PROCEEDINGS OF THE EXPERT PANEL WORKSHOP
TO EVALUATE THE PUBLIC HEALTH IMPLICATIONS
FOR THE TREATMENT AND DISPOSAL OF POLYCHLORINATED BIPHENYLS-
CONTAMINATED WASTE
Chapter 3 - Expert Panel Report (Cont'd)
IV. SUMMARY STATEMENT OF EACH PANELIST
At the end of the Panel discussions, each Panel member was given the opportunity to make a 5-minute general statement. It was suggested that panelists discuss their views on incineration, the health impacts of incineration, what ATSDR should consider when doing a health assessment of incineration, or the key points that should be considered. Following is a transcript of each panelist's statement, in the order they were made at the meeting. Only minor editorial changes have been made by the panelists.
I'll start out by saying that I think incineration is a viable method of destroying waste which is particularly valuable when the physical and chemical form of waste is variable. That's where it's preferred, or may be preferred to alternatives. But whether it's used or not depends upon the local community. I think our role is to provide the best scientific information to communities, so that they can make their own decisions. Where incineration is adopted, it should be regulated to minimize public risk. And I think ATSDR, in looking at the risks, should consider both local impact and also the national impact--that is--what is the impact of all PCB incinerators, with allowance for long-range transport. Even where the risks do not justify it, I think one should adopt the very best available technology. We discussed going beyond the emission standards on particulates, because clearly there are better technologies today, which are widely adopted in Europe. I don't see why they should not be adopted in the U.S.--to meet, say, 30 milligrams per meter cubed instead of 180.
The two classes of pollutants for which emissions from incinerators are significant relative to other sources are the dioxins/furans and heavy metals. There are many other compounds in the effluents, but I think whether those are analyzed on a routine basis should be based on whether a risk is perceived or identified. I think that use of limited resources to do the job well, rather than spreading them out over many chemicals, is best. Where I think ATSDR can provide a service is the monitoring of (using) biomarkers in combination with exposure models in order to validate and refine our methodologies. If there is another Panel in a few years, hopefully, they'll have a better story to work with than what we have here.
First of all, I think, once again, it's been a very useful opportunity for members of multiple disciplines to get together and talk through these issues. I found it to be a very good and positive discussion and I certainly learned some things from it. In terms of suggestions or advice for ATSDR, I think if we're going to be looking at incineration as a possibility, we do need to deal with the upfront issues of movement of the waste materials to the facility. We heard that over and over again, and I think that's an issue that is important to get out on the table, both in terms of questions of volatility and fugitive emissions. I continue to be comforted by the theoretical aspects of incineration from listening to people talk about them. I'm reasonably well convinced that we can do the job of destroying waste that we want to get rid of, and that the technology is evolving to allow us to do a better and better job at that. I do have to say, however, that I still am not as comfortable with the characterization of what good current practice is, in terms of incineration. I heard a number of potential safeguards for assuring good practice, and I guess I'd like to suggest that ATSDR take that into consideration, and really look at how one can look at both management and scientific checks and balances for good incineration practice. In terms of characterization of the emissions from the incineration process, I don't have a good sense of the relative contribution of, I guess we call them process emissions, as opposed to stack emissions, in terms of current practice and that's something that ought to be looked at carefully. That's something that, in terms of our evaluation of risk, needs to be factored in at some point. Generally, it is considered that those are not significant contributors to long-term exposures, but they may very well be significant contributors to acute episodes. That needs to be looked at more carefully, I think, so risk assessors have a better sense of what the relative contributions are. In terms of the emission profile, again, I feel reasonably comfortable with the suggestions that have been made by the panel in terms of what kinds of surrogates for emissions should be looked at, both in terms of looking at the operation of the incinerator, as well as understanding what types of emissions might be coming out. For the health risk assessor, knowing the total amount of hydrocarbons coming out, knowing something about some of the specific pollutants like dioxins and dibenzofurans, metals, and a profile to some extent of some of the other PICs is adequate to feed into our process.
I hope we've conveyed the point to those of you who are not as familiar with the risk assessment issues, some of the uncertainties we have to deal with, both from the toxicological database and the exposure issues. One of the points we made pretty carefully is that I hope everybody will ask the basis for numbers that are put out there in terms of risks, so that there's an understanding of what those numbers mean, and whether they are comparable from chemical to chemical, facility to facility, and technology to technology. That, to me, seems to be an important issue. Finally, I want to second or third or fourth, or whatever it is at this point, the suggestion that there should be more biological monitoring, both in populations around incinerators and at other hazardous waste sites, so that we have a better sense of the validity of the models that we have used to predict exposures from these particular facilities. And the last point is, we all need to do a better job of communicating our respective disciplines. This is not an easy issue, and I think that just getting together and trying it out this way makes it just that much easier when we have to talk to decision makers and the public.
I want to make a couple of points here. The main one is to ATSDR and/or the public, and that is, as you look at some of these non-incineration technologies, be sure you are just as inquisitive, just as hammering, in trying to get to the real answer, and to the bottom line, as you are with incineration. I think a lot of questions about things like chemical dechlorination and ISV (in situ vitrification), and bio-remediation, haven't been asked, let alone been answered. Beware of the hidden leftover residues, beware of emissions that nobody has thought about and nobody has measured, or qualified, or analyzed yet. Be aware of some of these things that are lurking within the nice-sounding, non-emission types of technologies. Because they're there. I know they're there, and I constantly ask my colleagues questions analogous to what I'm constantly asked about incineration, and it's obvious that either they haven't thought of the question, or they don't have the information.
