#148b: New Estimates Of Hazardous Waste: 2 To 10 Times More Than EPA Thought.

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RACHEL'S HAZARDOUS WASTE NEWS #148
---September 26, 1989---
News and resources for environmental justice.
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Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

The American Chemical Society (ACS) has published new estimates of the total size of the U.S. hazardous waste problem; quoting unnamed industry sources, the ACS says the total is somewhere between 580 million tons and 2.9 billion tons produced each year. The current official estimate by the U.S. Environmental Protection Agency (EPA) is 290 million tons.

Furthermore, the ACS says the federal government really has no idea how much hazardous waste is created each year by U.S. industry and has NO WAY TO FIND OUT. This means, though the ACS does not say so, that U.S. manufacturing industries, including the chemical industry which reportedly produces 70% of all hazardous wastes, are out of control. They are out of control quite literally because there is with sufficient resources or knowledge to control them or even track their behavior.

In 1973 the U.S. EPA (Environmental Protection Agency) wrote its first report to Congress on hazardous waste. At that time, the EPA estimated that American industry was producing 10 million tons of hazardous waste each year. If the latest ACS estimates are correct, it means that EPA originally underestimated the problem by somewhere between a factor of 58 and a factor of 290. In other words, the EPA's original 1973 estimate really accounted for only somewhere between 0.3% of the total waste and 1.7% of the total waste.

Even today the real size of the problem remains unknown because, "If Congress wanted to move on hazardous waste, its work would be impeded by a serious lack of comprehensive recent data. Except for some chemical industry data and estimates made by industry analysts, almost no studies have attempted to quantify the extent of the hazardous waste problem or determine what actually happens to those wastes," says a staff writer in C&EN [CHEMICAL & ENGINEERING NEWS], a weekly publication of ACS.

According to ACS, somewhere between 50% and 90% of all U.S. hazardous waste is not regulated by RCRA, the Resource Conservation and Recovery Act, which is supposed to be the nation's law for tracking wastes "from cradle to grave." The wastes not covered by RCRA were officially exempted from RCRA by EPA because the agency knew it did not have the resources to oversee their management. ACS refers to these wastes as "low hazard." Hazardous wastes that have been exempted from RCRA include cement kiln dust, utility company ash and sludge), phosphate mining wastes (often radioactive), uranium mining wastes (radioactive), other mining wastes (many of which give rise to acid leachate, damaging local streams and rivers), gas and oil drilling muds, and "some chemical process wastes."

Richard Denison of Environmental Defense Fund (EDF) says there are "a number of large waste categories" that are "sort of falling through the cracks" because of the way we categorize wastes: under RCRA, wastes are hazardous or they are not, and those are the only two choices. If wastes are classified as legally "hazardous" they are regulated, and if they are "not hazardous" you can do just about anything you want with them, no matter how dangerous they may be.

An alternative would be to rank wastes according to their degree of hazard and require different levels of control for different degrees of hazard. On the face of it, this would seem to make sense. However, Joel Hirschhorn of Congress's Office of Technology Assessment (OTA), who has favored such a system in the past, now says he's not sure it could work under the present regime in Washington. "The [EPA's] meager resources devoted to enforcing the current system are not enough, and I think the whole problem would be exacerbated even more under [a degree-of-hazard ranking] proposal."

The EPA's responsibilities have increased at least fourfold since 1975. Many new laws, and amendments to existing laws, have required the agency to evaluate the toxicity of thousands of new chemicals, and to regulate them in new ways. At the same time, the agency's purchasing power in 1989 was the same as it was back in 1975. It seems obvious that under such circumstances, the EPA would not be able to do its job even if everyone in the agency were bright, well-trained and eager to nail polluters.

"These are just a few of the reasons why the grass roots environmental movement is essential to the country's well-being. The Reagan-Bush administration has sent the EPA to the locker room, and industry has the playing field all to itself, except for local environmental groups confronting them."

For the latest ACS waste estimates, see David J. Hanson, "Hazardous Waste Management: Planning to Avoid Future Problems," C&EN [CHEMICAL & ENGINEERING NEWS] July 31, 1989, pgs. 9-18; the EPA's 1973 estimates appeared in REPORT TO CONGRESS ON HAZARDOUS WASTE DISPOSAL (Washington, DC: U.S. Environmental Protection Agency, June 30, 1973). The crippling of EPA has been cataloged by William Drayton, "Environment: Environmental Protection Agency," in Mark Green and Mark Pinsky, AMERICA'S TRANSITION: BLUEPRINTS FOR THE 1990S (New York: Democracy Project [215 Park Avenue South, Room 1814, NY, NY 10003; (212) 674-8989], 1989), pgs. 212-232. See also Jonathan Lash and others, A SEASON OF SPOILS; THE REAGAN ADMINISTRATION'S ATTACK ON THE ENVIRONMENT (New York: Pantheon, 1984).

--Peter Montague, Ph.D.

Descriptor terms: acs; hazardous waste statistics; capacity assurance planning; epa budget; reagan-bush; regulation; rcra; edf; ota.

#124: Military-Industrial Stupidity.

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RACHEL'S HAZARDOUS WASTE NEWS #124
---April 11, 1989---
News and resources for environmental justice.
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Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

If you have been reading the papers in recent months, you know that the military and the federal Department of Energy (DOE) have been suddenly found out hiding millions (perhaps billions) of pounds of radioactive wastes that they hadn't told anybody about and they don't know what to do with. For forty years they've kept this little secret from Congress, from the press, and from local citizens who were breathing and drinking the stuff. It is a story of treachery unparalleled in our history.

For forty years the military (plus their civilian pals in the Department of Energy and their industrial co-conspirators like GE, Westinghouse, DuPont and Kerr-McGee) have dumped and buried millions upon millions of pounds of radioactive wastes into seepage basins, holding ponds, pits, lagoons, landfills, shafts, cribs, subsurface leaching fields, and deep injection wells. They have dumped additional millions of pounds of radioactive wastes into local creeks, streams, and rivers. They have intentionally and regularly released additional tonnages into the atmosphere. In some cases, they haven't even kept maps of where they dumped the stuff. In almost all cases, records of how much they dumped are vague, incomplete and--by their own admission--inaccurate.

All this is in addition to the estimated 1,752 toxic chemical dumps that the military has, so far, identified as their own. They're still discovering new ones each time they look. These are a story in themselves, but for another time.

