r®Science Applications International Corporation

An Employee-Owned Company

March 13,1995

Ms. Joan ColsonU.S. Environmental Protection AgencyRisk Reduction Engineering Laboratory26 W. Martin Luther King DriveCincinnati, OH 45268

Re: EPA Contract No. 68-CO-0048, WA 0-56SAIC Project No. 01-0832-07-1130-057

Dear Ms. Colson:^

Enclosed is the draft report in response to your request for SAIC to provide technical support for the Drake Y* - 7Chemical Superfund Site, Williamsport/Lock Haven, PA. This report has not been edited ano apesjiop ' o ^ 'incorporate Don Oberacker's comments received March 9,1995. In addition, there are a number ofedlorSal ^«r * • ..comments in Mr. Santoleri's report. However, since SAIC was not present at the meeting, it is difficult for Ah*?*"us to determine the validity of these comments. Please have Don Oberacker and Roy Schrock carefully ,*£review the text and note any changes they would like us to make. SAIC will incorporate these comments > ** ^and edit the report at that time. * ° £

7-X*7"If you have any questions regarding this report, please contact me at 723-2600, ext. 2610. - "

Sincerely,

SCIENCE APPLICATIONS INTERNATIONAL CORPORATION

Jim Rawetank Assignment Manager

cc: Art Shattuck, SAIC w/o encl.' Clyde Dial, SAIC si9a:coisoNPA.itr

635 West Seventh Street, Suite 403, Cincinnati, Ohio 45203 • (513) 723-2600 • FAX: (513) 723-2605Other SAIC Offices: Albuquerque, Colorado Springs, Dayton, Fa/Is Church, Huntsvi/le, Las Vegas, Los Altos, Los Angeles, McLean, Oak Ridge, Ortando, San Diego, Seattle, Tucson

AR3Q8076

REPORT

of

REVIEW MEETING

US EPA, CORPS OF ENGINEERS, PADERat Lock Haven, PA - Planetarium at Lock Haven University

February 28, \99/£

by: Joseph J. Santoleri, P.E.Senior ConsultantRMT/FOUR NINES

Plymouth Meeting, PA 19462

1.0 INTRODUCTION

1.1 Incineration has been selected as the proper treatment method for the disposal projectinvolving contaminated soils at the former Drake Chemical site in Lock Haven, PA. U.S.Army Corps of Engineers has responsibility for oversight of the contract.

1 .2 Rust International, Inc., is the selected contractor.

1 .3 US EPA Region III has assigned Mr. Roy Schrock as the remediation project manager(RPM) for the oversite of the disposal project.

1 .4 US EPA Region III has requested assistance from EPA's ORD Risk Reduction Laboratory. (RREL) in providing assistance at a public meeting to be held in Lock Haven on February28, 1995. Questions regarding the selection of incineration as the ROD, the incineratorsystem design, air pollution control system, expected emissions from the stack, and theeffect on surrounding community farmlands are major topics for discussions.

1.5 RREL contacted Science Applications International Corporation (SAIC) to provide anincineration expert to be available for a meeting in the Lock Haven area for an opendiscussion related to the incinerator design selected for the Lock Haven site. The expertmust also be able to describe the system graphically and relate the conditions occurringin the combustion and the APC zones to minimize impact of emissions to the localcommunity .AMajor concern-of dioxin emissions must b

C'-*.6 SAIC subpontracted RMT/Four Nines to provide the services of Joseph J. Santoleri. HewouldcSsneeded for two conference calls in preparation for the meeting, preparation ofmaterials for presentation at the meeting, attendance and support two sessions on Tuesdayafternoon 3:30-6:30 and Tuesday evening 7:30-9:00. A final report covering his overallview of the meetings would be prepared and sent to SAIC. _<\ . _ L

3R308077

1.7 After two conference phone sessions, the meeting was scheduled for Tuesday, February28, 1995, 3:30 P.M. in the Planetarium of Lock Haven University, Lock Haven, PA.

2.0 TELECONFERENCE - February 17, 1995

2.1 ParticipantsDon Oberacher USEPA.ORD, CincinnatiJoan Mattox USEPA,ORD, CincinnatiKurt Whitford SAIC, CincinnatiRoy Schrock USEPA, Reg.III, RPMJoseph Santoleri RMT/Four Nines

2.2 Discussion covered the time and materials necessary to prepare the posters listed inRMT/Four Nines proposal dated 02/15/95, Task 3. RMT/Four Nines planned to prepareposters showing entire incinerator process system including individual posters showing ingreater detail the rotary kiln, cyclone, secondary combustion chamber, quench, baghouse,induced draft fan, scrubber, and stack. Overheads would also be available showingmaterials handling at the site including front end loaders, grate screen, conveyors, weighbelt, and hopper into the kiln. At this time it was not known whether overheads couldbe used.

The location of the meeting was established at the Planetarium of Lock Haven University,Fairview Street, Lock Haven, PA. An afternoon open session would be held from 3:30PM to 6:30 PM. EPA personnel and consultants would be available to provide answersto citizens' questions. Session would be informal. Roy Schrock plans to meet with PeterKostmayer on Thursday, Feb. 23 to discuss the evening meeting with the citizens. Afollowup conference call would be held on Fri., Feb. 24, to discuss final plans for themeeting on the evening of Feb. 28.

Dr. Paul Connett, an associate professor of Chemistry at St. Lawrence University inCanton, New York made a presentation to the citizen's committee on Jan. 28, 1995. Dr.Connett, a well known opponent of incineration, has made similar presentations across theUSA. Questions that have been posed to Roy Schrock are a direct result of informationsupplied by Dr. Connett. Comments made by Connett are included in the flyers handedout by AIR, a local citizens group, at the 2/28 meeting. — &

Roy Schrock indicated the main items to be ready to discuss at the meeting^va^)the EPADioxin Reassessment of Sept. 1994 and, the impact of incinerator emissions on localproduce regarding the ability of farmers to continue selling to markets. He felt that theorganization opposing the remediation by incineration numbered 40 members withapproximately 20 very vocal and excitable individuals. They wish to know 'of riskassessments conducted at other superfund sites. Dr. Dorothy kntor's name wasmentioned as .having performed this at the WTI site. She would bfe contacted for thisinformation. Roy asked that Santoleri provide an explanation of the effect of temperaturein the APC system - an overhead or poster would be prepared. /

AR308078

3.0 TELECONFERENCE - February 24, 1995DRAFT

3.1 Prior to this teleconference, Kurt Whitford had telephoned J. Santoleri to question thenumber of hours needed to perform the /individual tasks for the project. This was inpreparation for the 2/24 teleconference. L f > j. ^ >x* «••.£</ Zc-

Participants in this teleconference were the same as on 2/17, except for Joan Maddox. JimRawe of SAIC also participated. The following will be at the meeting on 2/28 in LockHaven. The Region III administrator - Peter Kostmayer, Division Director - WilliamParley, Roy Smith - EPA toxicologist, an EPA hydrogeologist, an EPA communityrelations person and a cost recovery person. Informal meetings are still scheduled for 3:30to 6:30 and formal open meeting at 7:30 to 9 PM. Dioxin will be a major issue. Theyhave concerns about the levels of dioxins that will be emitted to offsite locationscompared to the existing concentration levels of hazardous materials at the site.

The citizens have requested an analysis be conducted of existing dioxin levels on localproduce prior to start of the project.

Santoleri covered the posters that he planned to have ready for the Tuesday 2/28meetings. They were as described in the telecon of 2/17. Two new posters are beingprepared and modifications made to seven posters covering individual pieces ofequipment. The new posters were of the Rust incinerator-APC system and the graphshowing the relationship with dioxins vs. temperature from temperatures of 200F to1 800°F. The impact is to show that at the APC operating temperature of < 400F, minimalreformation of dioxins occur. Copies of all posters in 8 1/2" x 11" hard copies would bemade. Roy Schrock requested that 50 copies be available for pickup at the meeting.

All EPA personnel and consultants will meet at the Days Inn in Lock Haven at 3 PM on2/28/95.

4.0 MEETINGS at LOCK HAVEN, PA., February 28, 1995

4.1 Afternoon Meeting - 3:30 PM to 6 PM

EPA personnel met at the DAYS Inn at 3 PM and left soon after for thePlanetarium at Lock Haven University.^Auditorium was set up with necessarytables, posters, and literature for distribution. The citizens' group AIR had also setup their tables and posters at the entrance to the building. Copies of the literaturethat was being distributedQs)enclosed in the appendix of this report.

Several groups of citizens approached us at the auditorium requesting adescription of the incinerator process, individual components, conditions withineach device such as temperature, pressure, etc. One individual expressed concernabout the secondary combustion chamber vent cap. The drawing shows anextension as you will note on the attached copy. This is often referred to as theTRY (Thermal Relief Vent). He was upset that it was specifically labeled. Iexplained that it is an emergency vent for protection of the downstream APCsystem in the event of failure of quench water flows or the loss of power to the

DRAFTI.D. fan. Either condition would cause overheating at the baghouse resulting intotal destruction of this device as well as the i.d. fan, wet scrubber, and stack. Thelast three items are made of fiber-reinforced-plastic (FRP) which will notwithstand temperatures above 200 F. The baghouse is limited to 550F. A fireresulting from failure of water or power would be far more dangerous to theenvironment and the public health than opening the TRV. Typical systemsdesigned with redundancy of water systems to the quench and backup power tothe i.d. fan have had less than two to three openings per year. When theseopenings do occur, the TRV is open for approximately five minutes.

I was immediately informed that the TRV at the Vertac site had opened 500 timesin 300 days. I had no information to refute this statement. AIR has direct contactwith Sharon Golgan, an activist in Jacksonville, AR. AIR had photographs in thelobby showing closeups of the Vertac incinerator. I am familiar with some of theproblems reported by AIR. RMT/Four Nines had reviewed the operating problemsfor the incinerator owner - VSC (Vertac Site Contractors) and had maderecommendations for modifications which would have eliminated most of theiroperating problems. Most of these were not implemented resulting in theproblems presently being reported. The basic components at Vertac are verysimilar to the Rust system. The physical sizes of the equipment and maintenanceare very important in predicting the ability of the components to operate withoutfailures. The Rust unit is designed similar to smaller units that have been operatedover the past six years. I pointed out to the citizens with these concerns that theyshould also have made available to them, the operating experience of welldesigned and operated units that have performed efficiently at sites without thehorror stories that have been presented to them by the activist's network.

The handouts provided by AIR have statements made by EPA representatives andcontractors that destroy any confidence that can be engendered with these citizens.The handouts also create unnecessary fears by the way they are worded. Suchterms as "toxic salts" and "barrels of contaminated ash" are used. Most of thisdata can be refuted. They have only been presented one side of the picture.

Many of the group were interested in the fact that the APC system comprises alarge proportion of the total equipment. I pointed out that the burning process isstraightforward at the operating temperatures of the two combustion zones. Thehazardous compounds in the soil at the Drake Chemical site will be easilyremoved at these operating conditions. There also was interest in the fact that thesystem was designed to prevent the reformation of dioxin in the APC system dueto the rapid quench from 1800 F to 400 F. The graph of temperature vs. dioxinreformation was very useful in explaining this phenomenon. This resulted in noquestions being raised during the evening meeting on dioxin reformation. Mr.Schrock's advice on having this graph available was well worth the effort.

The group that attended the afternoon session were the key people askingquestions during the evening session.