The other issue is that I started to boldly offer my definition of what a so-called, well-designed and operating incinerator is. What would be my dictionary definition? I have to admit, I chickened out on that because some of the my colleagues around the table here would say to me, give me one example, just name one. And I probably couldn't do it, because they're all sort of in various states of aspiring to be the perfect incinerator. I don't think there is a case in point of a real, perfect, non-polluting incinerator. They all have issues, they run well some of the time, and they might have their little stumblings or faults, but I see, thankfully, a constant striving for improvement. You always see better equipment being installed, even on older incinerators, more careful watching--EPA especially is constantly tightening up regulations, doing studies--asking ourselves whether we are regulating enough, or the right way, and so forth. I backed off from that definition, but I do want to kind of lecture on several key points with regard to remediation--incineration applied to a Superfund site, based on my experience.
Where you need to start off with, when you have a site and you are considering incineration or have chosen incineration, start off with a high-quality RFP (request for proposal); that's so important. To do that you need to assemble the proper number and types of experts, design engineers, the health risk people--a whole line from not only EPA, the Army Corps of Engineers, and ATSDR, I think, should be involved in the design and writing of the RFP to make sure you define the problem, and define what you need in terms of the types of waste, materials of construction, the list goes on and on. The next step is also very key--it's bid selection. Once you've sent out a public RFP, you begin to get the bids in, and then you have to evaluate them. Comparing one company's offering of "X" incinerator versus "Y" incinerator, and so forth. Again, that same group of experts who assembled the RFP should be there reviewing the bids, to select the best bidder. I've been involved with several of these bid writings and bid selections myself, and I have to say, none of them have really had a well-rounded Panel, and the result is always you get sort of an acceptable incinerator, but it could be better. Don't underestimate the amount of effort it takes for the RFP and bid selection procedure. Thank you.
I have a couple of thoughts. One is on communication. One of the ways scientists can communicate better is if the engineering community and the public don't hold scientists responsible for determining the safety of the process. It is outside the realm of science to determine whether something is safe. The best we can do is weigh the preponderance of the evidence and determine whether something is probably not unsafe. It's really in the realm of risk management, not risk assessment, to decide whether a process is safe or not. So I think that a lot of the problem with risk communication is that we scientists are being asked to do things that it's really outside of our realm to do.
With regards to incineration, I think that we've had 2 days to have the luxury of debating some of the fine scientific points, and caveats, and qualifiers. In doing so, we run the risk of missing the big point, and that is, incineration is a viable technology. We've destroyed many hundreds of millions of tons of hazardous waste safely. We've removed them from the environment. We've prevented untold numbers of Superfund sites. Incinerators can be the solution, not necessarily the problem. To focus on just the few bad operators as the norm, which they're not, is to really run us in a lot of danger of cutting off one of our best options for effectively managing some of these wastes. As an example, the question isn't always 99.99% versus 99.9999% destruction; to me, it's whether 99.99% is better than 0% destruction, which is what storing waste indefinitely or putting it in a landfill amounts to. I think those are some of the big picture questions that need to be kept in mind.
I was here in Bloomington 5 years ago, and I'm a little surprised that the issues are still the same now as they were 5 years ago. It disappoints me that we can't do anything better for the local residents. It's still an engineering question--can an incinerator be built, at whatever cost, that will efficiently manage the physical and chemical difficulties of the combinations of PCBs in municipal waste and sewage treatment sludges? I don't know if that engineering question has been sufficiently addressed, and until that's addressed, we can't access adequately the health impact of such a process.
Crystal ball projections? I will go on record. I think the focus on dioxins is totally overstated relative to the realm of contaminants coming out of stacks and the potential impacts on human health and the environment. I think history will look back on this as an era where we focused a great deal on the toxicants that we can spell, and less on those that are a real major impact to human health and the environment. I think that's causing us to overlook some real environmental health hazards.
Furthermore, in contrast to what the Panel concluded yesterday (which was that pilot plants were not an acceptable source of emissions data to use in risk assessments), I do think that if a pilot plant can be designed that is somewhat comparable to the final design, a pilot plant can in fact be a really good representative, or surrogate, for providing emissions data to use in some health risk assessments.
I very much appreciate ATSDR pulling this group together. I know it didn't serve Bloomington's purpose, but maybe it served a larger purpose in getting some of these issues out on the table. A couple of areas that I can see for the long-term role of ATSDR are these: certainly long-term biomonitoring, which is certainly overdue, and a very welcome addition to understanding and answering a lot of these issues. Number 2, help us better compare the relative risks of remediation technologies, which has not been done in a consistent fashion. Number 3, helping better define the emissions of true health concern rather than, as Drew alluded to, just copying what everybody else has done in selecting emissions of concern and not even thinking about what's going on in the kiln. Number 4, just helping us to translate this mass of data and facts into something that's truly useful information, about which we can make informed decisions. We are swimming in oceans of data, and yet we are not making reasonably good or informed decisions about them, at least not to the level of decisions that all this data would indicate that we could. Those are my comments.