Now a citizen watchdog group has begun the long, difficult job of cataloging this monstrous problem. The Radioactive Waste Campaign in New York City has released a study called DEADLY DEFENSE in which they begin to document the worst excesses of the "military-industrial complex" that President Eisenhower warned us about as he was leaving office in 1960.

Here we will not document the horrors. You must get DEADLY DEFENSE for that. In it, you will find a quiet, even-handed, understated, fact-filled compendium of intractable problems at the following military sites: Bendix Plant, Kansas City, MO; Feed Materials Center, Fernald, OH; Hanford Reservation, Richland, WA; Idaho Engineering Lab, Arco, ID; Lawrence Livermore Lab, Livermore, CA; Los Alamos National Lab, Los Alamos, NM; Mound Labs, Miamisburg, OH; Nevada Test Site, Mercury, NV; Oak Ridge Reservation, Oak Ridge, TN; Paducah Gaseous Diffusion Plant, Paducah, KY; Pantex Plant, Amarillo, TX; Pinellas Plant, Largo, FL; Portsmouth Uranium Enrichment Complex, Portsmouth, OH; Reactive Metals, Inc., Ashtabula, OH; Rocky Flats Plant, Golden, CO; Sandia Labs, Albuquerque, NM; Savannah River Plant, Aiken, SC. And all this, of course, is only a tiny part of the full story.

We will focus here on three important lessons revealed by this bleak history of stupidity, treachery and deception:

1) The government should never again get into the business of creating new industries. The government started the nuclear weapons industry; to make it appear more benign and useful, they started the "nuclear power industry" to generate electricity by splitting atoms. (Friendly Citizen Atom, a smiley-faced little fellow with a lightning bolt through his head, was going to make electricity too cheap to meter.) It is now crystal clear that the whole thing has gone bad. Both the weapons industry and the nuclear power industry have bungled their work, consistently tried to cover up their massive mistakes, and generally acted irresponsibly. Both industries are inefficient and enormously expensive, and both have covered the planet with huge reservoirs of deadly radioactivity, most of which are already leaking and all of which will continue to leak for as long as anyone can imagine into the future. These radioactive dumps will plague future generations with a pestilence of death, disease, fear and expense, time out of mind.

2) The only way to cure the problem of radioactive contamination of the planet is to stop making the stuff. There is talk in the newspapers these days of creating a new generation of nuclear power plants. Even the NEW YORK TIMES has taken to writing silly editorials about "inherently safe" nuclear power plants. Such talk is complete nonsense. Even if we could build nuclear plants simple enough to be run safely by yo-yos, plants that never melted down and never spewed glowing dust over the inhabitants of surrounding communities, those plants would still produce massive quantities of radioactive wastes that would have to be put somewhere forever. The nature of split atoms is such that they release heat (which can make steam to make electricity), but the heat is always accompanied by tremendous quantities of newly-created radioactive crud. THE MOST FUNDAMENTAL LAWS OF PHYSICS DECREE THAT THIS IS SO. This crud has to be put someplace. Once it's in that place (wherever it is), the crud will begin to disperse into the environment. Slowly but surely it will be carried into the food chains of the world, blown on the wind, transported by water, eaten by insects, fish, birds, mammals and eventually humans. The most fundamental laws of physics decree that this is so. Nature's processes, driven by the second law of thermodynamics, cannot be stopped. They are as inevitable as tomorrow's sunrise. The only possible solution to the problem of planetary contamination by radioactivity (and halogenated hydrocarbons) is to stop making the stuff. Period. Every other industrial path leads, finally, to planetary death. What Barry Commoner said about chemical contamination is equally true about radioactive contamination: pollution must be considered a terminal disease. It cannot be cured once is has been allowed to happen. It can only be PREVENTED.

3) An active citizenry is our only hope. Government and industry cannot police themselves. For forty years, we have left our most high-tech technologies in the hands of the nation's smartest scientists and engineers, who have been funded and managed by the country's most successful entrepreneurs. Now, like Rip van Winkle, we wake up to find that, between them, these technical geniuses and financial wizards have contaminated the planet and every living thing on it with radioactivity and with exotic toxic chemicals, threatening the health, well-being and peace of mind of every human alive. They have spread radioactivity and halogenated hydrocarbons EVERYWHERE. Not a square foot of the planet has been spared. These masterminds have claimed--against all common sense and contrary to the most fundamental scientific principles--that burying the stuff in holes in the ground would protect us. The holes, of course, are now leaking. Faced with their shocking record of stupidity and ruination, they now claim they can dispose of the stuff in immensely complex and expensive incinerators, or rebury it in deep salt caves, to solve the fundamental problems. It is an unmatched record of technical arrogance utterly devoid of common sense.

These military folks and their industrial co-conspirators, are clearly the sloppiest, most deceitful, most dangerous people in America. If they're active in your community, look into it. You won't like what you find, but your children will respect you and thank you.

Get: Marvin Resnikoff and others, DEADLY DEFENSE; MILITARY RADIOACTIVE LANDFILLS (NY: The Radioactive Waste Campaign, 625 Broadway, 2nd Floor, New York, NY 10012; phone (212) 473-7390. $15.00 plus postage; bulk rates available.

--Peter Montague, Ph.D.

Descriptor terms: radioactive waste; lanfilling; leaks; Bendix Plant, Kansas City, MO; Feed Materials Center, Fernald, OH; Hanford Reservation, Richland, WA; Idaho Engineering Lab, Arco, ID; Lawrence Livermore Lab, Livermore, CA; Los Alamos National Lab, Los Alamos, NM; Mound Labs, Miamisburg, OH; Nevada Test Site, Mercury, NV; Oak Ridge Reservation, Oak Ridge, TN; Paducah Gaseous Diffusion Plant, Paducah, KY; Pantex Plant, Amarillo, TX; Pinellas Plant, Largo, FL; Portsmouth Uranium Enrichment Complex, Portsmouth, OH; Reactive Metals, Inc., Ashtabula, OH; Rocky Flats Plant, Golden, CO; Sandia Labs, Albuquerque, NM; Savannah River Plant, Aiken, SC; radwaste; military; dod; doe; citizen action;

#145: Some Lessons From The Nuclear Age.

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RACHEL'S HAZARDOUS WASTE NEWS #145
---September 5, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

SOME LESSONS FROM THE NUCLEAR AGE.