AR3Q8Q80

A Question was raised about incinerating systems located near farmland and theimpacts. Santoleri indicated that he is familiar with two large commercialincinerators located in farm districts - Rollins Environmental Services of NewJersey in Logan Township, NJ and Laidlaw Environmental Services in Corunna,Ontario, Canada. On site facilities are usually in a chemical processing plant.PPG runs a 65 MM BTU/hr RCRA rotary kiln circle incinerator in Ohio whichis surrounded by farmland. The same questions came up during the permitapplication for the USPCI facility in Allenwood, Union County, PA. -approximately 40 miles from Lock Haven. In fact, members of the Organization^^,United for Ecology (OUE) were in the audience. A farm bureau cooperativemeeting was held in Lewisburg, PA. to discuss similar questions with the farmerswho had concern. The Pennsylvania State University_CoIlega,of Agriculture hadpresented a proposal to the PADER to review literature on the potential effectsof hazardous waste incinerators to agriculture and forestry ecosystems. This wasturned down by PADER and suggestion made that permit applicant fund theresearch. _-—•

A survey was conducted on farms in the US and Puerto Rico by a firm inWashington State in 1991. The results were reported in a paper by MichaelPoulson at the AWMA conference in Vancouver, B.C. during the week of June17, 1991. A 53% response resulted that indicated the location of the hazardouswaste facilities in proximity has not caused real or perceived adverse effects toagriculture.

These answers did not satisfy the citizens as will be noted in questions raisedduring the evening meeting.

A A I/ i" 4 *'A,

ATTENDEES

5.0 EVENING MEETING AT LOCK HAVEN 7:30. - 12:30A, r-

PANEL MEMBERSPeter Kostmayejx-/* J USEPA, Regional Director, Reg.IIIDon Oberachir j A' USEPA, ORD CincinnatiRoy SchrocJL -- USEPA, Region III, RPM

:' pwayneT' inters USEPA, Wash.,DC, Director, Dioxin Policy ProjectRx>y Smith USEPA, Wash.,DC Toxicologist ,Joseph Santoleri RMT/Four Nines, Inc.Consultant klu^Mick Harrison.Esq Greenlaw, Wash.DC, Director yU-5.1 Peter Kostmayer was introduced at 7:30 to the audience by the EPA public relations

person. Mr. Kostmayer introduced the panel members. Mr. Harrison was added to thepanel after one of the citizens objected to Santoleri (non USEPA employee) as a panelmember. They were not invited to provide a member so there was an objection to anoutsider-on the panel. Mr. Kostmayer agreed to their having representation and Mr.Harrison volunteered. Mr. Harrison has represented Greenpeace and other environmentalgroups opposed to incineration. He was the plaintiffs attorney in two hearings on theVertac site. Santoleri was cross examined by Mr. Harrison during both hearings. The

AR30808I

defendants were VSC contractors, USEPA and Arkansas DEHC. Mr. Harrison's presenceallowed the citizens to have his input to rebut every answer provided by the panelmembers. His overall responses were equal to or longer than those from all of EPA andconsultants combined. The major questions asked are listed below.

5.2 Incinerator System Description including monitors, safeties and automatic waste feedcutoffs. Santoleri was asked to provide the overall description. This was done with theposters that were mounted across the front of the auditorium. The system poster was usedto indicate the soil entry point to the system, the ash discharge, the combustion zones, thequench system and the APC system including fan and stack. A more detailed descriptionof the operation of the individual units was made including^the, combustion productsdischarged from each device. The posters included the expected composition of thesegases. Locations for temperature monitors and how they are used to control fuel firingrates was described. The importance of thejhree Ts in the SCC was also pointed out indestroying all organic compounds minimizing CO, Hydrocarbons or PICs(includingDioxins), and formation of acid gases (HC1 and C12). The need for ash removal as wellas acid gas removal was the reason for the APC system. The I.D. fan provides the motiveforce to insure gas flow into and through the system without fugitive emissions. The finalwet scrubber using caustic serves as a final polishing scrubber for the acid gases prior toexhaust to atmosphere. A description of what conditions were needed to reform dioxinswas presented. This requires a precursor (organic compound), free chlorine, soot or ashand a temperature level of 500-600F. Peak reformation occurs at 572 F (300C). Systemscontaining equipment such as boilers, economizers, electrostatic precipitators, etc. whichprovide locations for the dust to be maintained at these temperature levels for sufficienttime periods will result in higher dioxin levels exiting the system than that leaving thecombustion zone. The system design by Rust will not allow this to occur. This wasdescribed using the equipment posters with the temperatures designated at each exitlocation and the graph of dioxin vs. temperature.

Mr. Harrison pointed out that I did not cover metals in my discussion and there would beconcern for mercury emissions at the APC temperatures. The baghouse is the mostefficient device for trapping metals from incineration systems. Mercury is a problem onlywhen the waste materials fed to the incinerator contain mercury such as MSW plantshandling batteries.

The question was again raised regarding the TRV and the data regarding Vertacincinerator bypassing through TRV. This has been discussed above and still requiresJollowup regarding actual occurrences at the Vertac site. Rust system should be reviewedto point out the design differences that would prevent the same problems. Redundantpumps for quench water flow, water flow meter with alarm, generator for power failure,etc. A rsyiew_of the operation, ofihe R.UST design at Prentiss, Mississippi, and BogCreek, NJ would be helpful in showing the citizens that this system cannot be comparedto the Vertac unit.

5.3 Trial Burn - How dangerous is it? Citizens requested that a risk assessment be conductedfor the trial burn alone.

AR308082

5.4 Major concern by a number of citizens was the impact on their livelihood as farmers. Tli£following food markets - Weis^and Furman have indicated that they m»uld nofplircliiaso Jmeats or produce raised in the vicinity of an incinerator. The s^rroui\dingarea is anagricultural community. M wt citizens raise their own foodrNBHEjtown and operate farms.They request that these farms be tested before and after the trial burn. Surveys conductedin agricultural areas as described in afternoon session would be helpful.

5.5 Y1* Winters'pointed out that the background level of dioxin is already high. The impact ofemissions is primarily on the leaves and foliage of plants. Minimal uptake through therootsj90% ormtake is through the food chain and 10% through inhalation. Buildup is

^ vTlhrough the fatty tissues of animals, $«rti«3atly cattle. Trrfs- vttfalsi occnr-rri"tmmansjf fatty foods are eaten as a regular diet. fui«- *u*r~o

5.6 Distance to elementary school and community center - one mile. This was a majorconcern. Reports of the two major releases at ThermalKem, Rock Hill,SC were broughtup. A recent incident reported included uncontrolled burning of 1800 drums in storage at.the site. Other problems were fugitive emissions during waste handling. Their concernsrelated to emissions from the excavation of the soil. No one from the EPA hadinformation regarding the ThermalKem incident.

5.7 Rust is owned by Waste Management (WMX). AIR flyers had reports of major violations ?7by WMX. They do not trust this organization. (Note: Rust was recently merged into OHM ** •'Materials, a large environmental remediation firm).

5.8 The Ventura report was cited. I am not familiar with this report and can not comment.

5.9 Oversight of the contractor. EPA explained that the Corps of Engineers has oversightresponsibility 24 hours per day. EPA would also provide oversight. The Vertac site wasagain referenced by Harrison. EPA contracted the oversight to URS consultants. OSHAviolations by VSC was not reported by URS. They lacked trust in the followup based oncomments reported by others from the Vertac site.

5.10 Alternate Technologies. This was discussed at length. The citizens feel that EPA shouldhave revisited the ROD established in 1988. This discussion was started by the citizensbut followed up by Mr. Harrison. Bio-remediation was their main technology choice.Harrison pushed for a combination(two to three technologies) that would satisfy therequirements. No one had answers to the feasibility. Roy Schrock pointed out that thistechnology was looked at in the 1985-1988 period. The levels of contaminants were ashigh as 1500 ppm in some zones at the site. The safe level was 2 ppb. The onlytechnology capable of remediating to this level was incineration. iTestsjygre conductedSOheEPA IRF to prove that it could be_att i°fdj Mr. Kostmayer requested that thecitizens apply tor a Technical Assistance Grant (TAG) to hire their own experts todetermine if another technology could be applied. He agreed to release a $100,000 grantafter application is approved.

AR308083

5.11 DIOXIN - Risk Assessments

A great deal of discussion followed lead by Mr. Winters, the-EPA dioxin expert and RoySmith, EPA toxicology expert regarding risk assessment procedures and the effect ofcombined toxic compounds on this assessment procedure. Over 600 chemicals have beenanalyzed for toxicity levels. 2,3,7,8 - TCDD is most toxic. The next most toxic compoundhas a toxicity 200 times less than TCDD. Epidemiological studies have been conductedaround incinerators. The current body content of dioxin is known. The added impact ofmultipathways to the most exposed individual from an incinerator will not be measurable.

5.12 Inversions - The conditions in Lock Haven lend themselves to two to three inversions perweek. Concerns were raised that this was not considered when the ROD using incinerationwas established. They feel that this should be part of the meteorological data studies thatare conducted and request that this be done before a trial burn is approved. Roy Schrockcovered the MET data collection that has been conducted at the site.

5.13 Work Schedule - Concerns related to timing of excavation, approval and running of thetrial bum while they conduct studies with TAG. At present no excavation is planned untilthe sheet piling is put into place. Rust has commenced bringing equipment on site.Excavation for equipment foundations is planned in the next two months. Trial Burn isscheduled for late fall-early winter. Mr. Kostmayer indicated that the risk assessment forthe trial burn will be conducted. If this proves unsatisfactory, the trial bum will bedelayed until necessary changes are made. If the trial burn is run and the system fails toJSggt requirements, no furtherburning will be conducted until necessary improvements orequipment changes'are maS£rfhj$ questioned whether incinerators were forced todiscontinue operation due to a faHure to meet trial burn conditions. Santoleri indicated thatmany incinerator operators elected to shut down due to failures during mini-burns as wellas trial burns. The costs to modify did not justify continuing the operation. This was truewith the older existing units that were in interim status. Today, designs are nowconsidered "state of the art" and the costs involved in designing and building to meet theregulations are extremely high. As a result very few systems installed today fail.

5.14 Mr. Kostmayer informed the audience that this would be first of several open meetingsbetween the EPA and concerned citizens. The interest generated by the question - answersession continued until 12:30 A.M. March 1. Approximately 75%-80% of the audienceremained till that hour. Group discussions continued after the meeting was officiallyclosed. The citizens feel that there are critical questions that still are unanswered. Theywould prefer that incineration not be used due to their fears of emissions. The riskassessment based on expected stack emission is critical to their acceptance of thistreatment method. EPA must continue to be firm and point out that incineration is theproper method and the system design has sufficient safeties built in to protect the healthand environemt of the local community.

ch 9, 1995

_Joseph J/ Santoleri, P.E.

/' Senior Consu /nt - RMT/Four Nines

AR30808U

APPENDIX APosters/Handouts by RMT/Four Nines

Covering Incineration Systemat Drake Chemical Site

AR308085

I ") — -^\f

1 \ V / 1 *\ SfiSffiSSf't' •« ' • ' 5ifs

ffi.

