Within the walls of the waste-to-energy facilities lurks three major issues that may have a large impact on the industry. World Wastes went to four industry representatives for their reactions to the new standards for ash testing and disposal; the controls placed on mercury and dioxin emissions by the Clean Air Act; and the Supreme Court's recent ruling that labeled flow control discriminatory.
WW: Will the Supreme Court's May ruling to test fly and bottom ash as potential hazardous wastes influence your practice?
O'Sullivan: The new testing regulations will bring consistency to state governments' efforts to manage ash and most likely will result in further costs for the industry.
There are products that offer possible solutions to help avoid hazardous waste disposal expenses. One such product is a chemical fixative that immobilizes leachates and binds heavy metals so they are impervious to breakdown. In a granular form, it can be mixed with concrete-like compounds to further bind the hazardous waste particles and prevent them from entering the atmosphere. Many processes are available to properly dispose of hazardous waste ash.
Szurgot: In the short term, most plant ash will still be classified as non-hazardous and will continue to be disposed in the same manner. The long-term effects will re-sult from EPA promulgating rules for testing and disposal. I'm not sure how the rules will turn out, but if they are more stringent, then the facilities will bear the costs.
Facilities normally handle ash in a combined stream. If ash streams - fly ash and bottom ash - must be separated and tested, it's possible that the results will be different and the fly ash may require additional treatment.
Burton: In the near term, many communities and facilities will be looking for appropriate testing and sampling protocol and fixative techniques. In the long run, a lot will depend on how the EPA implements the Clean Air Act.
Wood: Right now, 80 percent of waste-to-energy facilities test ash under state law, so standards for ash testing won't be new.
In the short term, I think our waste-to-energy clients will become more focused on testing. Right now they are looking for guidance from the EPA and, as a result, will have cleaner, better documentation and record keeping.
I think we're going to see more programs to remove ma-terials at the source and possibly on the tipping floor, but it will be more toward recycling. On the tipping floor, it becomes pretty difficult to identify hazardous wastes.
WW: The implementation of the Clean Air Act is expected to result in tighter controls over mercury and dioxin emissions. What are you doing now to control mercury emissions?
O'Sullivan: The surest way to cut hazardous waste ash is to monitor what materials are entering the incinerator. If you don't want mercury coming out of your stacks, stop throwing in mercury-based batteries. Source elimination can be achieved through re-cycling programs that educate the public not to throw batteries into the waste stream.
Injecting activated carbon into the flue gas stream can reduce mercury that enters the air. A binding process takes place here as well. The carbon binds with the mercury and the particles are trapped in the filters as fly ash. That fly ash can be bound once a-gain with products and go to a municipal waste landfill.
Szurgot: While batteries are the most significant source of mercury, it is found in relatively few places. There are two ways to limit this source: keep batteries out of the waste stream or keep mercury out of the batteries (which some manufacturers are starting to do).
Hospitals can be a significant source of batteries since a lot of equipment is battery operated. We have been working with a Newark, N.J., hospital to institute source separation and have seen a reduction in emissions.
Source removal accounts for about a 90 percent reduction, and scrubbers and bag houses also remove mercury, using activated carbon injection. The industry has changed in the last decade; ten years ago, there were no scrubbers, bag houses or source separation.
Other sources of mercury include volcanoes, peat bogs, volatile fires and coal plants. As far as mercury production, waste-to-energy facilities pale in comparison to coal plants.
I think that we're saddled with two albatrosses. We produce electricity and we handle waste. Waste tends to be a lot more visible in terms of need to regulate than a power station.
Burton: Host communities collect batteries and it's in our interest to employ recycling wherever we can. There has been some progress in re-moving mercury from sources.
We've done our part with product removal. There are other sources of mercury including sugar canes, hospital incinerators and coal plants.
Wood: There are a fair number of programs to eliminate mercury from the waste stream. Last year, Florida passed legislation that prohibits the disposal of mercury containing de-vices such as fluorescent lights, batteries and various pieces of electronic equipment. As of January 1996, these items cannot be disposed in landfills or incinerators.
Expect to see more emphasis on controlling generation of mercury sources. There are also retrieval methods that come with the injection of carbon into furnace flues so the carbon absorbs the mercury.
WW: How will industry standards be affected by the release of the Dio-xin Reassessment Report, which may determine tolerance levels for humans and thereby crack down on dioxin producers?