Scientists no longer argue whether the "greenhouse effect" will heat up the earth's atmosphere and disrupt climate on a global scale. It now seems certain to happen, and the major remaining question is when the effects will first become visible: was the heat wave last summer an effect? Was the midwest drought? What about the wet spring this year on the east coast?

Ordinarily, sunlight streams in from outer space, strikes the surface of earth, turns into heat and is reradiated back into outer space as heat energy. The energy in the incoming sunlight equals the energy in the outgoing heat, so earth's average temperature remains constant. However, carbon dioxide and other "greenhouse gases" like methane are building up in the atmosphere, primarily because of burning fossil fuels (oil, coal, natural gas). Greenhouse gases have a peculiar property: they let sunlight pass through, but they act as a mirror to radiated heat energy, so sunlight striking the earth is radiated back but strikes the "mirror" of these gases in the atmosphere and can't escape into outer space. As a result, the heat is trapped and the average temperature of the earth is now increasing. (The glass in a greenhouse has the same effect, which is why greenhouses are warmer than the outside air, and why global warming is called the "greenhouse effect.")

The only real solution to the "greenhouse effect" is to reduce our dependence on fossil fuels. One way would be to generate electricity by some means other than burning coal, oil and natural gas. (Changing to some other fuel besides gasoline and diesel oil in cars and trucks would be another important step.)

The "greenhouse effect" is fueling a revival of nuclear power because nuclear power doesn't produce any greenhouse gases. Unfortunately, nuclear power produces other problems.

Advocates of nuclear energy are now hoping to convince the American public that the problems of nuclear power have been solved, and that a new generation of "inherently safe" reactors should be built. Respectable publications like the NEW YORK TIMES now use the phrase "inherently safe" nuclear plants as if the "inherent safety" of these new plants had been proven. It has not. The concept of an inherently safe nuclear plant exists only on paper.

Existing nuclear plants have the following problems:

1) Nuclear power plants are exceptionally difficult to operate because they are the most complex machines humans have ever invented; the nation's 88 existing nuclear reactors have only operated at 55% of capacity because of problems with turbine generators, steam generators, pumps, valves, control-rod drives and cracked pipes.

2) The design and construction of nuclear plants has been carried out by humans, with the following kinds of problems resulting:

 (a) in the Ohio Zimmer plant, the control panel could possibly catch fire because the panel lights were put too close together; (b) at San Onofre, California, the reactor was installed backwards; (d) reactor supports were 45 degrees out of line at Comanche Peak, Texas; (c) some operators at the Peach Bottom plant in Pennsylvania routinely slept at the operating console, while others played video games; (d) the wrong drawings were used in assessing the earthquake response of steel beams at the Diablo Canyon reactor in California. Humans are simply prone to errors, and the humans designing, building and operating nuclear plants are no exception.

3) The federal agency that regulates nuclear was (and is) staffed by people whom it is difficult to trust. A recent history of nuclear power portrays these individuals as blundering, fumbling bureaucrats whose arrogance is surpassed only by their ineptitude. (See Luther Carter, NUCLEAR IMPERATIVES AND PUBLIC TRUST: DEALING WITH RADIOACTIVE WASTE [Baltimore, MD: Resources for the Future, 1987.]) Even this view may be overly optimistic. The revelations of the last six months, about serious coverups at almost every nuclear weapons facility in the country, suggest that those in charge of regulating nuclear operations in the U.S. are not simply arrogant and incompetent; they also seem to be criminals.

4) There is still no way known to handle radioactive wastes safely. In 1985, commercial reactors had produced 12,450 tons of highly radioactive wastes (wastes that would radioactively cook you to a crisp if you stood next to them unshielded for just a few seconds). By the year 2000 the total will have risen to 41,500 tons.

One way to judge the hazard of any waste is to calculate how much water it would take to dilute the waste down to a concentration that meets federal drinking water standards. In the case of the 30 tons of high-level radioactive wastes produced by one year's operation of one typical (1000 megawatt) nuclear power plant, after the wastes had cooled off (through radioactive decay) for 1000 years, it would still take ten times the annual flow of the Hudson River to dilute them down to the level officially regarded as "safe". No one knows what to do with existing radioactive wastes.

5) The production of nuclear fuel requires the mining and processing of large quantities of uranium. The mining of uranium has produced an epidemic of lung cancer among two generations of miners, and it has resulted in mountain-sized piles of uranium "tailings" (radioactive sand) heaped on the desert, left free to blow around, in New Mexico, Arizona, Colorado and elsewhere.

There are two designs for "inherently safe" nuclear power plants on paper, the HTGR (high temperature gas cooled reactor), and the PIUS (process-inherent ultimate safety). Each of these designs is supposedly better than today's reactors because they would be less subject to catastrophic failure (core meltdown) leading to massive releases of radioactivity. However, both designs would still be subject to human error during design, construction, and operation. Both designs would be regulated by the incompetents and miscreants who oversee today's nuclear plants. Both designs would require mining uranium in the same amounts as today's reactors; both would produce the same amounts of radioactive wastes as today's reactors. Reactors of the new types, like today's reactors, would themselves have to be disposed of as radioactive waste when they were ready for the scrap heap--presenting a disposal problem that the nation has grappled with unsuccessfully since 1943.

Neither of the new reactor designs could be proven safe except by building a lot of them and operating them for many years (in other words, by trial and error)-the same way we learned about the flaws in today's reactors. In short, what we should learn from nuclear power is not that marginally better plant designs deserve to be termed "inherently safe," but that (a) humans have a strictly limited capacity to operate complex machines reliably; and (b) before you make a lot of hazardous materials, you'd better have in mind a safe place to put them, to keep them safely away from living things for the duration of the hazard (in this case, 100,000 years or longer). Inherently safe? Hardly. Inherently uncontrollable seems more correct.

See: Russ Manning, "The Future of Nuclear Power," ENVIRONMENT Vol. 27 (May, 1985), pgs. 12-17, 31-37. See also: UNION OF CONCERNED SCIENTISTS, THE NUCLEAR FUEL CYCLE. Revised edition. (Cambridge, MA: MIT Press, 1975).

--Peter Montague, Ph.D.

Descriptor terms: radioactive waste; nuclear power; energy; nrc; doe; greenhouse effect; global environmental problems; atmosphere; uranium;

#154: How to Achieve Pollution Control? Zero Discharge vs. 'Prove Harm'.