AR308086

ROTARY KILN

NITROGEN N2OXYGEN o2 CYCLONEWATER H20 SEPARATOR

CARBON DIOXIDE CO2CARBON MONOXIDE COHYDROCARBONS (CH)n

HYDROGEN CHLORIDE HCICHLORINE CI2

ASH

t—— FUFL WASTE OR

SOLIDS NATURAL GAS

FEEDSCREW

ASH

AR308087

CYCLONE SEPARATOR

TOSECONDARYCOMBUSTIONCHAMBER

CARBON DIOXIDE CO2CARBON MONOXIDE COHYDROCARBONS (CH)n

HYDROGEN CHLORIDE HCIROTARY , _ _ _ _ _ _ _ _ ' CHLORINE Cl,KILN J-——" ASH

NITROGENOXYGENWATER

CARBON DIOXIDECARBON MONOXIDEHYDROCARBONS •

HYDROGEN CHLORIDE HQCHLORINE ci2

ASH

ASH

AR308088

SECONDARY COMBUSTION CHAMBER

TOQUENCHER

N2OXYGEN O2WATER Hp

CARBON DIOXIDE CO2HYDROGEN CHLORIDE HCI

CHLORINE a 2ASH

NITROGENOXYGENWATER

CARBON DIOXIDECARBON MONOXIDEHYDROCARBONS.

HYDROGEN CHLORIDECHLORINE

ASH

FROMCYCLONE

SEPARATOR

BURNERFUELWASTE ORNATURAL GAS

ASH

AR308089

QUENCHER

WATER H2o

FROMSCRUBBERWATER H20

f*- A 1 ICTV"* kt«^NLJCAUSTIC NaOHSALT NaCI

f

>

FROMSECONDARYCOMBUSTIONCHAMBER w-rHrril1800 °FJ i

wajc

1 1 1 4 M M M i l"""Mill!

k'l 4 t kM » 1 M t t

M » t

NITROGEN N2OXYGEN O2WATER H20

CARBON DIOXIDE CO2HYDROGEN CHLORIDE HQ

CHLORINE CI2ASH

ASH ASH

TOBAGHOUSE

NITROGEN N2OXYGEN O2WATER Hp

CARBON DIOXDE CO2HYDROGEN CHLORIDE HCI

CHLORINE Q2SOLIDS CaC12SOLIDS Ca(OH)2-SOLD3 NaCISOLIDS NaOH

AR308090

BAGHOUSENITROGEN N2OXYGEN 02WATER H20

CARBON DIOXIDE CO2HYDROGEN CHLORIDE

CHLORINE

FROMQUENCHER

NTTROGENOXYGENWATER

CARBON DKDXDEHYDROGEN CHLORIDE HCI

CHLORINE CI2SOLOS NaOHSOLIDS NaaASH

V V

390>=rr'

TOID. FAN

SOUDS NaOHSOUDS NadASH

AR3D80S

WET SCRUBBER

WATERCAUSTIC

NtTROGENOXYGENWATER

CARBON DIOXIDE

NITROGENFROM OXYGEN

BAGHOUSE WATERCARBON DIOXIDE

HYDROGEN CHLORIDE HCI

TOQUENCHER

WATER Hp CAUSTIC NaOH-SALT NaCI

FAN

AR308092

STACK

FROMSCRUBBER

t180 'F

180'FNITROGEN N2 JOXYGEN O}WATER - Hp

CARBON DIOXIDE. CO2

AR308093

THERMAL BEHAVIOR OF DIOXINS/FURANSIN FLY ASH

10000 -r

onnn-L. CONCEMTRATIOM NB/B AT APC9000 -f TEMPERATURES

8000-•

TOTAL PCDD/PCDF

7000 - -

I-O 6000 -•

titu." 3 ceQOP-

5°o°"rCO

2000••

1000 - -

o3 f \ \rt t \ \ji

4000--d

3000- •

200 300 400 500 600 700 800 900 1000 1700 1800 1900

STACK TEMP.

AR308091* ..

COMBUSTION PRODUCTS OF PRODUCTS OFPROCESS COMPLETE INCOMPLETE

COMBUSTION COMBUSTIONH H H H

AIR H-C-C-C-C-H* H H H H ^ N.TROCEN N2

~; GASOLINE — ™ °20" c' oTMVHoxToE «x' ^^^ WATtR H2o >^ BENZENESPARK OLEFINS * v* . CARBON DIOXIDE C02

PARAFFINSM HEPTANEISO OCTANENAPHTHALENE

HEAT

COMBUSTION PRODUCTS OF PRODUCTS OFPROCESS COMPLETE INCOMPLETE

COMBUSTION COMBUSTIONASH

^ »: . H'THOGEH OX,OH NO,CELLULOSE ^ WATER H o - SOOT

WOOD ——— CA«OH O DE 4 -^ ^ OHOX-OE CO

HEAT ) \ ^ poTASHASH

HEAT - .

AR308095

COMBUSTION PRODUCTS OF PRODUCTS OFPROCESS COMPLETE INCOMPLETE

ci COMBUSTION COMBUSTION

AIR cf C C I NITROGEN OXIDE NOXO2 & N2 CI ^ NITROGEN N2 ^ CARBON TET.

" **N. - * OXYGEN 02 *""* BENZENEHEXACHLOROBENZENE WATER H2o-»- CARBON MONOXIDE co

^^^ CARBON DIOXIDE C02 ^ CHLORINE CLjHEAT ( ) ^*^ HYDROGEN CHLORIDE HCf * HYDROCARBONS (CH),

DIOXIN

HEAT

COMBUSTION PRODUCTS OF PRODUCTS OFPROCESS COMPLETE INCOMPLETE

n rf COMBUSTION COMBUSTIONc c /\c<2.Cx c«

er - J*AIR NITROGEN OXIDE NO-2 ^ NITROGEN M2 CARBON TET.^*^ OXYGEN 02 BENZENE2,3,7,8-DIOXIN WATER H2o— CARBQN MWQXIDE co^ * **. CARBON DIOXIDE CO2N ^ CHLORINE CU

HEAT (TCDD) ^- HYDROGEN CHLORIDE HC. HYDROCARBONS <<£,n

HEAT

AR308096

WHAT IS 99.99% DESTRUCTION EFFICIENCY?

WASTE STREAM IN

Assume 40,00 one pound waste balls are fed intoincinerator per hour

10,000 balls of chemical wastes

10,000 balls of water

20,000 balls - sand, clay, salt and otherunburnable materials

AFTER INCINERATION

Stack Exit 3 balls of dust

1 ball of chemical wastes

carbon dioxide

water vapor

nitrogen

oxygen

Ash discharge from kiln, SCC and APC

20,000 balls

AR308097

DIOXINS FORM WHEN A BURNING PROCESS

• OPERATES AT LOW TEMPERATURES (BELOW 1500T)

• CARBON MONOXIDE STACK EMISSIONS AREABOVE 100 PARTS PER MILLION

• BURNS WASTES CONTAINING CHLORINE

• PRODUCES ASH IN EXHAUST GASES

DIOXINS FORM IF CHLORINE AND ORGANICS

COMBINE AND REACT ON A SOOT PARTICLEAND ARE HELD AT TEMPERATURE OF 570TAND HIGHER IN AIR POLLUTION CONTROL SYSTEM

AR308098

WHERE HAVE DIOXINS BEEN FOUND.

EXHAUST MANIFOLDS OF DIESEL TRUCKS

CHARCOAL BURNERS

CIGARETTE RESIDUESi

TRASH TO STEAM PLANTS OPERATING WITHPOOR COMBUSTION CONTROL AND USINGHIGH TEMPERATURE ELECTROSTATIC'"pRECIPITATION|

STREET DUST IN WASHINGTON AND ST. LOUIS

AR308099

WHY TODAY'S HAZARDOUS WASTE INCINERATORSDO NOT PRODUCE DIOXINS

• PROPERLY DESIGNED

• PROPERLY OPERATED

• TESTED BY PA DER & U.S.E.P.A.

. • PERMITTED AS A RCRA INCINERATOR

• MONITORING CARBON MONOXIDE EMISSION ANDTEMPERATURE PROVIDES INSURANCE THATDIOXINS ARE NOT BEING FORMED

• OPERATE AT TEMPERATURES OF 1800T +

• UTILIZE TEMPERATURETURBULENCE (MIXING)TIMEOXYGEN (EXCESS AIR)

TO EFFECT HIGH COMBUSTION EFFICIENCIESGREATER THAN 99.9%

• COMBUSTION CONDITIONS CAUSE ALL CHLORINETO BE CONVERTED TO HYDROGEN CHLORIDE -NO PRODUCTS OF INCOMPLETE COMBUSTION »'WHICH CREATE DIOXINS

• AIR POLLUTION CONTROL SYSTEM COOLSGASES-RAPIDLY TO TEMPERATURES OF450T OR LESS

• BAG COLLECTORS TRAP DUST PARTICLESWITH MAXIMUM COLLECTION EFFICIENCY

AR3081QO

DIOXIN EMISSIONS

MASS BURN FACILITIES

• LOS ANGELES, CA - SD/FF - 0.066 ng/Nm3 TEF

• STOCKHOLM, SWEDEN - DS/FF - 0.142 ng/m3 TEF

• NORTH ANDOVER, MA - ESP - 10.377 ng/m3 TEF

• ST. PETERSBURG, FL - ESP - 2.131 ng/m3 TEF

HAZARDOUS WASTE INCINERATORS

• COMMERCIAL - TEXAS - ABS/IWS - .098 ng/m3 TEF

• CHEMICAL PLANT - MICHIGAN - VS/IWS/ABS- .0552 ng/m3 TEF

EUROPEAN COMMON MARKET STDS. - 0.1 ng/m3TEF

AR30810 11-129

APPENDIX B

Public Information by US EPARelated to Remediation ofDrake Chemical Site

AR308I02

THE REMEDIATION PROCESS DRAKE CHEMICAL SITE

^ What are the next steps in the remediation process?Source control response: Treating on-site soils and sludges, the source ofgroundwater contamination at Drake

Ground water remediation: Ensuring contaminants do not impact Bald EagleCreek

What does source control response involve?Excavation of soils and sludges

Thermal Treatment of soils and sludges in a mobile incinerator to removeorganics such as beta-nap thalamine

Stabilization of soils and sludges to control metals from leaching into thegroundwater

Backfilling of soils and sludges which meet treatment standards

happens during thermal treatment/incineration?Contaminated soils and sludges are heated in a rotary kiln to 1000°F and in asecondary unit to 1800° F. This destroys the organic compounds by convertingthem to carbon dioxide and water. The combustion air stream is treated in abaghouse to remove small particles. Then, a scrubber removes acid that isgenerated during incineration as organic compounds are destroyed.

• How are soils and sludges stabilized?Cement or other similar materials are mixed into contaminated soils to trapharmful metals. This prevents the metals from moving through the soil andentering the groundwater.

will groundwater treatment involve?Several shallow wells will be installed and pumped to draw groundwater intothe area. The groundwater will be treated in a water treatment facility and thendischarged into the Bald Eagle Creek or the local publicly owned treatment works(POTW). This will ensure that the site contaminants do not adversely impactthe creek.

AR308I03

IMPLEMENTING THE REMEDY DRAKE CHEMICAL SITE

^ What are the next steps before incineration begins?RUST is the contractor in charge of incineration at the Drake site. Beforebeginning incineration operations RUST must complete the following steps:

Obtain an equivalency permit: RUST, the incinerator contractor, must obtain apermit from the Pennsylvania Department of Environmental Resources(PADER) to operate the incinerator. The permit will be based on the trial burnplan RUST has already completed. The plan has been reviewed and approved byregulatory agencies including EPA, PADER, and the Army Corps of Engineers, aswell as their engineering consulting firm, Montgomery Watson.

Readiness testing: Clean soil from another location will be burned prior to thetrial burn to ensure the incinerator is operational.