Well to echo some of the other Panel members, I appreciated being here and even enjoyed moments of it, Dick. I have felt a lot like the surprise guest at the wedding. On the incineration issue, I think we, as at least examiners of technologies and appliers of technologies, owe it to the public to be very forthright and very honest about what we do and do not know. And I think back, I don't know about the rest of you, but when I was in graduate school, the worst thing you could do was admit that you did not know something. And either that unwillingness to admit that you don't know, or an ingrained arrogance, prevents you from admitting that you don't know. I think that serves the public the most poorly, and I think we have to be very real, that in this case, we do not know what is in the waste, what is in the material that will be burned. We do not know what the stack emissions will be, if it is incinerated. Of those stack emissions that we will be able to identify, we do not know all of their toxicological impacts. Given all those "we do not knows," and given the limits of precision and accuracy of the various methods whereby we are able to quantify and identify those few constituents in the air emissions that we can identify and quantify--I think it is unbearably arrogant, or we are quite remiss, if we pretend to the public that we can sit and tell them that there will not be impacts from the incineration of this waste.
I do not believe that risk assessment, in its current state, is more than an art. I mean, it may obtain the level of science at some point. I think that risk assessment is a lot like the perpetual motion machine--it's a great idea, but I don't really know anybody who can do it completely yet. I think it is an issue that's used as a smoke screen, to hide from the public what their exposures to various chemicals are. I think that in that case, again, we are misusing and abusing the public with that reliance, and this is not to speak ill of anybody's profession, or anything that they're fully dedicated to. I think it's something that is of interest and should be developed. I'm saying that I don't believe at this point that risk assessment is well-enough developed to be a basis for public health and public policy decisions.
So again, just to reiterate, we don't know what's going in, we don't know what's coming out, we don't know what the effects are of what we do know is coming out. So given all of that, I just have to question that anyone can contend that incineration is a viable technology at this point. We're talking here about experimentation. We're talking about biomonitoring in the public, to ascertain the effects of the technology that will be applied with some insistence. I question the ethics behind decisions that lead to this. And of course you have to question the decisions that led to the development of Superfund sites like this in the first place. Where are the perpetrators of this? Are they being held fully financially responsible for this? Why aren't they at the table at this discussion? Certainly the people who generated PCBs should know more about their disassembly and their detoxification than any of the rest of us. Why aren't they here? Why did we not insist that they be here?
I would reiterate what Adel said, only I would expand on that--I believe that incineration, in fact, all combustion technologies, should be looked at from a national perspective. We need to look very clearly at the emissions that are going out into our air and ending up in our food chain. I think we need to look at that first from the national level, and eventually from a global level. I do agree, from conversations I've had with some of our European colleagues, that pollution control systems on incinerators in Europe seem to be moving forward with a little bit more rapidity than they are here. But I would also say that they are being even more stringent in their application of regulations on incinerators. They're moving much more quickly then we are in tightening up on controls of incinerators. They are moving much more quickly then we are at looking at national budgets, for instance, for dioxins. They are moving much more quickly than we are toward national policies.
So again, I don't think there's any easy solution for the problems at Bloomington. I don't believe there's an easy solution for any of the sites around the country. I do know, given my own personal involvement in at least several of those sites, that we here can talk theory, and talk about the capabilities of incineration, and say that it can achieve certain things. What I would say is, when you go out into the field and look at its application, that its practice in the field is very different from its capabilities on the blackboard or in the textbook. I think that in its application, it does not serve the public well. I do not believe that in its regulation oversight that the public is well served. Thank you.
I want to address a couple of issues. The first is the statement that has been previously made that we don't know what's coming out of incinerators. I think that it is absolutely true, in general, we don't know everything that's coming out of an incinerator. We heard in the presentations though, that from an engineering point of view, incinerators are capable of completely destroying the organics that are going into them, given the right conditions. The engineers assert that what we see coming out of the stack is reformation of compounds after the destruction of the principal compounds going in. The composition of those pollutants, or hazardous compounds that are coming out of incinerators is similar to the composition of pollutants from most other forms of combustion and other industrial processes. So it also doesn't have much relationship to the waste that's going in. So, we do have toxic materials coming out of incinerators, but they're not necessarily related to what's going in. We are getting destruction of those compounds.
The next issue is, are people who are living around incinerators exposed to very high levels of pollution. I don't think that's the case for incinerators. First, you have to realize that the background levels of pollution are very high. Things like dioxins, benzene, PCBs, and other man-made contaminants are ubiquitous in our environment. They come from many, many different sources. Dioxins come from automobiles, wood stoves, furnaces, industrial processes. In the case of metals, we have the same kind of thing, many, many different sources, and the levels we're exposed to are high. When you do theoretical calculations on the levels of pollution that people should be exposed to around incinerators, the predictions are that you will not see an increase in environmental levels of pollution. The levels would be less than the high levels of natural background of pollution. When we take monitoring measurements (there are very few monitoring measurements around incinerators), the studies that have been done, haven't monitored for many things. There's been a couple looking for mercury. They didn't see increases of mercury around the incinerator. They didn't find any difference between upwind and downwind. They didn't find any difference between background levels in different parts of the United States. We need more of those types of studies. But there isn't any hard evidence that incinerators of new designs are increasing background levels of pollution. On a national level, it has been hypothesized that incinerators are a significant contributor to environmental pollution. However, the facts contradict this. We look at the total load of dioxins, for example, from all the incinerators in the United States, and it doesn't add up to a fraction of what we think the total load of dioxin into the environment is. So even on a national level, incinerators are not a principal source of pollution. It doesn't mean that they're an insignificant source, they're just not a principal source.
We don't know the toxicological effects of all compounds, that's true. Toxicity is probably the area of most uncertainty. We have agreed that we don't necessarily know what's going into an incinerator, and we don't necessarily know the toxicological effects of what's coming out. I would agree with that. But it doesn't necessarily mean that incineration isn't a viable option. The levels that are coming out are very low, and if we put the right safeguards on it, we can guarantee that they operate in a safe manner.