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RACHEL'S HAZARDOUS WASTE NEWS #154
---November 7, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================Original Source========================

What are the goals of the grass roots movement for environmental justice? Surely one goal is pollution control. How can we get there?

There are two fundamental philosophies of pollution control: total containment vs. partial abatement. We have written before about total containment (see RHWN #106); it is the principle of no dumping, or zero discharge, which says, "All peaceable people (that excludes criminals) are entitled to hold themselves and their property free from coercion, intrusion, and fraud, provided they secure the identical right for each other. This definition of human rights clearly prohibits people who own property from letting it intrude on anyone else's body or property, which includes the common air and water... It is not the obligation of other humans to prove that the dumping would be lethal or even a hazard at all. There is just no right to let your property intrude on others, and you'd better consider that before you make it or buy it." Zero discharge is allowed; anything more than zero will draw a penalty.

The alternative, which we call "prove harm abatement," is what the U.S. has been trying for the past 30 years. This philosophy allows polluters to dump into common air and water until someone can prove harm; after harm is proven, then "appropriate" controls may be required to restrict emissions to "acceptable" levels. Why doesn't this system work?

1) This system rests upon the assumption that we humans know what we are doing. It assumes that we can decide on a rational basis how much of each chemical the earth can endure. Then we are supposed to devise controls that will allow just the right amount of chemicals into the environment, and no more.

There is something ominous about these assumptions. They lack humility. Who really believes we humans know what we are doing? Who believes we understand the environment well enough to determine how much of each chemical is "safe" and how much is "unsafe." Who knew just 20 years ago that emitting CFCs [chlorofluorocarbons] into the atmosphere would destroy the planet's ozone shield and allow dangerous levels of ultraviolet light to flood the surface of the earth? Who knew that nitrogen and sulphur released from power plants in the midwest would devastate crops, forests and lakes throughout the eastern U.S., Canada and Europe by acid rain?

Even if we knew how much of a chemical we could safely release into the environment, who believes we can devise controls that will achieve the desired goal? When you eat swordfish, you are risking brain damage from mercury contamination. Mercury enters the oceans (and then the swordfish) from many sources-from coal combustion, from the manufacture of paper, from solid waste incinerators, and from mercury mining, to mention only a few sources. What level of restrictions on which industrial processes will reduce mercury emissions sufficiently to make it once again safe to eat swordfish? It is an incredibly complex question.

There are too many ways that pollutants get into the environment for society to be able to develop numerical controls on each substance produced by each human activity. There are too many to measure, too many to comprehend, too many to fix, if each is to be separately examined and subjected to a uniquely appropriate control.

2) There are thousands of ways pollutants can directly harm humans; because experiments on animals are expensive to carry out, we usually only test chemicals for gross signs of harm, such as cancer, but there are many more subtle kinds of harm we should be concerned about: reproductive disorders (stillbirths, birth defects, low birth weight), developmental disorders (reduced learning ability, for example), and sublethal effects like headaches, sinus problems, rashes, blurred vision, unsteadiness, kidney problems, and so forth. Medical science knows little or nothing about these sublethal effects of most chemicals. With 60,000 chemicals now in use and 500 to 1000 new ones coming into use each year, there are simply too many chemicals to be tested for subtle damage, so we only test for the most obvious effects (if we test at all).

The "prove harm" philosophy reduces the most obvious damage from the obvious poisons but it fails to take action against unknown ones until some new unforseen consequence becomes obvious. The "prove harm" philosophy is concerned with what are only the most visible fringes of the problem. 

3) Even when compelling scientific evidence of harm comes to light, there is still a decades-long struggle to curb pollution. Lead is an example. People have known for 2000 years that lead is a dangerous poison, yet we allowed the automobile industry to emit millions of tons of lead each year into our air. It took four decades to bring it under control. Lead in paint reveals the same problem: doctors knew for two decades that children in urban ghettoes were eating lead paint and damaging their central nervous systems before Congress acted to restrict lead in paint. Even after Congress acted, the problem continued, and continues to this day.

4) Even when you can prove harm, this is not sufficient to guarantee that a chemical will be controlled. It is now fashionable for industry and government to open up a new debate on how much harm is acceptable. Is it acceptable to kill one in 10,000 people exposed to benzene or may we only kill one in a million? As odd as it may sound in our Constitutional democracy, this is a real debate today. Under William Reilly, the EPA (U.S. Environmental Protection Agency) has selected one-in-10,000 whereas his predecessor had selected one-in-a-million.

5) Harm that is known to be occurring, but is not visible in reports of vital statistics, is labeled insignificant or inconsequential. For example, the Department of Energy estimated that the Chernobyl nuclear power plant explosion would kill 28,000 people by giving them cancer but they dismissed this as "negligible" compared to the natural cancer rate.

After the Natural Resources Defense Council (NRDC) published its estimate that the pesticide Alar on apples was causing 5,000 cancer deaths each year in the U.S., the winner of the American Chemical Society's coveted Priestley medal, George Pimintel, ridiculed NRDC's "hysteria," saying 5000 cancers is "a barely noticeable perturbation" of the nation's cancer statistics. (C&EN May 1, 1989, pg. 53.)

6) After harm is proven, and the need for restriction is accepted by government agencies, additional progress toward stricter control can be delayed by any well-funded industry that carries out additional research; each new study becomes an opportunity to open up a debate on whether to relax existing pollution controls.

7) The "prove harm" rule guarantees that we will have many victims of pollution. Until we have victims-or evidence of serious environmental disruption, like loss of the ozone shield, loss of oyster beds from sewage, loss of the striped bass population from PCBs-we do not have a compelling case for restricting emissions.

8) Under the "prove harm" philosophy, the development of controls is dependent upon risk assessments and mathematical models. Since risk assessments and mathematical models are matters of art more than they are matters of science, reliance upon these tools for setting controls is guaranteed to lead to endless debate among high-paid consultants, but little satisfactory control of chemicals. Furthermore, ordinary people are left out of the debate, which undermines democracy itself.

9) Prove harm strategies and item-by-item pollution control are subject to dispute arising out of differences in emphasis, in understanding, or even in aesthetics. When we decide it's OK to dump "some" chemicals into the environment, "some" is difficult to describe, arbitrary to establish, and always subject to question. "None" is not. That is why we should now move to a "zero discharge" philosophy of pollution control.

--Peter Montague, Ph.D.