Conduct a trial burn: The incinerator's efficiency will be tested using soil fromthe site. Data from the trial burn will determine when incineration will begin.

The contractor is required to operate the incinerator by the terms of theequivalency plan which is available for review at the public repository.

+ How is a trial burn conducted?Trial burns will ensure that the incinerator can meet EPA's performancerequirements. During a trial burn, a known quantity of specific compounds isintroduced into the waste feed and incinerated with the soil. This practice,known as spiking, provides a means of measuring the removal efficiency of theincinerator. The known quantity of specific compounds introduced to theincinerator is compared to measured quantities of the same compounds leavingthe incinerator stack. The contractor is required to meet removal efficienciesspecified in the contract and trial burn plan. Additional information can befound in the trial burn plan which is available at the public repository.

AR30810U

PUBLIC PARTICIPATION DRAKE CHEMICAL SITE

citizens have any say in what is done to clean up Superfund sites?EPA seeks to involve the public throughout the Superfund process. Superfundlaw requires EPA to consider the views of the public prior to remedy selection.EPA must provide the public with an assessment of the health andenvironmental problems associated with the site and an evaluation of possibleapproaches for solving these problems. In addition, a period of public comment,including a public meeting, must be provided to obtain citizen comments andconcerns regarding remedial options. The community's concerns must beaddressed, and a written response provided in the "Record of Decision" for allmajor issues submitted.

EPA encourages community involvement in the design and construction ofSuperfund remedies, as well. This is why many meetings regarding thedevelopment of design plans are being conducted at Drake. Numerousperformance requirements may be of interest to the community such as: testing,reporting and record keeping requirements, and monitoring and oversightrequirements. EPA transcribes the Drake meetings; the transcripts are placed inthe public file.

+How can citizens change the remedy after a Record of Decision has been signed?After a Record of Decision is signed, EPA will reevaluate remedies and providefor public comment when:

[ • the selected remedy is found to be ineffective;

• major site differences (e.g. type or volume of waste) areencountered; and/or

I •• major cost differences occur.Ij\ + Where can I find more information about EPA activities at Drake?{ EPA has established a number of site repositories that are open to the public.: These repositories contain copies of legal documents and studies, including thej feasibility study, that-pertain to the Drake site. Community members may| , review the documents at the following site repository locations in Lock Haven,; Pennsylvania:I

Lock Haven City Hall Ross Public Library Drake Chemical20 East Church Street 232 West Main Street Water Street

: (717)893-5910 (717)748-3321 (717)893-4000

AR308105

THE INCINERATION CHOICE DRAKE CHEMICAL SITE

^ Will municipal or medical waste be burned in the incinerator at the Drake site?No. Only the contaminated soils presently at the site will be treated in theincinerator.

+ Since the contamination at Drake does not present an imminent threat, shouldEPA take the time to evaluate alternative remedies?Because of stabilization measures taken by EPA between 1982 and 1988, the sitedoes not pose an immediate threat. However, none of these actions havereduced site contamination. Contaminated groundwater continues to migratefrom the site.

Clean-up options for the contaminated soil and sludges have already beenevaluated carefully as part of the July 1984 feasibility study. Based on siteconditions, EPA believes the most suitable remedy was chosen. The decision touse thermal destruction was made with the involvement of the public and localofficials.

s incineration a proven technology in regard to the health and safety of thecommunity?EPA considers incineration a proven technology due to the accumulation ofoperational experience. Incineration has been chosen at over 50 Superfund sitesnationwide. Several sites are currently using incinerators. Air monitoring datareviews show no adverse air impacts to the surrounding communities.

• How efficient is the incinerator that will be used at Drake?The Drake incinerator should operate at nearly 100 percent complete combustionefficiency. Complete combustion produces only carbon dioxide and water vaporfrom the destruction of hydrocarbons. After initial burning in a primarychamber, gases are reburned in a second chamber. Practically no organiccontaminants remain in_the exhaust from the secondary chamber, regardless ofwhether they originated in the waste or resulted from products of incompletecombustion. The combustion exhaust is further treated by a series of air cleaningdevices before being released to the environment.

AR3081Q6

PRODUCTS OF INCOMPLETE COMBUSTION DRAKE CHEMICAL SITE

+ What are PICs?PICs are Products of Incomplete Combustion. PICs form when elements presentin material being burned are not burned completely. The atoms of unburnedelements combine to form PICs.

+ Do PICs pose a risk to the community?The occurrence of PICs is difficult to predict and, therefore, difficult to regulate.To address concerns, EPA researched information during trial burns athazardous waste incinerators throughout the United States and at incineratorsused strictly for research. Testing was done under normal and "upset" operatingconditions. Findings indicated that incinerators meeting stack emissionrequirements, particularly the carbon monoxide (CO) limit of 100 parts permillion by volume, produce PIC emissions at low concentrations. „

Also, to ensure that complete and safe incineration takes place, the Superfundhazardous waste incinerators must pass a battery of rigorous tests before beingauthorized to operate. While in operation they are subject to testing andcontinuous monitoring.

AR308I07

i-

i

I

DlOXIN DRAKE CHEMICAL SITE

• What are the dioxin risks associated with incineration at Superfund sites?Dioxin is a probable carcinogen primarily released to the environment throughcombustion. Once in the environment, dioxin becomes incorporated into thefood chain. The major route of human exposure is from eating animal fat.

At Superfund sites, dioxin may be emitted during incineration due to dioxinwaste not being completely destroyed or because of incomplete combustion ofnon-dioxin wastes that may form dioxin as a product of incomplete combustion.

• How •will dioxin emissions be monitored at Drake?The release of dioxin will be carefully monitored during the trial burn. The riskassessment following the trial burn will involve a careful analysis of the risksfrom inhalation of emissions as well as from deposits of emissions onto the soil.In addition, continuous monitoring will be conducted during the actualincineration period. Incineration will commence only after successful

. completion of the trial burn.

&R3081

Reassessment of Dioxin - External Review Drafts • Contents

The following information is provided to assist you in locating information contained in the twoexternal review drafts for dioxin.

Health Assessment Document for2,3,7,8-TetrachIorodibenzo-p-dioxin (TCDD)

and Related Compounds(EPA/600/BP-92/001a, OOlb, OOlc)

Volume I of III (EPA/600/BP-92/001a):

Chapter 1. Disposition and Pharmacokinctics

Chapter 2. Mechanisms of Toxic Actions

Chapter 3. Acute, Subchronic, and Chronic Toxicity

Chapter 4. Immunotoxic Effects

Chapter 5. Reproductive and Developmental Toxicity

Chapter 6. Carcinogenicity of TCDD in Animals

Volume II of III (EPA/600/BP-92/001b):

Chapter 7. Epidemiology/Human Data

Chapter 8. Dose-Response Relationships

Volume III of III (EPA/600/BP-92/001c):

Chapter 9. Risk Characterization (Note: This third volume of the 3-volume setintegrates health and exposure information on dioxin and relatedcompounds; approx. 100 pages.)

Estimating Exposure to Dioxin-Like Compounds(EPA/600/6-88/005Ca, OOSCb, OOSCc)

Volume I of III (EPA/600/6-88/005Ca): Executive Summary (Note: This first volume of the3-volume set summarizes the exposure information ondioxin and related compounds; approx. 100 pages.)

Volume II of HI (EPA/600/6-88/005Cb): Properties, Sources, Occurrence, and BackgroundExposure

Volume III of III (EPA/600/6-88/005Cc): Site-Specific Assessment Procedures

AR308I09

DRAKE CHEMICAL SITE

• what is the greatest risk associated with Drake?The greatest risk associated with the Drake site is from a color dye compoundcalled beta-napthalamine (BNAP). BNAP is a known carcinogen. The site haslayers of purple and red sludge that contain BNAP in high concentrations andsignificant concentrations of BNAP have already leached into the groundwater.

is BNAP harmful?BNAP is known to cause bladder cancer. BNAP was used in the production ofdyes by Drake Chemical. In 1962 the Commonwealth of Pennsylvania made itillegal to produce this compound.

• How will the BNAP be removed?Incineration will assure the removal of all the BNAP and other organic

* compounds and will allow the site to be opened for unlimited access and1 ^ unrestricted use.

" '

AR308I 10

MONITORING INCINERATION DRAKE CHEMICAL SITE

• To what standards will the Drake incinerator be held?The incinerator must comply with CERCLA and all Applicable or Relevant andAppropriate Requirements (ARARs), such as state and local regulations. Theincinerator must meet an emission rate that is eight times more stringent thancommercial incinerator regulations. In addition, the Pennsylvania Departmentof Environmental Regulation (PADER) has mandated that the incinerator meetbest available technology standards for air pollution control devices. The specificstandards established for the operation of this incinerator unit are specified inthe permit.

• How will the incinerator's compliance with permit standards be monitored?Pre-operating Tests: A trial bum will be conducted to test the incinerator'sefficiency for the compounds found at the site. The results of the trial burn willshow the specific types and amounts of compounds, including dioxins, emittedduring the incineration process.

Operations Monitoring: Incinerator operations are expected to take one year.During this period, monitoring instruments in the control room will recordmeasurements continuously.. Operational parameters are expected to be reportedin the control room in the on-site trailer and at the remote monitoring station.

These operational parameters are as follows:

waste feed ratekiln face vacuumkiln gas temperaturesecondary combustion chamber temperaturescrubber pHscrubber liquid flowratestack gas velocitystack gas carbon monoxide concentrationstack gas oxygen concentrationstack gas carbon dioxide concentrationstack gas nitrogen oxide concentration.

Off-site monitoring: EPA plans to have an off-site monitor in a central locationin the community. This will allow residents to verify the operating conditionsof the incinerator at all times.

I f l R 3 0 8 1 ! l

AIR is a local citizens' group that was organized in July, 1994 to protest the EPA'sdecision to remediate the Drake site here in Lock Haven with incineration. Thegroup has met regularly since its inception, holding weekly meetings on. Thursdaynights (7 PM at the Lock Haven University PUB), working actively to educate thecommunity about the dangers of incineration. The groups' arguments are based entwo claims: one, that incineration as it is practiced in this country is dangerous, andtwo, that other forms of less invasive, and less expensive, remediation exist at thistime and should be considered for this site. The group argues that:

*the track record of Superfund incinerators indicates a clear failure to meet thesafe emission standards EPA has set; no incinerator that operates now, or that hasoperated in the past, has succeeded in meeting these standards;

*the track record of WMX, the parent company of Rust, Inc. (the contractorbuilding and operating the Drake incinerator), indicates a clear and on-goingfailure to meet safe emission standards; the company's typical modus operand!is to violate the standards and then simply pay the requisite fines;

*based on EPA's own recent findings about the dangerous effects of exposureto even low-level, background amounts of dioxin, and based on the fact thatchlorine (dioxin-producing) compounds are present at the Drake site, remedia-tion by incineration is a dangerous and out-moded practice, unacceptable notonly for the country but also for Lock Haven;

"because Lock Haven suffers from a phenomenon called atmospheric thermalinversions, whereby pollutants are commonly held for long periods close to theground, and because Lock Haven and nearby residents already suffer, in above-average numbers, from a variety of ailments, ranging from upper-respiratoryproblems to cancer, the decision to subject residents to an additional sourceof dangerous pollutants is completely unacceptable;

*and because other, less invasive, forms of remediation are currently beingutilized at Superfund sites across the country, AIR is asking EPA, in light ofthese, findings, to re-open its Record of Decision — in other words, tore-examine its original decision to utilize incineration to clean up Drake.