Now the kinds of things that I think are needed are, first, you have to use very good control technologies to make sure that the levels that are coming out are low. My definition of low would be that we shouldn't be able to detect any of them in the environment. You shouldn't be able to see an increase in the environment of any of the pollution that is coming from an incinerator. This would decrease the objections to incineration--the fact that we don't know what's going in and the fact that we don't know the toxicological effects. The fact that we don't know everything about incinerator emissions doesn't really matter, if there's no increase in environmental levels of pollution. Another thing that is needed is, there should be extensive monitoring of the facility while it is operating, and the people should have direct access to that process, be able to watch it, be able to talk to operators, be able to get the data on a continuous basis. And besides just having environmental monitoring around incinerators to make sure that you can't see any increase in environmental levels--either air levels or soil levels or beef or milk--you need biomonitoring in humans. Blood samples should be taken to show that the levels of major pollutants are not increasing in humans. If you do that, then you've shown that there isn't an increase in exposure due to the incinerator. Those are the conditions under which I believe the operation of incinerators is possible. It's possible for them to operate under those conditions, and those are the conditions under which they should operate. If there is any increase in human exposure, they shouldn't be operating.
OK, I'm not sure where to start. Incineration is one of those technologies I described once as: "If you build it, the waste will come." And I think that it is as much an example of our misuse of technology and how we approach a number of examples of remediation. It's almost a truism, as far as I'm concerned, that yes you can incinerate some wastes, some materials, with minimal impact on the environment. What incineration has become is as much a generic technology as anything else. I actually disagree with Adel in the sense that it is best suited for a wide variety of wastes. I think incineration is functionally much like a landfill: one size fits all.
So the simple answer is yes, incineration is a viable technology for certain wastes. It is more viable the better defined, the more homogeneous the waste is. That means, as we discussed the other day, the more you make the waste non-homogeneous and less well-defined, the more you're pushing the envelope of what is possible with incineration. And I think that is a difficult thing to evaluate. I think we have to, ATSDR has to, evaluate just what that means, especially in comparison to alternatives. The more that the issue of incineration comes up, it's more than just remediation. Obviously there is the use of incineration for a wide variety of wastes outside of PCBs, we're restricted to PCBs here; that is obviously an issue. How we evaluate the choice of technology is a critical issue that is beyond Bloomington or any other specific site.
Incineration has been the rather lavish recipient of funding for many years, more than any other alternative. As a result, therefore, everyone says it's viable, it's already here, because we funded it for 15, 20 years to the exclusion of many other alternatives. The application of technology to waste, whether it's Superfund sites or industry-generated waste, is still a discipline in its infancy. To think that incineration is the be all, end all, for waste management with a small "w" and a small "m," I think is a mistake. I think that we need to evaluate incineration in the context of other alternatives.
I have, obviously, problems with some of the chronic effects, chronic impacts, long-term impacts of incineration that we can't really evaluate very well at this point. I think the choice of a technology which is continuous throughput raises a number of questions, if you will, both toxicological and engineering questions. If we are going to evaluate other technologies, we are going to have to evaluate them in terms of the risk, the ability to control residuals and emissions, which is actually very difficult with incineration. Incineration and evaluating risk is, I'll agree with Pat, far more of an art. There's also an art to toxicology. Other people have described risk assessments in various ways. There's the Ruckelhaus quote. There's Dave Ozonoff, who described risk assessment as "Shoot an arrow into the wall and paint your target around it." Either way, there's a great deal of subjectivity to how you do the assessments, and what judgments you make. It's one tool, and we have to recognize what the limitations are.
We have to look at the loading of persistent and bioaccumulative compounds in the environment, and what that means. It's not just an individual facility, as Adel has said, you have to look at the multiplicity of facilities.
So, as far as ATSDR is concerned, there are a number of things I said before, but I think what they have to evaluate is the ability to control technologies, and know what the field is, in terms of evaluating technology. They need to evaluate just what the impact of the existing sites are, any existing site, as well as the impact of digging it up and doing something with it.
One of the things about technology that I've learned over the past 15 years is that how well you control it, the human operation, the actual operation oversight of a facility is of critical importance. That means that it's not just that you can design it; it's a question of whether you can operate it consistently. That means better monitoring, as Curtis said, actually on site, citizen oversight, and a number of ways to actually increase the control over what's happening. Thank you.