Descriptor terms: zero discharge; risk assessment; health effects; lead paint; gasoline; chernobyl; nrdc; alar; george pimintel; global environmental problems;

#136: Fine Particles--Part 4: Harm To Humans: Solid Evidence.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #136
---July 4, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================Original Source========================

Small particles (ash, soot, smoke) in the air, even in amounts that are legal, can harm human health. This fact was emphasized dramatically by events in the Utah Valley near Provo, UT during the period April, 1985, to February, 1988, when a steel mill closed and then reopened. The steel mill was the source of 82% of all the small particles in the local atmosphere, and a researcher at Brigham Young University, Dr. C. Arden Pope, studied hospital admissions for pneumonia, pleurisy, bronchitis, and asthma with the steel mill closed and with the steel mill open. Opening of the mill coincided with a dramatic increase in hospital admissions for these respiratory ailments, especially among children.

Douglas Dockery [see RHWN #134] at the Harvard University School of Public Health called this "a landmark study," when it appeared in the AMERICAN JOURNAL OF PUBLIC HEALTH in May, 1989. In epidemiology, he explained, "you look for unique situations where there is a natural experiment going on." The Utah Valley from 1985 to 1987 provided such an experimental setting.

The Utah Valley is an especially good place to study the effects of air pollution on human health because only 5.5% of the 258,000 adults (18 and older) who reside there smoke tobacco, about one-fourth the national average; smoking is strongly discouraged by the Mormon church.

At times, pollution is very noticeable in the Valley. During winter 1985-86, in a random survey of Valley residents, 29% said they had one or more family members with health problems aggravated by air pollution.

Admissions data from three local hospitals were collected for the period April, 1985, to February, 1988. Emergency and outpatient care were not included, so this study only counted people sick enough to be admitted into the hospital.

Particles in the atmosphere were measured as PM-10 (particulate matter 10 micrometers or less in diameter), which is U.S. Environmental Protection Agency's standard measure for particles in air.

The EPA's allowable limit on PM-10 pollution is a 24-hour average of 150 micrograms of particles per cubic meter of air; higher than that violates the standard. (A microgram is a millionth of a gram and there are 28 grams in an ounce. A meter is approximately a yard.) The allowable annual average is 50 micrograms per cubic meter of air.

Dr. Pope looked at the data four ways. First he compared hospital admissions during those months when the 24-hour PM10 standard was exceeded one or more times, versus hospital admissions during months when the standard was not exceeded. During the four months when the 24-hour standard was exceeded, admissions of children (0-17 years of age) nearly tripled compared to admissions during the 31 months when the 24-hour standard was not exceeded. During months when the 24-hour standard was exceeded, adult hospital admissions rose 44%, compared to months when the standard was not exceeded.

Dr. Pope next compared hospital admissions during eight high months when the average (mean) PM-10 levels exceeded 50 micrograms per cubic meter of air versus admissions during 27 low months when average PM-10 levels never exceeded 50 micrograms per cubic meter. During high months, hospital admissions for children doubled, compared to low months, and adult admissions increased by 47%.

Dr. Pope then compared hospital admissions during periods when the steel mill was open versus when it was closed. During winter months, children's hospital admissions tripled when the steel mill was open, compared to winter months when it was closed. During fall months, children's admissions doubled when the steel mill was open, compared to fall months when it was closed.

The fourth technique, called regression analysis, created a mathematical model of the relationship between PM-10 pollution levels and hospital admissions for chest ailments. The model showed a very strong correlation between pollution and hospital admissions.

Strong correlations do not prove a cause and effect relationship. It is always possible that a third variable (such as a flu epidemic) coincided by chance with the opening of the steel mill.

To try to rule out such extraneous events, Dr. Pope studied admissions at a "control" group of Utah hospitals outside the Utah Valley and he could find no similar effects related to either PM-10 levels or to the opening or closing of the steel mill. He was also unable to find a relationship with the cold winter weather, and he was able to rule out an epidemic of contagious illness (such as flu) as a cause of the peaks in hospital admissions.

"The results indicated that hospital admissions for respiratory illnesses were strongly associated with PM-10 levels. This association is much stronger for children than adults, and is somewhat stronger for asthma and bronchitis than for pneumonia and pleurisy," Dr. Pope concluded.

It is important to note that "increased admissions for children are observed even for months when PM-10 did not exceed 150 micrograms per cubic meter, suggesting that this standard may not be adequate protection for some children," Dr. Pope concludes. The federal standard is not adequate to protect children.

In fact, the EPA itself admitted, when it published the PM-10 standard, there is evidence that NO levels of fine particle pollution are safe, especially for children. The EPA said, "The data do not provide evidence of clear thresholds in exposed populations. Instead, they suggest a continuum of response for a given number of exposed individuals with both the likelihood (risk) of any effects occurring AND the extent (incidence and severity) of any potential effect decreasing with concentration." [See FEDERAL REGISTER, Vol. 126 (July 1, 1987), pg. 24642; emphasis in the original.] The absence of a threshold means that ANY exposure to fine particles will take its toll on the health of the exposed population. The fine particles produced by every incinerator are harmful to humans, especially to children. The cumulative evidence is now overwhelming and has been ignored for too long by the promoters of incineration. It's time they were forced to confront the consequences of their dangerous technology.

Get: C. Arden Pope III, "Respiratory Disease Associated With Community Air Pollution and a Steel Mill, Utah Valley," AMERICAN JOURNAL OF PUBLIC HEALTH, Vol. 79 (May, 1989), pgs. 623-628. For a free reprint, contact Dr. Pope, Associate Professor of Natural Resources and Environmental Economics, Brigham Young University, Provo, UT 84602; phone (801) 378-2157.

--Peter Montague, Ph.D.

Descriptor terms: ut; steel mills; health effects; brigham young university; studies; air quality; qir pollution; epa policies; regulations; standards; children; adults; particulates;

#134: Fine Particles--Part 3: Federal Standards Allow Disease.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #134
---June 20, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

Particles in the air (smoke, dust, soot, haze) are more dangerous to humans as the size of the particles decreases. Particles are produced by the combustion of fossil fuels (especially coal, but also oil and gasoline), and by burning garbage or hazardous waste. In July, 1987, the U.S. Environmental Protection Agency (EPA) officially recognized that small particles are more dangerous than larger particles when the agency established air quality standards for particles smaller than 10 micrometers in diameter. A micrometer is a millionth of a meter and a meter is about 39 inches.