AR308I 12

=Elcctronic Edition3RACHEL'S HAZARDOUS WASTE NEWS #299

—August 19,1992—Environmental Research Foundation

P.O. Box 5036, Annapolis, MD 21403, Fax (410) 263-8944; Internet: crfifigc.apc.org

THE SAN DIEGO REPORTThe District Attorney of San Diego County. California, Edwin L. Miller, Jr., has issued a 260-page background report on

Waste Management, Inc. (WMI). the nation's largest waste hauler. The San Diego Report, as it has become known, draws thefollowing conclusions, which we quote verbatim:

• WASTE MANAGEMENT, INC.'S METHODS OF DOING BUSINESS AND HISTORY OF CIVIL AND CRIMINALVIOLATIONS HAS [sic] ESTABLISHED A PREDICTABLE PATTERN WHICH HAS BEEN FAIRLY CONSISTENT OVER ASIGNIFICANT NUMBER OF YEARS.

• WE [the San Diego DA and his investigative staff] HAVE REVIEWED RECENT PRACTICES AND PROBLEMS ANDOUR CONCERNS HAVE NOT DIMINISHED. THE COMPANY'S RECENT BUSINESS PRACTICES AND VIOLATIONS DONOT APPEAR TO BE DIFFERENT FROM THE PAST.

• ...[T]HE COMPANY'S HISTORY REQUIRES EXTREME CAUTION BY THE SAN DIEGO COUNTY BOARD OFSUPERVISORS OR ANY OTHER GOVERNMENTAL ENTITY CONTEMPLATING ANY CONTRACTUAL OR BUSINESSRELATIONSHIP WITH WASTE MANAGEMENT.

• ...[I]T IS CLEAR THAT WASTE MANAGEMENT ENGAGES IN PRACTICES DESIGNED TO GAIN UNDUEINFLUENCE OVER GOVERNMENT OFFICIALS.

• THESE PRACTICES SUGGEST AN UNSEEMLY EFFORT BY WASTE MANAGEMENT TO MANIPULATELOCAL GOVERNMENT FOR ITS OWN BUSINESS ENDS. IF UNCHECKED, THESE PRACTICES, LtKE OTHER MOREDIRECT FORMS OF IMPROPER ATTEMPTS TO GAIN INFLUENCE, MAY HAVE A CORRUPTING IMPACT ON LOCALGOVERNMENT AND LEAD TO DECISIONS UNSUITABLE TO THE BEST INTERESTS OF THE PUBLIC.

Background of the San Diego ReportIn late 1990, Waste Management, Inc. (WMI). requested a permit to develop a large garbage dump in Gregory Canyon, S;

Diego County. The request needed approval by the County Board of Supervisors, and the Board asked the District Attorney, EdwiL. Miller, Jr., to conduct a background check on WMI. The check took over a year and resulted in a report, released in March, 199!and updated in July, 1992, containing the following chapters: Introduction; Company History; Environmental Problems; SignificantEnvironmental Cases; Organized Crime Connections; Public Corruption; Anti-trust and Unfair Business Practices.

There have been several reports on Waste Management in recent years, but until now none has openly discussed thecompany's alleged connections to organized crime. In its section entitled, Organized Crime Connections, the San Diego Reportbegins this way (we are quoting verbatim):

HISTORICALLY. THE REFUSE INDUSTRY HAS BEEN REPUTED TO BE INFILTRATED BY MEMBERS OFORGANIZED CRIME. IN MANY INSTANCES, THIS IS A WELL-DESERVED REPUTATION. THE WASTE CARTAGEBUSINESS IN CERTAIN AREAS OF THE COUNTRY, PRIMARILY THE NORTHEASTERN SEABOARD, CONTINUES TOBE KNOWN AS AN INDUSTRY WITH STRONG TIES TO TRADITIONAL ORGANIZED CRIME FAMILIES. WHEREORGANIZED CRIME IS INVOLVED IN THE HAULING INDUSTRY FT IS COMMON TO FIND A "PROPERTY RIGHTS"SYSTEM AT WORK WHEREIN CUSTOMERS ARE CONSIDERED THE "PROPERTY11 OF THE HAULING COMPANY.THUS, THERE IS NO COMPETITION AND THE COMPANIES ARE FREE TO SET HIGH SERVICE FEES WITHOUTCONCERN THAT CUSTOMERS WILL BE LOST TO COMPETITORS. WHERE ORGANIZED CRIMINALS ARE INVOLVEDIN WASTE STORAGE OR LANDFILL OPERATIONS, FEE SKIMMING AND MONEY LAUNDERING ARE COMMONLYAPPLIED SCHEMES. IN MANY INSTANCES, THE DISPOSAL COMPANIES ASSOCIATED WITH ORGANIZED CRIMEHAVE BEEN FAIRLY BLATANT IN THEIR DISREGARD FOR STATE AND FEDERAL ENVIRONMENTALREGULATIONS. HOWEVER, SUCH UNLAWFUL BUSINESS PRACTICES HAVE NOT BEEN LIMITED TO ORGANIZEDCRIME OPERATED BUSINESSES.

THE DEFINITION OF "ORGANIZED CRIME" IS GENERALLY ASSUMED TO BE MERELY ANOTHER TERM FORTHE MAFIA, OR TRADITIONAL ORGANIZED CRIME FAMILIES. HOWEVER, NOW THE TERM "ORGANIZED CRIME"MAY BE APPLIED TO MANY CRIMINAL ENTERPRISES WITH DIVERGENT INTERESTS. ANY ENTERPRISE WHICH ISORGANIZED TO CIRCUMVENT THE LAW FOR PROFIT MAY PROPERLY BE DESCRIBED AS "ORGANIZED CRIME."

IN EARLY 1960, DEAN BUNTROCK (ONE OF THE FOUNDING MEMBERS OF WASTE MANAGEMENT, INC.)[and today the chairman of the board of directors of WMI-P.M.] WAS CHARGED WITH UNFAIR BUSINESS PRACTICES\LONG WITH ELEVEN [sic] OTHER INDIVIDUALS. [The Attorney General of Wisconsin brought formal charges against Mr.Buntrock and 13 other individuals in 1962; Waste Management, Inc. was not formed until 1968.] MOST NOTEWORTHY AREALLEGATIONS THAT THOSE CHARGED HAD USED THREATS OF PHYSICAL HARM AND INTIMIDATION AGAINSTTHEIR COMPETITORS. THE ALLEGATIONS IN THE COMPLAINT DESCRIBE BEHAVIOR AND METHODS MOSTTYPICALLY ASSOCIATED WITH ORGANIZED CRIME OPERATIONS AMONG THE ELEVFN rsic] INDIVIDUALS

flR308I 13

APPENDIX C

AIR (Arrest the Incinerator Remediation)Flyers Concerning Use of Incineration

for Drake Superfund Site

concerningthe Drake Superfund Site Incinerator

Fantasy: Fact:"

EPA will monitor dioxin emissions. "The only time tests for dioxins will be doneis during the trial burn."-Roy Schrock, EPA 1/12/95

There will be no dioxins produced. "There could be dioxin coming out of thestacks."-Roy Schrock, EPA 1/12/95

The potential impact on local farmers "The potential impact to the surroundingwill be minimal. community could be physically disastrous

andeconomically dangerous...(diorin) testingcould cost $1,200 to Sl,400 per test. Eachcrop would need several tests...As a foodprocessor, we must be assured of safe food.The only way we can be confident of this isto require all fresh product to be tested"-James F. Kohl, Executive Vice President ofFurman Foods Inc., 2/6/95

Studies have been done to determine Lock "No."Haven's atmospheric suitability for -Roy Schrock, EPA, 1/12/95 when asked ifincineration. Lock Haven's prevalent weather conditions

(inversions) had been studied prior .to thedecision to incinerate at the Drake Site.

The incinerator will operate for one year. "The contract with RUST expires on9/30/98."-Roy Schrock, EPA 1/12/95

A R 3 0 8 1 1 5

Fantasy; Fact:-r.:munr-' ..IT... —— - - ^r« r« T-- ~— ~-

"The incinerator is a political issue." "The incinerator is a health issue effecting-Al Hoberman, Lock Haven City Councilman everyone from the unborn to the elderly."1/28/95 -Dr. Paul Connett, professor of chemistry,

St Lawrence University, respected authorityon incineration, 1/28/95

Incineration is the best available technology to Safer methods of remediation are availableremediate the Drake Superfund Site. including the cleanup technology being used-EPA Record of Decision on the Drake Site at the adjacent American Color and

Chemical Plant.

The incineration of the Drake Site will have a "Hazardous waste incineration does not mixpositive local economic impact. with agriculture, deer, fish, tourism or

property value."-Dr. Paul Connett, professor of chemistry,St Lawrence University, 1/28/95

Trust Waste Management Inc. and its Waste Management Inc.'s environmentaloperating subsidiary RUST International record has been and continues to be one ofInc. numerous violations of environmental laws

and regulations which have resulted inmillions of dollars in fines.

Trust EPA. The tank explosion during phase I of theDrake cleanup, Agent Orange, Love Canal(NY), Times Beach(MO), East Liverpool(OH), and Jacksonville(AR), are a fewexamples of EPA failure to protect thepublic.

For more information concerning our opposition to the planned incineration of the Drake Site

please write to:

A.I.R. (Arrest the Incinerator Remediation)P.O. Box 166

Lock Haven, PA 17745

AR308I 16

THEY MAKE THE LAWSThe following is a list "of elected officials representingthis area in Washington and Harrisburg. Addressesand telephone numbers are published as a publicservice by The Express. Please clip this and keepfor future reference, and-write or call these people tolet them know you are concerned about the issuesfacing all of us.

. WHITE HOUSEPresident Bill Clinton (D), 1600 Pennsylvania p!f;Vp|riir'|gfbn, DC20006 (202-456-1414)

U.S.Sen. Rick San forum (R), (Temporary address)..__..._ .7 _Senate Building, Washington DC 20510 (202-224-4962) orBuilding, 228 Walnut St.,''Sen. Arlen Specter (R), SSt., Harrisbura, PA17101Sen. Arlen Specter (R), SuiteSt., Harrisburg, PA 17101 (71Washington, DC 20510 (202-

U.S. HOUSECong. William F. Clinger,College, PA 16801 (81Building, Washington

Governor-Elect TomFinance Buildipg

Sen. J. Doyle Cc(814-355-0477, ^* . . .. marrlsburg, PA

SR308117

VERTAC EPA Superfund siteJacksonville, Arkansas-Chronology of Events

BACKGROUNDVertac manufactured 2,4 D and 2,4,5 T herbicides andpesticides, better known as Agent Orange, during the 1960'sfor the Department of Defense for use in Vietnam. They arenow in the fourth year of an EPA Clean-up of the site. EPAtold the residents of Jacksonville that the remediation wouldtake between ."> and 8 months.

1. Sept. 1990 - EPA tells citizens of Jacksonville -hat themobile rotary kiln incinerator a the Vertac Superfund site isthe "best designed, state-of-the-art incinerator in theentire country".