Being last, I think there's not much left to say. I'll probably repeat a lot of thoughts that everybody has already expressed here. I'm one of those who does believe that incineration is a viable technology. I think that quite often it is probably the environmentally best option for waste disposal in a variety of circumstances. I think, when it is used, it ought to be compared to alternatives, in each individual case that you're looking at, to make sure that it is true, that it is the environmentally best option to select. It should be applied in that way. As Bob said, it probably has been studied more than just about any other waste disposal option around. I suspect we know more about combustion and operation of incinerators than we know about combustion and operation of industrial boilers. I also suspect that sometimes because we know so much about the way they can be operated and designed today, that if you did a risk analysis, you would find more risk from a coal-fired industrial boiler than you do from a typical hazardous waste incinerator. Because we've studied incineration so much, it seems to actually lead to more questions. So it's almost a Catch 22. Questions do still keep coming up, and I think it's legitimate to look at them and try to answer them. I'd like to say that this panel discussion, over the last couple of days, is a pretty good representation of the types of questions and issues that are around. I think the discussions here have been very good in giving an overview of the incineration-related issues that are there, or at least the questions that people are asking, and we should try and give the best answer we can for them. The only area I'd really highlight, that we need to look at closely, is one that Bill said earlier, which is fugitive emissions at facilities. I think the fugitive emissions from storage, and from handling of wastes at an incineration facility should be given as much attention as what's coming out of the stack. I don't think that has always been done in the past; I'm not sure that's being done now actually. My last comment is, (believing that we've studied incineration extensively)--in the past, there have been a lot of studies which were searches, if you would. They were good studies at the time, where we were looking for information to try and learn more, and we did learn more by doing that. I think we've gotten to the point where there's diminishing returns of doing any large-scale, fairly open, objective studies of hazardous waste incineration. I think what we ought to focus on now is asking specific questions that we still have and doing further work that is designed explicitly to answer those particular questions. We will make better progress, and get a lot more out of the money spent on research or studies, if we go at it that way, than if we just put money in to doing further general studies in this area.
As Rapporteur, I have listened very closely over the last 2 days to what's come out of this meeting. And although we were not given the charge to try to come to consensus on different issues, and indeed we haven't come to a consensus on a number of things, I think there were some recurring points that I tried to gather. In fact I put a little list together before we had this little summary, and I found that a number of the items were mentioned in the summary, but I think that there were a number of recurrent issues or points that came out that all of us, I sense, would look for, to kind of enhance our comfort level and understanding of incineration. I'd like to just briefly go over those within my couple of minutes. Just to touch on them.
For example, I heard over and over again, I think, that it would be useful to have information about what happens to the environment surrounding the incinerator--real world information, doing the biomonitoring, doing the environmental monitoring. Maybe we can really answer some of these questions if we can look at the increase that we find by measuring these in the environment. We want to have some confidence that the incinerator is going to be operated the way it's supposed to be operated after the testing is done. So, I think a number of people mentioned that there may be some better, stronger oversight that's needed. Perhaps, these telemetry systems, sending a signal either to regulators, or maybe both the regulators and an informed community representative. Perhaps even going to the extent of having a perimeter monitoring board where people could go and look at the operating parameters themselves. And if they're trained to look at it, they'll know what to look for. It's something that I heard several times. Another thing I think I've sensed here is that since we've been talking about a mixed matrix of waste, that is, PCB-contaminated soil, sludge, and municipal solid waste (which is a fairly new mix as far as incineration goes) that it may be a very valuable thing to try to do some sort of pilot test or identify an incinerator like ones that would be proposed for this application, and actually do some sort of testing to try to find out how they perform with this kind of a mix. This is somewhat based on the physical characteristics, and what I heard from Don is, that we have a physical mix that heretofore has really not been tried, and so we ought to try to gather some information on the front end.
The other thing that might be useful, that I heard mentioned, was doing not just a trial burn for regulatory satisfaction, but also doing some burns with actual waste mixes, and not the contrived, blended mix that would be done only for a trial burn. And doing the same kinds of sampling to see if the results from that kind of testing would be comparable to those with the trial burns. The last couple of points that I've heard mentioned are the importance of quality control throughout the operation--all the way from the monitoring systems, making sure that they are calibrated and inspected fully, all the way to the feed materials going into the incinerator, to make sure what the incinerator sees is what it's supposed to see when it goes in--that there aren't surprises once the incinerator is up and running. Finally, I think there was some interest expressed in expanding our knowledge of some of the chemicals that may be emitted from the incinerator itself; and this could be somewhat targeted by some of our health scientists to help us know what to look for in addition to the things that are typically targeted during trial burns. Also, we may want to expand the metal database over the typical ones that we look for, or maybe there are some other organic volatiles, semi-volatiles, or whatever, that may be identified that we should also be looking for in addition to the target compounds typically looked for. So I think those are some of the issues I heard recur, that I think in the future, if they're addressed, may help enhance our level of confidence in the work that we're doing.
My view is the following. I'm a person who is not frightened by what I don't know. I think I tend to focus on what I do know, and I believe I know a lot about incineration, and I believe that it allows me to make informed decisions regarding the technology. I don't believe that it's a panacea. I don't believe it should be used in all cases. However, based on everything that I've seen, the people I've talked to, there is a lack, in my mind, of negative data that would indicate that this is such a terrible technology that I should just never consider it for any situation at all. So therefore, my bottom line always is that I believe incineration should remain on the table for consideration in specific situations. I believe that critical to incineration, first of all, is design of the incinerator itself. There are different types of incinerators, and the choice of the incinerator used has to be matched to the waste stream you're going to incinerate. It must also be coupled with the air pollution control equipment. I have to know, for example, whether I've got competing requirements in the incinerator to destroy organics, and at the same time to capture very volatile heavy metals. Obviously my job is a lot easier if I only have an organic-containing waste, in which case I probably will approach it in a different way. I would disagree with a couple of my colleagues on the panel, in the sense that the more simplified the waste (even though I do believe it's easier from an incineration viewpoint), the more attractive the alternative technologies. By that I mean the following: If I'm simply dealing with PCB contaminated soil, not mixed in with municipal waste, not mixed in with other materials along the way, then I believe, based on the data that I have seen, that thermal desorption and soil washing should be serious contenders for that waste stream. From my own experience in doing work in our laboratory, for PCB contaminated waste, I would think soil washing would stand a chance of being the technology of choice. However, as the waste stream becomes more complex, and I get more and more different types of waste mixed together, I find that other alternative technologies become basically not applicable. They cannot handle a complex waste stream. In those cases then, I believe that incineration offers the best possibility in dealing with very, very complex waste streams. It would not be my choice to incinerate complex waste streams, but I think incineration is the technology that will handle the widest range of waste streams.