Now, just two years later, an extensive medical study has shown that human illness can result from particles in the air at levels that fall within EPA guidelines. In other words, an area may meet the federal requirements and yet still make residents sick.

The EPA standard is called PM-10, meaning it is an air quality standard for "Particulate Matter" 10 micrometers or less in diameter. (See FEDERAL REGISTER July 1, 1987, pgs. 24634-24669.) The older standard was for total suspended particulate [TSP] and it did not take into account the size of particles. The new standard specifically recognizes that particles smaller than 10 micrometers in diameter are not filtered out by the nose and throat and can pass into the large airways below the trachea. The smallest particles, which are less than 2.5 micrometers in diameter, are known as fine particles and they are the most dangerous because they pass all the way to the bottom of the lungs where they can move directly into the blood stream. (See RHWN #131 [revised] and #132b.] The federal air quality standard does not distinguish fine particles from others, though the existence of the PM-10 standard is recognition that small particles are more dangerous than large ones.

The federal standard says that, averaged over a year's time, an area's air should not contain more than 50 micrograms of PM-10 particles in each cubic meter of air; the 24-hour average is not supposed to exceed 150 micrograms per cubic meter of air. A microgram is a millionth of a gram and there are 28 grams in an ounce.

For the past decade, researchers at Harvard University have been studying the relationship of human health to particles in air; their work has been supported by the federal Department of Energy (DOE) which plans to burn coal on a massive scale (since nuclear power is, deservedly, on the ropes). The Harvard researchers have issued periodic reports on their work; the most recent one appeared in March, 1989. This study examined 8131 grade school students in six U.S. cities during the period 197479, and examined the same students again in 1981-82. To avoid complexities of age and race, only 5422 white students aged 10 to 12 were the final subjects of study. The cities were Steubenville, Ohio; St. Louis, Missouri; Kingston, Tennessee; Portage, Wisconsin; Topeka, Kansas; and Watertown, Massachusetts.

The students were asked about bronchitis, persistent cough, chest illness, wheeze and asthma. Bronchitis required a doctor's diagnosis within the last year; chronic cough was defined as being present for three months during the past year; chest illness required restriction of activity for 3 days or more; wheeze was defined as wheeze apart from colds or for most days and nights during the past year; asthma required the reporting of a doctor's diagnosis. The Harvard researchers also asked about three symptoms they didn't expect to be related to air pollution: earache, hay fever, and non-respiratory illness or trauma that restricted activities for 3 days or more.

The Harvard researchers did not collect data specifically on particles below 10 micrometers in diameter; they collected data (starting in 1978) on PM-15 (particulate matter less than 15 micrometers in diameter). The annual average PM-15 readings were as follows:

The least polluted city was Portage, WI (10 micrograms, or ug); then came Watertown, MA (26 ug), Topeka, KS (33 ug), St. Louis, MO (38 ug), Kingston, TN (42 ug), and finally Steubenville, OH (59 ug), the most polluted. Boys and girls in the more polluted cities were twice as likely to have bronchitis, compared with youngsters in the less polluted cities. Similar results were apparent for chronic cough and chest illnesses.

These results are important because in the most polluted city (Steubenville) the annual average particle count was 59 micrograms per cubic meter and this was a PM-15 measurement; if only particles 10 micrometers or smaller had been counted, the readings would have been substantially lower. In every other city in the study, the measured [PM-15] pollution levels were below the allowable federal PM-10 standard, yet children in those cities reported excessive disease rates. "We found health effects occurring at levels below the current annual average PM-10 standard," of 50 micrograms per cubic meter, says Douglas Dockery, leader of the Harvard study. This study provides unmistakable evidence that the federal standard for particles is inadequate to protect public health and safety.

The Harvard researchers say their results are important for another reason: there is some evidence that chest ailments during childhood predispose a person to permanent, serious breathing problems, like emphysema, in later life.

The study revealed that the 571 students (10.5% of the total) with asthma or persistent wheeze were particularly susceptible to bronchitis. Bronchitis was reported among 25.5% of the children with asthma or wheeze versus 4.0% of those without; for chronic cough the rates were 29.5% versus 3.2% and for chest illness 36.5% versus 7.6%.

When compared separately, those children without asthma or wheeze in the most polluted city were 2.2 times as likely to have bronchitis as non-asthmatics in the least polluted city; those children with asthma or wheeze in the most polluted city were 3.8 times as likely to have bronchitis, compared to asthmatics in the least polluted city.

An important point of this study is that it confirms that the relationship between particles in the air and childhood disease is "linear," which means that the more particles in the air, the more disease there is. This means that ANY increase in particles in the air is likely to cause disease in someone, somewhere. Thus, an incinerator proposing to spew particles into the air is very likely doing so at the expense of some innocent bystander somewhere. The defense, "I'm meeting all applicable state and federal standards" isn't sufficient to prevent illness. Even when a polluter meets those standards, someone will most likely get sick. Who gave polluters the right to make us sick? We, the people, didn't. It must have been someone else. Let's find out who and go after them.

Get: Douglas W. Dockery and others, "Effects of Inhalable Particles on Respiratory Health of Children." AMERICAN REVIEW OF RESPIRATORY DISEASE, Vol. 139 (March, 1989), pgs. 587-594. For a free reprint, write: Dr. D.W. Dockery, Department of Environmental Science and Physiology, Harvard School of Public Health, 665 Huntington Ave., Boston, MA 02115.

--Peter Montague, Ph.D.

Descriptor terms: epa; pm-10; children; regulations; health effects; air pollution; air quality standards; asthma; lung diseases; particulates;

#132b: Fine Particles--Part 2: Incineration's Tiny Byproducts Aggravate Asthma, Bronchitis.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #132b
---June 6, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
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========================Original Source========================

The most dangerous products of incineration are tiny, invisible, pollution coated particles released into the atmosphere. In the air pollution business, these are known as "fine particles." Despite the best available control technology, incinerators emit large quantities of such particles, which typically measure two micrometers or less in diameter. A micrometer is a millionth of a meter and a meter is 39 inches. Pollution control devices like Venturi scrubbers and baghouse filters are not very efficient at trapping these small particles, so to save money for incinerator operators (and thus encourage incineration, which is the stated goal of the EPA), the U.S. Environmental Protection Agency has declared it "OK" for incinerators to emit large quantities of the smallest particles. Federal law says that an incinerator is allowed to emit 180 milligrams of particles with each cubic meter of air (or 0.08 grains with each cubic foot of air). There are 437.5 grains in an ounce. One large incinerator smoke stack may emit 100,000 cubic feet of air every minute, day in and day out, or 52 billion cubic feet per year. It would be legal for such an incinerator to emit 300 tons of particles yearly. Typically, half of these particles will measure 2 micrometers or less in diameter and thus will be "respirable," which means that you and I can breathe them into the very bottom of our lungs because nature has provided us with no defense against particles this small. From our lungs, they can pass directly into our blood. (See RHWN #131, where we discussed the penetration of these fine particles into human lungs.)