2. March 14, 1992 - The Trenholm report is released. DaveTrenholm, principal engineer for the Midwest ResearchInstitute (MRI), was hired by the EPA to conduct fieldstudies on incineration devices. In 1989 his team issued areport to the EPA on data collected from 8 EPA incineratorsacross the U.S. None of the incinerators was able thedestroy low concentrations of dioxins or chlorophenDlcontaminated wastes at the required 99.9999% DRE (DestructionRemoval Efficiency). ,With concentrations of wastescontaining less than 10,000 ppm, th<? 6-9's DRE could not beattained. Bob Hall, Chief of EPA's Combustion Branch in N.C.concurred. He expressed doubt Jacksonville could achieve therequired 6-9's.

3. April 10, 1992 - V'ertac sire manager says "puffs"(released gasses and products of incomplete combustion! can'tbe eliminated. All workers were ordered to carry respiratorswith them in case of releases. Vertac says "puffs" arerelatively common in rotary kiln incinerators.

4. Jan. 1993 - Vertac reports more waste rolls out thanrolls in. They are producing more barrels of contaminatedsalt and ash than they have burned.

5. May 14, 1993 - A release of toxic salts and gassesoccurs.

6. June 4, 1993 - Above release is confirmed. EPA denies atfirst, but the man who denied release is later removed frommanagement. Wo-rkers quit because of the discharge and thedangerous situation, and become whistle blowers.

7. June 19, 1993 - The Arkansas Peace Center and localenvironmentalists ask for a temporary restraining order basedon new and disturbing evidence showing improper incinerationof dioxin containing wastes resulting in the discharge ofsubstantial amounts of toxic chemicals into the atmosphere.

AR3081 18

8. June 22, 1993 - Carolyn Lance, employee of VSC (VertacSite Contractor) gives sworn affidavit at hearing on releasethat occurred May 14th. She reports that this was not anUnusual Happening, that in fact, releases occur quite oftenat the site. She has observed the release of salts from thesmokestack which look like a light snow and last in durationfor 10 to 15 minutes. She has also observed hazardous wasteoozing from the seals on the stacks by the barrelful!

9. June 23, 1993 - U.S. District Court Judge•StephenReasoner says there is no point in trying anymore to stopthe incinerator.

"On each occasion this court has attempted to stopthis burning activity, which activity this court firmlyfeels is both potentially hazardous, and is in violationof the EPA's own regulations, this court's orders havebeen promptly stayed or set aside. It is ludicrous tothink that yet another restraining order would enjoy adifferent fate. Given the determination of the EPA toproceed with this operation, and the prior frustration ofthis court to interfere therewith, the court finds itwould be a waste of time and resources to conduct ahearing for a temporary restraining order."

10. April 4, 1994 - The highest levels of dioxin releasedsince the start of the burning in 1992 occurred in lateDec. of 1993, and were reported today (4 months later).The levels were recorded on a monitor on the perimeterfence at the site. When asked earlier if monitors hadrecorded any unusual releases in late 1993, Chief ofEnforcement Section of the Superfund Branch of the EPAsaid "Let me assure you that our air monitors picked upnothing even close to the EPA's action level."

11. April 11, 1994 - Reports by workers at Vertac claim theincinerator is falling apart! 2,4,D is' oozing out of thekiln by the barrelful and'contaminated salts are shootingout of the smokestack. And they haven't even started toburn the most toxic substances on the site yet.

Also on this date, VSC officials reported high levels ofdioxins were released in Oct. and Nov. of '93. Theworkers were never notified. Instead they were told thewaste had such low levels of dioxin the workers had"nothing to worry about".

When worker's asked to see air monitoring reports, theywere told the reports were "not available, and if theywere, we wouldn't understand them anyway. Theyendangered us and think we are too stupid to understandwhat's going on" said an employee.

CURRENT SITUATION (2/20/95)The Vertac incinerator never worked properly after the

A R 3 0 8 I 1 9

initial trial burn. It stayed broken down and off linebecause of malfunctions or modifications nearly every otherday for more than four years. The EPA finally said enough isenough and has decided to ship the most toxic waste, 3200drums of 2,4,5 T to a commercial hazardous waste incineratorin Coffeyville, Kansas. The remaining 2,4 D waste, and thenewly created 38,000 drums of contaminated salt and ash fromthe incinerator (10,000 more barrels of toxics than theystarted with) are being stored indefinitely in drums on sitebecause thers is nowhere else to put them. EPA claims itwill eventually go to a landfill somewhere (in whosebackyard?).

All of this has gone on under the "watchful eye" of the EPA.Instead of stopping the violations, EPA made excuses for thecontractors. Incineration at Vertac has been a totalfailure, whether EP\ admits it or not. DO WE WANT THIS TOHAPPEN IN LOCK HAVEN? DO YOU TRUST THE EPA? ARE THEYLOOKING .OUT FOR OUR BEST INTERESTS?

THE EPA IS" PLAYING RUSSIAN ROULETTE WITH THE LIVES OF OURCHILDREN AND THE FUTURE OF THE HUMAN RACE. D£OX[N HAS THEPOTENTIAL TO CHANGE LIFE AS WE KNOW IT ON THIS PLANET.INCINERATION MUST BE STOPPED. THERE ARE CHEAPER AND SAFERALTERNATIVES. ASK THE "EXPERTS" AT AIR. JOIN US.

All information for this chronology was sent to us fromSharon Golgan, an activist in Jacksonville. Most of thematerial consisted of articles in local papers, and from themonthly reports issued by Vertac. We have all thedocumentation, if anyone wishes to see it, but it was toomuch to make numerous copies for everyone.

AR308I20

The E.P.A. has regrettably accepted a bid by RUST (Rust EnvironmentalInc.) for the soon-to-begin E.P.A. Incineration of the Drake SuperfundSite in Lock Haven. RUST is owned and operated by WMI(Waste ManagementInc.) a multibiiiion dollar company that has a horrible history ofincineration recklessness and human disregard. Additionally, the E. P.'has recently agreed that NO current E.P.A. Incinerator is meeting Legalair quality limits. Incineration is outdated and win soon be dead inthis country. We know that more modern and safer clean-up methods existand demand that the E.P.A. use them for this "center city" site. We

refuse to be the last guinea pigs in this failed experiment and opposeincineration as ^ means of remediation.

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SUITE *5. PENNY LANE BUILDING, LOCK HAVCM °*PHONE: (717) 748-3990: FAX: SA fl R 3 Q 8 i 2 1

Rachel's Environment & Health Weekly #428Providing news and resources for environmental justice — February 9. 1995

the world's population. Pollution of rivers, lakes, andWORLD SCIENTISTS' WARNING TO HUMANITY g™nd water further limits the supply.

Oceans: Destructive pressure on the oceans is[The U.S. Congress is presently re-thinking all U.S. severe, particularly in the coastal regions which produce

environmental laws, regulations, programs, and ideas. One most of the world's food fish. The total marine catch istheme keeps echoing throughout the debates current envi- now at or above the estimated maximum sustainableronmental laws and programs are based on "bad science" yield. Some fisheries have already shown signs ofand many of the nation's and the world's so-called environ- collapse. Rivers carrying heavy burdens of eroded soilmental problems have been exaggerated. This theme has into the seas also carry industrial, municipal, agricultur-been amplified by a handful of news reporters and writers; al, and livestock waste-some of it toxic.David Shaw of the Los Angela Times, describes a "the sky- Soil: Loss of soil productivity, which is causingis-NOT-falling movement" in U.S. journalism.1 Shaw, him. extensive land abandonment, is a widespread by-productself a member of this "movement," identifies other mem- of our curr nl ractices in agriculture and animalbers:Boyce Rensbergerof the Washington Post, lohn Slot- husbandry. Since 1945, 11 percent of the earth'ssel of ABC News, GreggEasterbrookof A/lfH*H>eal:, Mich- vegetated surface has been degraded— an area largerael Fumento (author of the book. Science Under Seige), than India and China combined-and per capita foodand Keith Scheider of the New York Times, among others. production in many parts of the world is decreasing.Shaw says these writers are "part of a backlash, a revision- Forests: Tropical rain forests, as well as tropicalist contrarian movement among a growing number of jour- and temperate dry forests, are being destroyed rapidly.nalists who believe that the media have needlessly alarmed At present rates, some critical forest types will be gonethe American public..." Shaw didn't mention perhaps the in a few years, and most of the tropical rain forest willbest-known member of the movement-Rush Limbaugh. \^ gone before the end of the next century. With them

Congressional leaders, the anti-environment "wise will Urge numbers of plant and animal species.use" movement, and a handful of influential writers and Tjving Species: The irreversible loss of species,publicists are claiming that the public has become need- whid, by 2ioo may reach one-third of all species nowlessly worried about environmental problems. The envi- Uvin is especially xrio We are losing the potentialronmental community is saying the opposite. Who should they*hoW for providing medicinal and other benefits,

T Pclrps Tfi"" "-v1 rtsrass! &» £2£±±i csassst £X£*fiS' <S £ fodtoyhea^onishing beauty of the earthftsellished a "World Scientists' Warning to Humanity/ Of Much °f this damaSe » w «*l« ™> a «=these 1680 scientists, 104 were Nobel prize winners. Be- CftntU"S: .°r P6™5* Other processes appear tolow, we print the text of their warning verbatim. Publica- Pf« additional threats. Increasing levels of gases in thetioa of the original statement was organized by the Union • atmosphere from human activities, including carbonof Concerned Scientists in Cambridge, Massachusetts.2] dioxide released from fossil-fuel burning and from

deforestation, may alter climate on a global scale.World Scientists' Warning to Humanity Predictions of global warming are still uncertain-with

Human beings and the natural world are on a col- Pr°J« ted «^ ranging from tolerable to very severe-

«.!»>•. F«.dan,«nul change »« °" C"°n! "* "" "" <">lyit w, „. » ,v d ,h« couao. our ,hc

many life : forms. Air pollution near gjound kve and -P J earth,s Current nomicaadprecTiUtwo.arealreadycausingwidespreadinjury prtctices which damage the environment, in bothto humans, forests, and crops. _ developed and underdeveloped nations, cannot beVater Resources: Heedless "Plo.uuoo i of deplet- J JJ ^ able groundwater suppbes endangers food production , A9rn».,..A i**,** ,.«-.,>

shortages in some 80 countries, containing 40 perceat of ^ anv efforts lo achieve a sustainable future

AR308122

If we are to halt the destruction of our environment, we and the global environment. The developed nationsmust accept limits to that growth. A World Bank esti- have the obligation to provide aid and support to devcl-mate indicates that world population will not stabilize at oping nations, because only the developed nations haveless than 12.4 billion, while the United Nations con- the financial resources and the technical skills for theseeludes that the eventual total could reach 14 billion, a tasks.near tripling of today's 5.4 billion. But, even at this Acting on this recognition is not altruism, butmoment, one person in five lives in absolute poverty enlightened self-interest: whether industrialized or not,without enough to eat, and one in ten suffers serious we all have but one lifeboat No nation can escapemalnutrition. from injury when global biological systems are damaged.