I believe, as we have said earlier, that we underestimate the impact of fugitive emissions, but I also believe that fugitive emissions are not technology specific. And therefore, I would basically charge ATSDR, in looking at various technologies, to look at the impact of fugitive emissions on public health around the facility and how to minimize it. I'd also recognize that no matter how good technology is, that I design and build, all the benefits I might get could be easily lost by improper process monitoring equipment and operation by operators. So therefore, I strongly endorse an independent training and certification program for operators, and a very strong independent monitoring assessment to make sure equipment is monitored properly. As it's been said, I certainly believe the public should have input into the facility, and direct access to be able to know what's going on, on a real-time basis.
We've heard some negative things said about those in our group who do risk assessments. My feeling is, don't lose sight of the fact that these same individuals, using the same methodology, will be doing the risk assessments for all technologies. So if they're inadequate in their ability to do risk assessments for incineration, they will also be inadequate in doing risk assessments for other technologies as well. I'm willing to bet on them, that they are the best we have, and I will defer to their expertise to give me the best answer, within the framework of what we can provide them, as far as the health impacts of all the alternatives.
Finally, as far as ATSDR is concerned, I think we've identified some opportunities for them to participate. One is assembling the PCB incineration database, which we could all benefit from. It would help us understand what's in that database, and what's not in that database. Second of all, I think there's a role for you to bring together the combustion people and the health people to answer the questions: What should we be measuring? Are we getting the right information out of these tests that provides you the ability to do the best health risk assessment? So we can better devise our test burns, and provide some information back, so that we get maximum benefits. And finally, I totally support the suggestion here that we've got to do more perimeter, and bioaccumulation, and biomonitoring studies around the facilities. Let's pick a facility. Let's do that job well. Let's try to get some field answers, as to whether or not those of us who say the impact of these facilities is quote "non-measurable," to those who might argue the impact of these facilities is horrendous, and, therefore, we should be looking for other technologies. It's time to do the experiment, and it's time to stop the talk.
I just want to say thank you to the Panel. You all have given us a lot of good input over the last couple of days. I've really enjoyed the discussions that have gone on here. I hope everybody has felt comfortable in being frank, in putting forth what they think are the issues that ATSDR needs to consider. I think we've gotten some good suggestions from all of you, as to things that we can do, and need to do, to help get the answers to what the health effects of incineration may be. I feel like we've gotten a charge back from you all. We started off the first day with Maureen Lichtveld giving the charge to the panel, to provide input to us, and I think what we've gotten out of it is a lot of good input.
I know you all worked some pretty long days, and we went pretty late last night. I really appreciate everybody giving of your time to come to Bloomington, and agreeing to do this in a public forum so the public can sit in and hear all the issues that do exist on both sides of the coin, so they can be better informed in their own right. I want to thank you very much.
A. RECOMMENDATIONS TO ATSDR ON HEALTH ISSUES
B. RECOMMENDATIONS REGARDING DATA NEEDS
APPENDIX A
INCINERATION PANEL BIOSKETCHES
The following persons were members of the Incineration Panel. Although their participation included reviews of drafts of the Incineration Panel Report, it does not necessarily imply their endorsement of the final written report or their support for all of the conclusions derived in the Incineration Panel Report or the overall workshop report.
CHAIR: Richard S. Magee, Sc.D., P.E., DEE
Director, Northeast Hazardous Substances Research Center
New Jersey Institute of Technology
Newark, New Jersey
M.S., Mechanical Engineering
Sc.D., Mechanical Engineering
Chair of Thermal Destruction Task Group, Wastech '92. Vice-Chair, ASME Committee on
Industrial and Municipal Wastes. Member of United Nations Special Commission Advisory
Panel on Destruction of Chemical Weapons Capabilities. Member of ASME Dioxin Emission
Committee (1985-88). Diplomate-American Academy of Environmental Engineers. Author of
more than 40 publications, many on hazardous waste incineration, municipal solid waste
incineration, and dioxin emissions; contributor to 12 books.
RAPPORTEUR: Harvey W. Rogers, M.S.
Chief, Environmental Engineering Program
Center for Environmental Health
Centers for Disease Control and Prevention (CDC)
Atlanta, Georgia
M.S., Sanitary Engineering
Hazardous, medical, PCB, dioxin, and municipal waste incineration and public health experience
at CDC, ATSDR, and National Institutes of Health (NIH). On Surgeon General's Review Panel
for Disposal of Lethal Chemical Agents by the Department of the Army. Co-author of Public
Health Overview of Incineration as a Means to Destroy Hazardous Wastes. Author of 17 publications related to management and incineration of wastes.
Pat Costner, M.S.*
Research Director, U.S. Toxics Campaign
Greenpeace
Eureka Springs, Arkansas
M.S., Organic Chemistry
Research Director of the U.S. Toxics Campaign from 1988 to present. Research chemist from 1961 to 1974 in industry and academe. Postgraduate work in physical organic chemistry (2 years). Co-author of Playing with Fire: Hazardous Waste Incineration. Author of 15 publications by Greenpeace related to incineration and water pollution.
* This panelist expressly asked that the Panel's report express her disagreement with select
statements in the report.