O'Sullivan: The Dioxin Reassess-ment Report was leaked to the press before being officially released. I question some of the animal testing that revealed the compound's tendency to cause sterility in seagulls. I don't have an idea of where this fits into the whole context of human health. Making the quantum leap that humans will become sterile just because seagulls became sterile seems a bit reckless to me.
Other industries are responsible for producing greater quantities of dioxin, but the scrutiny seems to be on us. In terms of volumes of pollutants, we're tiny emitters compared to utilities.
I think that we are already close to meeting those possible new standards, but we're going to have to spend money to meet them completely, for not a whole lot of return.
The best control for dioxin seems to be good combustion practices. When you maintain a high-combustion temperature with the injection of outside air into the incineration process and the temperature is high, more dioxin is consumed than re-leased.
Szurgot: With dioxin, it's not possible to get to absolute zero.
The standards defined by the Clean Air Act will have an effect and impact which will not necessarily be felt because of the Dioxin Reassess-ment Report. We believe the technological standards will be higher than those necessary to affect health.
Current technology sends airborne ash through a bag house or particulate collection device made of a heavy-duty woven cloth. Picture the device to be eight inches round and 12 feet tall with hundreds of these bags inside of a steel box. The beauty of the device is that, as the particles collect, a cake forms and be-comes part of the filter.
The thing to remember is that dio-xin can be controlled or destroyed best by combustion.
I hate to point the finger at everybody else, but I do hope the EPA i-dentifies all the sources of dioxin out there - besides us. My concern is that waste-to-energy is under a mi-croscope while greater sources exist and operate without scrutiny. Also, we need to better understand how dioxin gets from its source into the environment.
Burton: We will see new and ag-gressive standards. The toxic equivalent quotient (TEQ) totals will reflect the state of the art. I think the number we could be seeing will reflect the Dioxin Reassessment Report and won't be as low as it could be, but it will be the lowest by currently available technology.
Also, if someone is concerned with environmental quality, they need to consider other sources. It's altogether appropriate that they be considered for regulation. We've taken pride in developing state-of-the-art facilities and devices that will benefit the environment. I daresay, as with mercury, this industry will be exemplary in the control of dioxin.
We're not saying that assertive and aggressive regulations don't help us meet our goal of preserving the environment, but we want to make regulators aware of what is possible. We want to make sure the EPA is in-formed of what is achievable and what is possible under the act.
As far as the Dioxin Reassessment Report, I am anxious to see the final version. Earlier drafts were seen before the final one. I think the final report will benefit from a peer group having looked at it, and as a result it will be a balanced document based on good science.
WW: Will the Supreme Court's ruling against flow control cause any hardships for the waste-to-energy industry?
O'Sullivan: The elimination of flow control laws will have less of an im-pact on Wheelabrator waste-to-energy facilities than perhaps others a-cross the nation since we have ar- rangements based on economic price guarantees for 20 years. We've al-ways made allowances for changes in population, but we still believe that the best way to keep an industry healthy is to allow it to freely compete.
Some allowances will be made for facilities founded on flow control. The instruments needed to build these facilities were too complex so it won't be easy to unwind them.
Szurgot: Allowing the state government to control where waste goes is only one way to guarantee a plentiful waste stream. Any competent project developer will study the waste shed, determine if a project is needed and, if so, what size will assure the operation of a facility - it just makes good business sense.
In this day and age, one has to know the market before building. Long-term contracts are one possibility, but whether or not an operation will be affected by the elimination of flow control laws depends on how the plant was set up and sited in the beginning. We do not rely on flow control for business and have always had plenty of business on our own.
Burton: For the solid waste industry, getting rid of flow control laws means eliminating an important tool for managers to achieve integrated management. Some of our projects have benefited from flow control while others have not.
We work with city managers to make flow control a device for managing waste, designating recovery and obtaining financing. We don't see the absence of flow control being particularly disruptive to our business, although we have been supportive of it since local managers should use it as a tool to financing waste-to-energy facilities.
Wood: I think that without flow control laws, it will be more difficult to obtain financing for new facilities. One way for the plants that have been affected by the elimination of flow control to get around the challenge is to down-size. However, federal legislation has been proposed to grandfather in some existing flow control arrangements.
All in all, I think you will see private firms continuing to attract waste to their operations without any problem. It's the smaller, publicly-operated facilities that will ex-perience problems.