The National Academy of Sciences, in AIRBORNE PARTICLES (Baltimore: University Park Press, 1979), discussed the health dangers of fine particles from many points of view. The "background level" of these fine particles in uninhabited regions of Canada is 1 to 3 micrograms in each cubic meter of air; in the rural Midwest, you'll find 5 to 12 micrograms in each cubic meter of air. This is not a "natural" background level; it represents pollution created by humans. Nevertheless, this background level is a good standard against which to judge the allowable emission of particles from incinerators. The allowable emissions from an incinerator exceed background concentrations by anywhere from a factor of 15,000 to a factor of 180,000. The EPA is relying upon dilution to protect you. They will argue that, by the time those particles reach your lungs, they will be diluted in a lot of fresh air and thus won't be quite so far above background levels when you breathe them. But this, of course, depends upon how close you live to an incinerator, how the wind currents go, whether there are thermal inversion conditions in your local atmosphere, and so forth. There is growing evidence (to be presented next week)#133 that the EPA's dilution strategy isn't safe.

Fine particles remain airborne for long periods of time, and before they fall to earth they can travel several hundred miles or even farther. They can present a danger to humans all along their route. Fine particles weigh so little that they do not respond predictably to the pull of gravity. The smallest air current keeps them aloft. These particles are so small that rain drops do not wash them from the atmosphere. You are no doubt familiar with the force of air being pushed ahead of a truck barreling down the highway; it gives your car a push as it goes by. In the same way, raindrops (which measure 500 to 9000 micrometers in diameter) push air ahead of them as they fall, and they knock fine particles aside instead of washing them to earth.

Increasing the concentration of fine particles in the atmosphere is not good for people. Hardest hit are those with bronchitis and asthma, those who are very young or old, and those who exercise outdoors. Breathing through your mouth (which is one of the first things people do when they exercise, play sports, or jog) increases the intake of fine particles into the lungs. In addition, some healthy people absorb 50% more fine particles into their lungs than the average. The reasons for this are not understood. One particularly important aspect of fine particles is that they carry into our lungs pollutants that could not otherwise get there. In this sense, fine particles have synergistic (multiplier) effects with other pollutants. The Academy said, "The generally accepted view of synergism extends beyond potentiation [increasing a pollutant's power] to include the role of toxic vector [carrier]. Such gases as sulfur dioxide are probably either adsorbed to the particulate surface or absorbed into the particles, and thereby transported into the alveolar regions [in the deep lung], where they exist in high, localized concentrations. These localized high concentrations [in the lung] could not be produced without particles. Accordingly, sulfur dioxide sorption to particulate matter might effectively allow sulfur dioxide penetration into the alveolar regions at even nominal environmental concentrations of the gaseous pollutant." In other words, "normal" or "acceptable" levels of sulfur dioxide may be made dangerous by the presence of fine particles.

"In summary," said the National Academy, "particulate atmospheric pollutants may be involved in chronic lung disease pathogenesis as causal factors in chronic bronchitis, as predisposing factors to acute bacterial and viral bronchitis, especially in children and cigarette smokers, and as aggravating factors for acute bronchial asthma and the terminal stages of oxygen deficiency (hypoxia) associated with chronic bronchitis and/or emphysema and its characteristic form of heart failure (cor pulmonale)."

--Peter Montague, Ph.D.

Descriptor terms: lung disease; particulates; air pollution; air quality; canada; bronchitis; emphysema

#131: Fine Particles--Part 1: The Dangers Of Incineration.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #131
---May 30, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================Original Source========================

Incineration of anything, including garbage and hazardous chemical wastes, produces a kind of pollution that is uniquely dangerous to humans: fine particles.

In this series, we will first discuss the characteristics of fine particles, and later we will discuss health studies showing the consequences of breathing fine particles.

The process of incineration turns solids and liquids partly into gases and partly into tiny particles of soot or ash. As the gases rise in the smoke stack, they cool and some of the gas molecules come together to form additional fine particles. The resulting particles are exceedingly small when they are emitted into the environment. Scientists who study particles make a distinction between coarse (large) particles and fine (small) particles. Fine particles behave entirely differently from coarse particles and, as we will see, are much more dangerous to humans. Fine particles are also much more difficult and expensive to control. They are also invisible, so when they are not controlled, there is no way to know it except by monitoring with the proper instruments.

Coarse particles are those with a diameter larger than 2 micrometers (micrometers); fine particles are those with a diameter less than 2 micrometers. A micrometer (micrometers) is a millionth of a meter and a meter is about a yard. (An older term for micrometer is micron.)

Incinerators emit large numbers of particles, despite the best available control technology. Half of all the particles emitted will have a diameter less that 2 micrometers, and the majority of these will have a diameter of 0.3 micrometers.

It is difficult to imagine how small these particles are. To help understand what we're talking about, look at the dot over the letter i in this newsletter; that dot measures about 400 micrometers in diameter. You can fit 40,000 particles with a diameter of 2 micrometers on the dot. When the particles have a diameter of 0.3 micrometers, you can fit 1.7 million particles on the dot over the i.

Unfortunately, U.S. EPA [Environmental Protection Agency] regulations do not take into consideration the sizes of the particles emitted by an incinerator. For regulatory purposes, coarse particles are considered to be the same as fine particles, as if they were all equivalent. The regulations issued as part of the Resource Conservation and Recovery Act (RCRA) allow the emission of 0.08 grains per dry standard cubic foot of stack gas (or 180 milligrams per dry standard cubic meter). There are 437.5 grains in an ounce. 

Measurements show that half these particles will have diameters ranging from 2.5 down to 0.1 micrometers; of that half, a majority will have a diameter of 0.3 micrometers. If we assume that 25% are 2 micrometers, 25% are 1 micrometers, 35% are 0.3 micrometers and 15% are 0.1 micrometers in diameter, we can generalize about the fine particle emissions from an incinerator.