William H. Farland, Ph.D.
Director, Office of Health & Environmental Assessment
U.S. Environmental Protection Agency
Washington, D.C.
Ph.D., Cell Biology/Biochemistry
Currently directs EPA's major risk assessment program. Former Director, Carcinogen
Assessment Group (CAG) and Acting Director, Reproductive Effects Assessment Group in
EPA's Office of Research and Development. Conducted research and assessment of mechanisms
and implications of genetic damage and its repair on the carcinogenic process and on
developmental toxicity. Experience in assessing indirect exposure of the public from incinerator
emissions. Co-author of more than 30 documents related to health effects and risk assessment.
Robert E. Ginsburg, Ph.D.
Environmental Health Consultant
Chicago, Illinois
M.A., Chemistry
Ph.D., Inorganic Chemistry
Was Midwest Research Director and chemist/toxicologist for Citizens for a Better Environment
from 1980 to 1988. Author of more than 27 publications, most regarding health and
environmental issues, risk assessment, hazardous waste incineration, and recycling. Author of
the National Toxics Campaign Fund report Beyond the Rush to Burn. Presented
environmentalist viewpoint at International Incineration Conference in Knoxville, Tennessee, in
May 1993, and at the 19th Annual RREL/EPA Hazardous Waste Research Symposium in
Cincinnati, Ohio, in April 1993. Also, speaks on industrial facility and site evaluations, pollution
prevention audits, and evaluating exposures to toxic substances. Environmental health
consultant to municipalities, community groups, labor unions, and environmental groups.
Kathryn E. Kelly, Dr.P.H.
President, Environmental Toxicology International, Inc.
Seattle, Washington
Dr.P.H., Public Health, Columbia University
M.P.H., Public Health, Columbia University
B.A., Human Biology, Stanford University
Dissertation on the health effects of hazardous waste incineration. Author of more than 30 publications, primarily related to risk assessments of stack emissions from incinerators, boilers, and industrial furnaces burning hazardous wastes, and publications on risk assessments for various other remedial alternatives at hazardous waste sites. International speaker on health effects of incinerator emissions. Co-author of All Fired Up: Burning Hazardous Waste in Cement Kilns.
Donald A. Oberacker, M.S.
Risk Reduction Engineering Laboratory
U.S. Environmental Protection Agency (EPA)
Cincinnati, Ohio
M.S., Mechanical Engineering
Senior Mechanical Engineer for 28 years at EPA research laboratory in Cincinnati. EPA research
primarily in areas of municipal, PCB, and hazardous waste processing, incineration, and disposal.
Author of 48 published reports, 27 papers, and 9 unpublished reports related to incineration.
Recommends remedial technology selection(s) for specific Superfund sites to EPA regional
offices.
Adel F. Sarofim, Sc.D.
Department of Chemical Engineering
Massachusetts Institute of Technology
Cambridge, Massachusetts
Sc.D., Chemical Engineering
Director of Center of Airborne Organics, Associate Director for Air Quality, Center for
Environmental Health Sciences. Served on EPA's Science Advisory Board and the Steering
Committee for the 3rd International Congress on Toxic Combustion By-Products. Served on
numerous national committees, including National Academy of Sciences Committee on
Chemicals in the Environment, H.E.W. Committee on the Health and Ecological Effects of
Increased Coal Utilization, and the Health Effects Working Group on Coal Technologies.
Author of numerous publications on combustion of various types of materials.
Curtis C. Travis, Ph.D.
Health Effects Director
Center for Risk Management
Oak Ridge National Laboratory
Oak Ridge, Tennessee
M.A., Biomathematics
Ph.D., Applied Mathematics
Serves on four National Academy of Sciences Panels including Biomarkers for Immunotoxicology and
Remedial Action Priorities for Hazardous Waste Sites. Serves on numerous other national and
international advisory boards and panels. Author/editor of Hazardous Waste Incineration and
Human Health, Municipal Waste Incineration Risk Assessment, and six other books. Author of
numerous publications ranging from chemical toxicity studies; modeling and data interpretation;
health and risk assessments of chemical exposure; and plant, animal, and human uptake and
metabolism of chemicals, including PCBs, benzene, and municipal and hazardous waste
incinerator emissions.
Andrew R. Trenholm, M.S.
Midwest Research Institute
Cary, North Carolina
B.S., Chemical Engineering
M.S., Chemical Engineering
Chair, Air and Waste Management Association's Hazardous Waste Thermal Treatment Division.
Responsible for many hazardous waste incineration PIC studies, stack testing, and data analysis. Experience in municipal solid waste incineration
program at EPA (1970-79). Co-author of several EPA guidance documents related to hazardous
waste incineration and author of more than 30 publications related to incineration and
incineration/industrial furnace testing.
CO-CHAIR: Betty C. Willis, M.S.
