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Waste Incineration: A Dying Technology - GAIA

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Defeating the Stack Test 64<br />

Incinerator operators often base<br />

their claims of safe operation upon stack<br />

gas emissions tests that show dioxin<br />

emissions below some regulatory level.<br />

There are a number of flaws with this<br />

argument: to begin with, the assumption<br />

that any level of dioxin emissions is safe<br />

does not take into account issues of<br />

multiple sources, long-distance<br />

transport, bioaccumulation,<br />

biomagnification and the extremely<br />

high background levels of dioxins. But<br />

an even more fundamental flaw is in<br />

how dioxins are measured. The standard method for measuring dioxins in an incinerator stack<br />

is to insert a probe for a period of time from two to six hours. This probe is then removed, the<br />

sample is sent to a lab, which analyzes the quantity of dioxins present, calculates the total<br />

volume of gases sampled, adjusts for oxygen levels, and returns the result weeks later. The time<br />

lag between sampling and test results defeats one of the primary purposes of measuring<br />

emissions: to tell the operators when something is awry so that they can take action to identify<br />

and fix the problem.<br />

Dioxin emissions are not constant. Most incinerators see “spikes” of dioxin emissions<br />

during warm-up, when the furnace is just starting; during shutdowns; and during “upset<br />

conditions.” An upset condition can be anything from a batch of wet trash that causes furnace<br />

temperatures to dip to an out-of-control fire or explosion. Dioxin tests are almost never performed<br />

during these circumstances, so periods of high dioxin production are excluded from the test.<br />

When the dioxin test does happen to coincide with an upset condition that produces dioxins in<br />

excess of the legal norm, some authorities (including the US EPA) have allowed incinerator<br />

operators to scratch out that result and try again.<br />

In the U.S., dioxin tests are typically performed once or twice a year, at most, and require<br />

substantial advance preparation, because of the physical requirements to place a probe in the<br />

stack. Incinerator operators can plan their operations so that the best possible — rather than<br />

the typical — emissions levels are recorded. As the Columbus Free Press reported, one such<br />

incident occurred in March 1994, in Columbus, Ohio, where the incinerator operator (having<br />

exceeded EPA dioxin guidelines by 600 times on a previous test) took special measures to<br />

ensure a better result. The operator’s logbook recorded deliberate attempts to stockpile special,<br />

“clean” trash to ensure a good burn, and to fluff and dry this trash to avoid problems from<br />

dampness. The EPA had decided to test only one of the six “lines” (furnaces) of the incinerator,<br />

which was then retrofitted with a natural gas burner; and the test was scheduled to avoid peak<br />

dioxin production times (“soot blowing”). The Columbus Free Press reported that one EPA<br />

official wrote that these actions “might constitute a criminal conspiracy to violate federal<br />

environment laws” but the EPA chose to accept the results instead.<br />

To actually control incinerator emissions requires not just continuous, but real-time<br />

monitoring. In other words, the operating engineers must know the emissions levels as they<br />

leave the stack, not receive a report two weeks later, if they are to take action to correct any<br />

problems. This is not technically possible for dioxins, and is rarely implemented for mercury.<br />

20 <strong>Waste</strong> <strong>Incineration</strong>: A <strong>Dying</strong> <strong>Technology</strong><br />

© Vasily Mazaev/Foundation for the Realization of Ideas

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