No more than one or a few decades remain before No nation can escape from conflicts over increasinglythe chance to avert the threats we now confront will be scarce resources. In addition, environmental and eco-lost and the prospects for humanity immeasurably dimi- nomic instabilities will cause mass migrations with incal-nished. culable consequences for developed and underdeveloped

WARNING nations alike.We the undersigned, senior members of the world's • Developing nations must realize that environmental

scientific community, hereby warn all humanity of what damage is one of the gravest threats they face, and thatlies ahead. A great change in our stewardship of the attempts to blunt it will be overwhelmed if their popu-earth and the life on it is required, if vast human misery lations go unchecked. The greatest peril is to becomeis to be avoided and our global home on this planet is trapped in spirals of environmental decline, poverty, andnot to be irretrievably mutilated. unrest, leading to social, economic, and

'WHAT WE'MUSTDO -\-f& —•vircnmental collapsw.Five inextricably linked areas must Success in this global endeavor will

be addressed simultaneously. . require a great reduction in violence and1. We must bring environmentally war. Resources now devoted to the prepa-

damaging- activities under control to re* ' ration and conduct of war—amounting tostore and protect the integrity of the over SI trillion annualty-will be badlyearth's systems we depend on. We must, for example, needed in,lhe new tasks and should be diverted to themove away from fossil fuels to more benign, inexhaust- new cbalteifees.ible energy sources to cut greenhouse-gas emissions and A new ethic is required~a new attitude towardsthe pollution of our air and water. Priority must be giv- discharging our responsibility for caring for ourselvesen to the development of energy sources matched to and for the earth. We must recognize the earth's limi-Third World needs-small scale and relatively easy to ted capacity to provide for us. We must recognize itsimplement fragility. We must no longer allow it to be ravaged.

We must halt deforestation, injury to and loss of This ethic must motivate a great movement, convincingagricultural land, and the loss of terrestrial and marine reluctant leaders and relucnant governments and reluc-plant and animal species. tant peoples themselves to effect the needed changes.

2. We must manage resources crucial to human The scientists issuing this warning hope that ourwelfare more effectively. We must give high priority to message will reach and affect people everywhere. Weefficient use of energy, water, and other materials, inclu- need the help of many.ding expansion of conservation and recycling. We require the help of the world community of

3. We must stabilize population. This will be pos- scientists-natural, social, economic, political;sible only if all nations recognize that it requires im- We require the help of the world's business andproved social and economic conditions, and the adop- industrial leaders;tion of effective, voluntary family planning. We require the helfEof the world's religious lead-

4. We must reduce and eventually eliminate pover- ers; and we require the help of the world's peoples. Wety. call on all to join us iiti is task.

5. We must ensure sexual equality, and guarantee .TnIW,.""'." .~ ,...•...., , . _, • j • • [l)D<vidSbv,1JwgSaraii:DoMarSkcpikuaE>l<nCc»nmfioaE>vinxia«I BiaEwomen control over their own reproductive decisions. svwpuMe m *<*** •«» »un«i by • .cflon u> W* &• Emi- AJ u>< pmfcwaThe developed nations are the largest polluters in •"•»• "EH***** "'"JT-' tZ£*'*£'Z?f?!'*'21' lwiJS 1L.i , , j, -r-, t_ ? t_ • mUnoiefCeMtMdSa<ra«i.:Bn(ikS4\ura.dnbndfhMM»<feitMtu 02231; pkooethe world today. They must greatly reduce their over- wxi-sssziucwttMtas. o onbk «««»(. fa p»pu«fc>m.»ra»*ikbu

consumption, if we are to reduce pressures on resources tm "°: *«•• •**•?'?** "*** ** Ujsa Far **" otdOT> *' **""** **~f * DAB •OWB; tt9*+ft UC5 fOf (MttJiS.

RaeheTs Eatuviunent &, ffeakk Weetfy, ISSN 107S-103X,(formerly Rachel's Hazardous Waste Newt) a publishedweekly by. Environmental Research Foundation (ERF);Telephone (410) 263-1584; fax: (410) 2634944; Econet:erf; Internet: erf@igc.apc.orj. Peter Montague, PLD,editor, Maria B. Pellerano, associate editor; Todd Fiedo>rowicz, circulation manager, Mary OTJrien. staff scientist;Andrea K. Feameyhough. research assistant.Subscription rates: S25 per year for individuals andcitizen groups; S45 for universities and libraries; $80 forprofessionals and government agencies; $15 for studentsand seniors with ID; S400 for businesses; in Canada andMexico, add S6.00; in iD other countries, »dd SI LOO. Allpayments in UJ5. funds drawn on U.S banks. Visa &Mastercard accepted. Rachel's Environment & HealthWeekly is not copyrighted; we encourage reprinting solong as you send us a copy. Printed on 100% recyded.

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PERMITSANNAPOLIS MD

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HR. BILL SMEDLEYROUTE 4, BOX -53AJERSEY SHORE PA 17740

,,„„,,„„„ JllllHlllllllIII

EXPIRES' #429

|(1JR308123

ARREST THE INCINERATOR REMEDIATIONSUITE #5, PENNY LANE BUILDING, LOCK HAVEN, PA 17745

PHONE: (717) 748-3990; FAX: SAME

10 Reasons why you should oppose the EPA'sDrake incineration plan.

1. Drake and American Color and Chemical (ACC) dump sites are widespread in the city.11 additional sites have no remediation plans. (L.H. Hospital, Piper, ACC, L.H. Junior LeagueField, Old L.H. Landfill etc.) The local population will not be safe from ground-ladenChemicals after the "Clean up." (Local Geologist, Dr. George Pedlow)

2. The contractor, Waste Management Incorporated (WMI or RUST), has a history ofenvironmental violations and incineration recklessness. (Greenpeace, Environmental ResearchFoundation)

3.90% of the organic waste at Drake are "unknown intermediate chemicals." (EPAAdministration Files, Drake Site Vol. HIE.)

4. Lock Haven is often under the influence of atmospheric thermal inversions which trappollution Close to the ground. (EPA Project Manager, Roy Schrock)

5. The EPA has known since 1985 that no present toxic incinerator can burn at 99.99% DRE(Destructive Removal Efficiency) as required by law. (Greenpeace, Environmental ResearchFoundation)

6. "Up to 30 additional years of ground water pumping and treating is to be done afterincineration, possibly by ACC." (A company with another local site on the NationalPriority List for Clean up.) (EPA Project Manager, Roy Schrock)

7.12.5' excavations are not deep enough to rid the site of buried chemicals, i Fluctuatingwater levels and down-gradient ACC flows will recontaminate the remediated soils.z(1. EPA Administration Files, Drake Site Vol. HIE., 2. Local Geologist, Dr. George Pedlow)

8. Heavy metals (Cadmium, Lead Etc.) will remain in the backfilled ash after incineration.(EPA Administration Files, Drake Site Vol. HIE.)

9. Excavations could expose city residents to heavily contaminated dust if WMI (RUST) failsto wet down the exposed areas correctly. (EPA Project Manager, Roy Schrock)

10. Other more modern and safer technologies exist. (Greenpeace)

What can you do?flR308!21*

/276

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

The Health Impacts of IncinerationExcerpts of Testimony

by Barry L. Johnson, Ph.D.Assistant Surgeon General, Assistant Administrator

Agency for Toxic Substances and Disease Registry, Public Health Service,U.S. Department of Health and Human Services

Before theSubcommittee on Human Resources and Intergovernmental Relations

Committee on Government Operations, United States House of RepresentativesJanuary 24, 1994

[The Subcommittee's transcript of thgJTeartn'g on Tire-Health Impacts of Incineration" is not yet available.•^k To request a cop call 202-225-254S, and ask to be put on mailing list.]

Part 1 of 2Good morning. I am Barry Johnson, Ph.D., Assistant Administrator, Agency for Toxic Substances and Disease Registry

(ATSDR). I am accompanied today by Maureen Lichtveld, M.D., Senior Biomedical Officer for Public Health Practice, ATSDWe welcome this opportunity to present testimony on the health impacts of incineration: what we know and what we dOur testimony is derived from ATSDR's responsibilities and findings under the Comprehensive Environmental Resp<Compensation, and Liability Act, as amended (CERCLA, or Superfund) and the Resource Conservation and Recovery A*(RCRA, Section 3019).

I will endeavor to respond to the eight issues listed in your letter of invitation to ATSDR. Because ATSDR is a federalpublic health agency, our responses to your issues will be given in a health context. As the Subcommittee knows, there aremany scientific, technology, and policy issues that attend incineration of wastes. Our focus will be only on the public healthissues. But as preface, I can share with you that many communities have expressed concern to ATSDR about the potentialimplications of incineration of wastes. Their concerns are usually expressed as health effects questions about their health. Asthis testimony will describe, ATSDR often finds itself unable to answer citizens' questions about associations between

yfl • . • f^m • f^ . •

incineration of wastes and public health impacts. JL He SCientlllC inlOmiailOn

on human health impacts of incinerationisn't often available because the relevantstudies haven't been conducted.

Incineration of wastes should be viewed from a public health perspective in the larger context of. generation andmanagement of wastes. Wastes become a public health concern when they are improperly managed and disposed of. Therefore,in a public health context, the most protective action is not to produce waste. Waste elimination or minimization comports withprevention or reduction of health consequences of wastes...

3 What data currently exist-on health impacts from incinerator emissions of dioxin, furans,lead, mercury, and other chemicals you think most relevant? What is the range of healtheffects and their intensity at likely emission levels?

There are very few data on the actual human health impacts of incinerator emissions on the healtl!communities near incinerators. Epidemiologic investigations have rarely been conducted, nor have studiesdisease and illness patterns been undertaken. For example, ATSDR staff conducted a recent literaturesearch of the 10 most frequently used computerized .environmental data bases. As part of the

Printed on Kenaf, a tree-free paper ————— a p O n Q I 25

search over 1,000,000 entries were identified. Approximately 72,000 of those entries dealt withincineration. Of these only one single entryscussed the conduct of a population-basediidy conducted in a community living in

*tf • • • • t* • •tlie VlCinity Ol an inCineratOr. That study of residents living nearCaldwell Systems Incinerator in North Carolina was conducted by ATSDR. [See Notes in Waste Not #277.]

In the absence of human health data, reliance is placed on using toxicity data for individual substances released into theenvironment. The effect of any toxic substance depends on factors such as duration of exposure, concentration of the substance inthe environment, biological uptake, and persons' susceptibility factors (e.g., age). All these factors have to be considered in anyestimate of impact of incinerator emissions...

Adequate information does not exist to support speculation on what, if any, human health effects might be associated withincinerator emissions. However, our experience with public health associations related to hazardous waste sites would suggestthe need to conduct two kinds of human health investigations. One kind of investigation would look at cancer, birth defect, andrespiratory disease rates in areas thought to be impacted by releases from incinerators. These studies would combine health datafrom many geographic areas. A second kind of study would be site specific. Community health surveys would help clarifywhether any unusual exposure or morbidity is occurring that might be associated with a given incinerator.

4 What data do you have or gather on additive, multiple, and synergistic impacts when there isexposure to more than one chemical, as would be the case with incinerator emissions? Doyou expect those impacts would be greater than from single chemical exposure alone?

There are few data available in the scientific literature onspecific interactions of the contaminants that may be releasedrom waste incinerators (dioxin, furans, lead, mercury);', in the

nee of specific studies using combined contaminants, and limited understanding of the mechanisms of actions for somestances, it is prudent to assume that the effects of exposure to these contaminants is additive.

5 What data exists on the sensitivity of various populations, by age, gender or ethnicbackground, to these chemicals?

Infants and children are arguably the most sensitive segment of the human population to toxic exposures. Infantsand children are at special risk because they play outdoors, they ingest or mouth foreign objects, they are smaller (greaterchemical doses per pound) than adults, they breathe more air (greater volume and breathing rate per pound) than adults, they arenutritionally challenged (because of protein-calorie requirements to support rapid physical growth) and they are undergoingdevelopmental changes that make them especially vulnerable to chemical exposures. Moreover, they have the longest lifeexpectancies, during which long-term adverse health effects may become manifest. Certain disorders may not become evidentuntil a child reaches a particular developmental stage, which may occur long after the damage was done. Some of the largestenvironmental health programs (e.g., lead, asbestos) are directed at children.