Division of Health Assessment & Consultation
Agency for Toxic Substances and Disease Registry
Atlanta, Georgia
B.S., Chemistry
M.S., Chemistry
Incineration and public health experience. Nine years incineration experience at EPA in
permitting incinerators for hazardous wastes, PCBs, and chemical warfare agents. Was EPA
Region IV Hazardous Waste Combustion Expert from 1987 to 1990. Served on several national
EPA incineration workgroups developing policies and regulations for incinerators and industrial
furnaces. Technical contributor to several EPA guidance documents related to hazardous waste
combustion sources. Co-author of Public Health Overview of Incineration as a Means to
Destroy Hazardous Wastes.
| AENTB - | Adult Environmental Neurobehavioral Test Battery |
| APCD - | Air pollution control device |
| APCE - | Air pollution control equipment |
| AWFCO - | Automatic waste feed cut off |
| AWFSO - | Automatic waste feed shut off |
| Btu/lb - | British thermal unit(s) per pound |
| CB - | Chlorobenzene(s) |
| CDD - | Chlorinated dibenzodioxin (dioxin) |
| CDF - | Chlorinated dibenzofuran (furan) |
| CEM - | Continuous emissions monitor |
| CERCLA- | Comprehensive Environmental Response, Compensation, and Liability Act |
| CFR - | Code of Federal Regulations |
| CI - | Confidence Interval |
| CO - | Carbon monoxide |
| CO2 - | Carbon dioxide |
| CP - | Chlorophenols |
| DHAC - | Division of Health Assessment and Consultation (ATSDR) |
| DHS - | Division of Health Studies (ATSDR) |
| DOT - | U.S. Department of Transportation |
| DRE - | Destruction and removal efficiency |
EPA - |
U.S. Environmental Protection Agency |
| ESP - | Electrostatic Precipitator |
| g - | gram(s) |
| g/s - | gram(s) per second |
| HC - | Hydrocarbon |
| HCl - | Hydrogen chloride |
| HHV - | High heating value |
| HW - | Hazardous waste |
| kg - | kilogram |
| MACDP - | Metropolitan Atlanta Congenital Defects Program |
| MdW - | Medical waste |
| MSW - | Municipal solid waste |
| NaOH - | Sodium hydroxide (caustic soda) |
| ng/dscm - | nanogram(s) per dry standard cubic meter |
| ng/m3 - | nanogram(s) per cubic meter |
| NIOSH - | National Institute for Occupational Safety and Health |
| NOx - | Nitrogen oxides |
| NPDES - | National Pollution Discharge Elimination System |
| NPL - | National Priorities List (EPA Superfund) |
| NRC - | National Research Council |
| NRT - | National Recovery Technologies, Inc. |
| OR - | Odds Ratio |
| OSHA - | Occupational Safety and Health Administration |
| PCB - | Polychlorinated biphenyls |
| PCC - | Primary combustion chamber |
| PCDD - | Polychlorinated dibenzodioxin (dioxin) |
| PCDF - | Polychlorinated dibenzofuran (furan) |
| PEL - | Permissible exposure limit |
| pg/m3 - | picogram(s) per cubic meter |
| PIC - | Product of incomplete combustion |
| POHC - | Principal organic hazardous constituent |
| POTW - | Publicly owned treatment works |
| ppb - | part(s) per billion |
| ppm - | part(s) per million |
| ppmv - | part(s) per million by volume |
| PVC - | Polyvinylchloride |
| RCRA - | Resource Conservation and Recovery Act |
| RDF - | Refuse derived fuel |
| SCC- | Secondary combustion chamber |
| STS - | Sewage treatment sludge |
| SVOC - | Semivolatile organic compound |
| TEF - | Toxic Equivalent Factor |
| THC - | Total hydrocarbon |
| TPD - | tons per day |
| TSCA - | Toxic Substances Control Act |
| µg/m3 - | micrograms per cubic meter |
| µg/m3/g/s- | micrograms per cubic meter (ground level concentration) per gram per second (of stack emission) |
| VOC - | Volatile organic compound |
APPENDIX C
DISCUSSION DOCUMENT
BLOOMINGTON PCB PROJECT
QUESTIONS AND ISSUES DOCUMENT FOR
INCINERATION PANEL
INTRODUCTION
This document presents topics for discussion for the expert incineration panel that the Agency for Toxic Substances and Disease Registry (ATSDR) has assembled for the Bloomington PCB Project. The focus of the panel is to provide guidance to ATSDR on how to evaluate the public health impacts of incineration of polychlorinated biphenyl (PCB) contaminated waste streams. The panel is also asked to discuss how the Agency should evaluate the potential public health implications of incinerators that are proposed for incineration of a single waste feed or a combination of waste feeds.
I. INCINERATOR OPERATIONS AND PERFORMANCE
I.A. WASTE FEEDS
QUESTIONS
I.B. COMBUSTION CONDITIONS
QUESTIONS
I.C. STACK EMISSIONS
QUESTIONS
I.D. RESIDUALS MANAGEMENT
QUESTIONS
II. FACILITY ISSUES
II.A. SITING OF INCINERATORS
QUESTIONS
II.B. TRANSPORTATION OF WASTES AND RESIDUALS
QUESTIONS
II.C. FUGITIVE EMISSIONS
QUESTIONS
II.D. SYSTEM SAFEGUARDS
QUESTIONS
II.E. TESTING AND MONITORING
QUESTIONS
II.F. MAINTAINING PERFORMANCE
QUESTIONS
II.G. TRAINING OF OPERATORS
QUESTIONS
II.H. PUBLIC INPUT
QUESTIONS
III. FACTORS AFFECTING PUBLIC HEALTH
III.A. IDENTIFICATION OF PARAMETERS CRITICAL TO ANALYSIS
QUESTIONS
III.B. AIR PATHWAY
QUESTIONS
III.C. SOIL PATHWAY
QUESTIONS
III.D. WATER PATHWAY
QUESTIONS
III.E. FOOD CHAIN PATHWAY
QUESTIONS
III.F. IDENTIFICATION OF DATA GAPS
QUESTIONS
III.G. DEALING WITH UNCERTAINTIES
QUESTIONS