letter to Mr. Pompili (Sept 15, 1994) he claims
that his 850 gram total for all U.S. trash incinerator emissions
combined “is not invalidated by a comparison to the highest
individual run in the two-conditioned 1992 Columbus test.”
However, the Ohio EPA made it quite clear in their Health Risk
Assessment**4 **that the emission figure they used (and which
extrapolates to a 984 gram per year total) was based on an __ average
of all 5 tests__, which included the three compliance tests
and the two baseline tests, as the following excerpt makes clear:

In his Sept. 15th letter, Dr. Rigo claims that he gets a figure
of 516 grams per year using the “correct average baseline
value.” We are puzzled, in the light of the Ohio EPA’s
analysis, which was apparently reviewed by the U.S. EPA, why he
feels using only the __two__ baseline values gives a more representative
value than the average of __all five__ tests, especially since
one of the two baseline tests was only run for 50% of the normal
testing time because it “was shortened due to thunderstorms
in the area.”**7**

We are further puzzled by Dr. Rigo’s estimates of 516 grams,
since extrapolation from 0.18 kg/year, given as the average baseline
emission by the Ohio EPA**7**, yields a total emission (assuming
a 4.22 average boiler usage) of 760 grams per year

We would appreciate Dr. Rigo sending us details of his calculations so that we can run them by the Ohio EPA for their comments.

Even if we take Dr. Rigo’s estimated 516 grams TEQ annual
total for the Columbus incinerator at its face value, we are still
puzzled why he didn’t draw attention to it at the August
18th Press Conference since it represents **60 percent** of
the **850 grams TEQ **total he had estimated for ALL (127+)
U.S. trash incinerators combined. Such a comparison would have
indicated that either the Columbus incinerator was very high,
or his estimate for the combined total of all U.S. trash incinerators
was very low. His omission becomes even more puzzling when it
is taken in conjunction with a statement made by Mr. Pompili (Assistant
Health Commissioner for the city of Columbus) in a September 16,
1994, letter to Stanley and Sherry Loscko:

If the Columbus incinerator is not “number one or two”
in U.S. trash incinerator dioxin emissions, and as Dr. Rigo estimated
that 516 grams dioxin TEQ from the 1992 Columbus test burn, then
the lowest total figure for __all__ U.S. incinerators must
be at least three times 516 grams, or 1548 grams per year. Even
this assumes that the other 127 or so trash incinerators have
a combined emission total of zero grams of dioxin! It is quite
possible, however, that Mr. Pompili and Dr. Rigo have made their
calculations since the August 18th Press Conference, in which
case we hope that they will share with us their latest views on
this matter.

In his September 19th letter to us, Mr. Diamant refers to our
extrapolation of this 984 gram figure for annual dioxin TEQ emissions
from the Columbus incinerator as “clearly erroneous and does
not follow accepted statistical and engineering standards.”
In our view, Mr. Diamant is wrong in this assertion. As the
calculations above indicate, we derived the 984 grams per year
total by applying simple arithmetic to the **7.397 x 10-6**
gram per second for the boiler tested and assuming the 4.22 boiler
usage figure supplied by the Ohio EPA. It required no reference
to engineering or statistical methodology on our part. If Mr.
Diamant has a problem it is with the Ohio EPA. ---- Continued
to *Waste Not # 305.*

**References appear in Waste Not # 305**