People of reproductive age. All women of reproductive age must be included in this population because themost severe effects usually occur during the very early stages of pregnancy, often before a woman knows she is pregnant. Inaddition, pregnant women, especially those with multiple pregnancies, as well as the developing fetus have increased protein-calorie requirements to support rapid physical growth.

The developing fetus is particularly sensitive to chemical exposures. Exposure to chemicals has the greatest impact onthose functions undergoing the most active development at the time of exposure. Animal studies and some human studies showthat there are critical fetal developmental stages during which chemical exposure can cause permanent and devastating effects.

There is also a small, but growing, scientific literature that implicates some toxicants as causing effects on malereproductive processes. For example, laboratory animal studies have shown that exposure to lead causes adverse reproductiveoutcomes in male rats, leading to effects on neurologic function in the offspring of the males. Similarly, PCBs in fish andwaterfowl have been reported to cause feminine features in males of these species.

CONTINUED TO WASTE NOT # 277

A STE N OT # 2 7 6. A publication of Work on Waste USA, published 43 times a year. Annual rates an: Croups& Non-Profits f SO, Students & Seniors 535; Individual f40; Consultants & For-Profits $125; Canadian $US50; Overseas $65.Editors: Ellen & Paul Connett, 82Judson Street, Canton, NY 13617. Tel: 315-379-9200. Fax: 315-379-0448.

Printed on Kenaf, a tree free paper ——————RR308V26

VERTAC EPA Superfund siteJacksonville, ArkansasChronology of Events

BACKGROUNDVertac manufactured 2,4 D and 2,4,5 T herbicides andpesticides, better known as Agent Orange, during the 1960'sfor the Department of Defense for use in Vietnam. They arenow in the fourth year of an £PA Clean-up of the site. EPAtold the residents of Jacksonville that the remediation wouldtake between n and 8 months.

1. Sept. 1990 - EPA tells citizens of Jacksonville that themobile rotary kiln incinerator a the Vertac Superfund site isrhe "best designed, state-of-the-art incinerator in theentire country".

2. March 14, 1992 - The Trenholm report is released. DaveTrenholm, principal engineer for the Midwest ResearchInstitute (MRI), was hired by the EPA to conduct fieldstudies on•incineration devices. In 1989 his team issued areport to the EPA on data collected from 8 EPA incineratorsacross the U.S. None of the incinerators was able thedestroy low concentrations of dioxins or chlorophenolcontaminated wastes at the required 99.9999% DRE (DestructionRemoval Efficiency). With concentrations of wastescontaining less than 10,000 ppm, the 6-9's DRE could not beattained. Bob Hall, Chief of EPA's Combustion Branch in N". C.concurred. He expressed doubt Jacksonville could achieve therequired 6-9's.

3. April 10, 1992 - Vertac site manager says "puffs"(released gasses and products of incomplete combustion; can'tbe eliminated. All workers were ordered to carry respiratorswith them in case of releases. Vertac says "puffs" arerelatively common in rotary kiln incinerators.

4. Jan. 1993 - Vertac reports more waste rolls out thanrolls in. They are producing more barrels of contaminatedsalt and ash than they have burned.

5. May 14, 1993 - A release of toxic salts and gassesoccurs.

6. June 4, 1993 - Above release is confirmed. EPA denies atfirst, but the man- who denied release is later removed frommanagement. Workers quit because of the discharge and thedangerous situation, and become whistle blowers.

7. June 19, 1993 - The Arkansas Peace Center and localenvironmentalists ask for a temporary restraining order basedon new and disturbing evidence showing improper incinerationof dioxin containing wastes resulting in the discharge ofsubstantial amounts of toxic chemicals into the atmosphere.

AR308J27

8. June 22, 1993 - Carolyn Lance, employee of VSC (VertacSite Contractor) gives sworn affidavit at hearing on releasethat occurred May 14th. She reports that this was not anUnusual Happening, that in fact, releases occur quite oftenat the site. She has observed the release of salts from thesmokestack which look like a light snow and last in durationfor 10 to 15 minutes. She has also observed hazardous wasteoozing from the seals on the stacks by the barrelful!

9. June 23, 1993 - U.S. District Court Judge StephenReasoner says there is no point in trying anymore to stopthe incinerator.

"On each occasion this court has attempted to stopthis burning activity, which activity this court firmlyfeels is both potentially hazardous, and is in violation-of the EPA's own regulations, this court's orders havebeen promptly stayed or set aside. It is Ludicrous tothink that yet another restraining order would enjoy a .different fate. Given the determination of the EPA toproceed with this operation, and the prior frustration ofthis court to interfere therewith, the court finds itwould be a waste of time and resources to conduct ahearing for a temporary restraining order."

10. April 4, 1994 - The highest levels of dioxin releasedsince the start of the burning in 1992 occurred in lateDec. of 1993, .and were reported today (4 months later).The levels were recorded on a monitor on the perimeterfence at the site. When asked earlier if monitors hadrecorded any unusual releases in late 1993, Chief ofEnforcement Section of the Superfund Branch of the EPAsaid "Let me assure you that our air monitors picked upnothing even close to the EPA's action level."

11. April 11, 1994 - Reports by workers at Vertac claim theincinerator is falling apart! 2,4,D is'oozing out of thekiln by the barrelful and contaminated salts are shootingout of the smokestack. And they haven't even started toburn the most toxic substances on the site yet.

Also on this .date, VSC officials reported high levels ofdioxins were released in Oct. and Nov. of '93. Theworkers were never notified. Instead they were told thewaste had such low levels of dioxin the workers had"nothing to wo.rry about".

When workers asked to see air monitoring reports, theywere told the reports were "not available, and if theywere, we wouldn't understand them anyway. Theyendangered us arid think we are too stupid to understandwhat's going on" said an employee.

CURRENT SITUATION (2/20/95) .The Vertac incinerator never workQ<^ n^nno-riv aft**? the

'AR3-0-8I28

initial trial burn. It stayed broken down and off linebecause of malfunctions or modifications nearly every otherday for more than four years. The EPA finally said enough isenough and has decided to ship the most toxic waste, 3200drums of 2,4,5 T to a commercial hazardous waste incineratorin Coffeyville, Kansas. The remaining 2,4 D waste, and thenewly created 38,000 drums of contaminated salt and ash fromthe incinerator (10,000 more barrels of toxics than theystarted with) are being stored indefinitely in drums on sitebecause there is nowhere else to put them. EPA claims itwill' eventually go to a landfill somewhere (in whosebackyard?).

All of this has gone on under the "watchful eye" of the EPA.Instead of stopping the violations, EPA made excuses for thecontractors. Incineration at Vertac has been a totalfailure, whether EPA admits it or not. DO WE WANT THIS TOHAPPEN IN LOCK HAVEN? DO YOU TRUST THE EPA? ARE THEY 'LOOKING OUT FOR OUR BEST INTERESTS?

THE EPA IS PLAYING RUSSIAN ROULETTE WITH THE LIVES OF OURCHILDREN AND THE FUTURE OF THE HUMAN RACE. DIOXLN HAS THEPOTENTIAL TO CHANGE LIFE AS WE KNOW [T ON THIS PLANET.INCINERATION MUST BE STOPPED. THERE ARE CHEAPER AND SAFERALTERNATIVES. ASK THE "EXPERTS" AT AIR. JOIN US.

All information for this chronology was sent to us fromSharon Golgan, an activist in Jacksonville. Most of themate.rj.al consisted of articles in local papers, and from themonthly reports issued by Vertac. We have all thedocumentation, if anyone wishes to see it, but it was toomuch to make numerous copies for everyone.

Request for Superfund Technical SupportRSKERL-Ada QJ RREL-Cincinnatl jsf*1 Wtv

D ERL-Athens D EMSL'LV . / I-*rte- IECAO-Cincinnati CH ERT-Edison

iupport

Date: ________Requestor: —————————Region & Division: —————Superfund Site Name & No.:

Phone? Faxf?

PI Fund Lead Q Enforcement Lead

Nature of Request

Note contaminants of concern!

Deiiverables and Due Dates

List of Attachments

Return request to? Engineering Technical Support Center(ETSC)26 V. Martin L King Dr.Cincitinsti, OH 45268 Fax (513) 569-7676

Attention: Joan Mattox' Phone (513) 569-7624

AR308

ROUTING OF SHOP DRAWINGS, EQUIPMENT DATA, MATERIAL SAMPLES, OR MANUFACTURER'S CERTIFICATESOF COMPLIANCE FOR APPROVAL

(Used to route ENG Form 4025 with items attached. Not to become a part of the Contractors's record)

1

111millHIillStSSMt

11

111Ill

2

&££:

3

$vXv

III

•:*:*:':'i

4

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ill11£Pi:•:':•:&>;m•i11inHiIIIII11:$?S; s$*B?

TO: FROM: DATE ^ fc.MONTGOMERY WATSON RUST INTERNATIONAL INC. M^B >

ONE MARSHALL STREET (CORNER OF OLD MASON STREET) 1 SO MYRTLE STREET MARCH 9 M^B :PRESIDIO SAN FRANCISCOSAN FRANCISCO, CA 94129

ATTN; RICK WILSON

LOCK HAVEN, PA 17745 ^

ATTN: TOM KELLY

The attached items listed on ENG Form 4025 are forwarded for approval action i

CONTRACT NUMBERDACW45-93-C-0200

TRANSMITTAL NUMBERS54

CONTRACTORRUST INTERNATIONAL INC. •

PROJECTTITLE AND LOCATIONDRAKE CHEMICAL SUPERFUND SITE, LOCK HAVEN, PA.

COMMENTS (Attach additional sheet, if necessary,) I

TRANSMITTAL NO. 54 IS SUBMITTAL NO. 1 000 BACKGROUND AIR QUALITY REPORT.

NO. OF INCL. TYPED NAME AND TITLE2 TO AE THOMAS JOSEPH KELLY6 TO AREA QUALITY CONTROL MANAGER

TO:

COMMENTS (Attach additional sheet, if necessary,)

FROM:

NO. OF INCL. TYPED NAME AND TITLE

TO: FROM:

COMMENTS (Attach additional sheet, if necessary,)

NO. OF INCL. TYPED NAME AND TITLE

TO: FROM:

SIGNATURE i

J \ ~-\ DATE

SIGNATURE

DATE

&

SIGNATURE

DATE

The following action codes are given to items listed on ENG Form 4025:ACTION CODES

A - APPROVED AS SUBMITTED. D - WILL BE RETURNED BY SEPARATE CORRESPONDENCE.

B - APPROVED, EXCEPT AS NOTED ON DRAWINGS. E - DISAPPROVED (SEE ATTACHED)RESUBMISSION NOT REQUIRED.

F- RECEIPT ACKNOWLEDGEDC - APPROVED, EXCEPT AS NOTED ON DRAWINGS.

REFER TO ATTACHED SHEET. RESUBMISSION REQUIRED. G - OTHER (specify)

ACTION CODES TO BE INSERTED IN COLUMN G, SECTION I, ENG FORM 4025 (Attach sheets, when required,)

ITEM NO.(Taken from ENG Form 4025)

CODE GIVEN

REMARKS

NO, OF INCL. TYPED NAME AND TITLE•

SIGNATURE

ENG FORM 4028 EDITION OF NOV66 MAYBE USED. * U.S. GP.O.: 1988-523-1081 NOV 74 AR308I3