Each pound of fine particles emitted from an incinerator will consist of 140 quadrillion (1.4 x 1017) individual particles. A quadrillion is 1000 trillion. Over a year's time, an incinerator meeting the federal standards will legally emit anywhere from 10 to 1000 tons of fine particles, depending upon the size of the incinerator.

Breaking things into fine particles has the effect of vastly increasing their surface area. A single lump of waste weighing a pound (and having the same density as water) would have a surface area of about 44 square inches (a square 6.5" on a side), about the size of a large post card. But when that same pound is broken into fine particles, its combined surface area grows to 9900 square yards (approximately two football fields). This is important for several reasons: as these fine particles move upward in the smoke stack, they are immersed in a bath of gaseous chemicals that are cooling and are "looking" for a place to turn from a gaseous to a solid state. Fine particles, with their large surface area, provide an inviting place and so the surfaces of fine particles become covered with pollutants ("enriched" is the technical term for this) before they are released into the local air. In particular, fine particles become coated with toxic metals (lead, cadmium, arsenic, chromium, and zinc, and with sulfur and polycyclic aromatic hydrocarbons--or with whatever else is in the smoke stack).

As the human body evolved throughout its long history, it adapted to the environment. One factor in the environment has always been dust, principally from dust storms. Dust from storms is larger than 5 micrometers in diameter and the human body evolved mechanisms for protection against such large particles. The hairs inside the nose, the mucous membranes lining the nose, throat and lungs, and even the shape of the throat, help to trap dust. As air is inhaled, the shape of the throat causes the air to swirl, so heavy dust particles are thrown outward by centrifugal force, where they strike the mucous-lined walls. As the tubes and passageways leading to the lungs twist and branch, they provide many opportunities for particles to collide with sticky walls and become trapped before they enter the lungs. Once trapped by mucous, coarse particles are coughed up and excreted.

Nature has gone to great lengths to protect the lungs because the deepest regions of our lungs provide places (called alveolar sacs, or alveoli) where oxygen passes into the blood and carbon dioxide passes out of the blood. The lungs provide a large surface area for contact with air, and thus with fine particles; the surface area of the alveoli is 65 square yards, which is larger than two tennis courts.

Thus, the deep regions of the lung provide very efficient, direct access to the blood stream and, by this means, to every part of the body. Unfortunately, humans now produce huge numbers of fine particles, and these are not caught by the body's protective mechanisms--they are simply too small. Fine particles pass easily into the deepest regions of the lungs, the alveoli, or alveolar sacs. There they remain indefinitely because no clearance mechanisms effectively remove them. Nature did not protect us against such particles, because none existed until very recently. Once lodged in the deep regions of the lung, fine particles, with their enormous surface area enriched with toxics, provide a particularly efficient means for delivering metals and organic pollutants directly into the blood stream. Their large surface area provides effective contact with moist tissue and the opportunity for dissolving or for other chemical reactions, putting pollutants directly into the victim's blood. Once in the circulatory system, toxics are then distributed throughout the body.

Fine particles have one other characteristic worthy of mention. They remain airborne for long periods of time and travel long distances--hundreds of miles, or ever farther. This occurs because they are so small and light that gravity does not pull them downward efficiently, so the slightest air current holds them aloft.

Furthermore, as we shall see, they are not removed from the atmosphere efficiently by rain. Therefore, for a long time after they are released into the environment, they remain available for humans to breathe in.

[To be continued.]

The best books on fine particles are those of the National Research Council, National Academy of Sciences: AIRBORNE PARTICLES (Baltimore, Md: University Park Press, 1979) and CONTROLLING AIRBORNE PARTICLES (Washington, Dc: National Academy of Sciences, 1980); a short summary appears in FINE PARTICULATE POLLUTION, a Report of the United Nations Economic Commission for Europe (London and NY: Pergamon Press, 1979). A good, though very technical, introduction is William Hinds, AEROSOL TECHNOLOGY; PROPERTIES, BEHAVIOR AND MEASUREMENT OF AIRBORNE PARTICLES (NY: John Wiley and Sons, 1982).

--Peter Montague, Ph.D.

Descriptor terms: particulates; air pollution; air quality; incineration; epa policies; rcra; emmissions;

#155: Zero Discharge: The Right Goal

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #155
---November 14, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com
========================Original Source========================

The earth looks large. As you gaze out your window at the landscape (or cityscape or seascape), it looks immense. But the appearance of great size is deceiving. The biosphere (the part of the earth that supports life) is a thin film on the surface of the planet. All but 1% of the air is contained in the lowest 20 miles of the atmosphere. The oceans average only 2.5 miles deep and at their deepest they are only 7 miles.

If the surface of the planet were smooth, without valleys or ridges, it would be evenly covered with water to a depth of one and three-quarter miles. Ocean water would account for all but 165 feet of that depth. That 165 feet of fresh water would consist of 140 feet of water from glacial ice, 15 feet from groundwater, and four or five inches from all the lakes and rivers; a last inch would hold the moisture content of the air. 

Together, the air and water on earth weigh only 1/4300 as much as the earth itself, the relationship of one pound to more than two tons. We inhabit a stone, partly bare, partly dusted with grains of disintegrated rock, upon which rests a thin film of air and water no thicker, relative to the size of the earth, than the fuzz on a peach.

The human population on earth is now roughly five billion people. We increase by 85 million people each year; by the year 2000, we will be six billion. Eighty percent of the global population lives in developing countries--countries that want to build industry modeled after Japan, Europe and America. But already we 20% who are industrialized have become a force large enough to destabilize the biosphere. Our mining, agricultural and industrial activities now move materials around on a scale that in many cases approaches the size of nature's own forces--and in some cases exceeds them.

For example, nature produces 80 billion tons of carbon dioxide (CO2) each year while humans produce 20 billion tons through the combustion of fossil fuels. In CO2 production, we humans are 25% as large as all of nature, and gaining. But even though our CO2 production has not yet matched nature's, in the past century we have increased the CO2 content of the atmosphere from 260 parts per million (ppm) to 325 ppm--a 25% increase across the entire planet. This is the cause of the "greenhouse effect." And each year brings another steady increase with no end in sight.

Nature mobilizes 50 million tons of sulfur each year in new plant growth, but humans release more than twice as much (120 million tons) by petroleum refining and combustion of coal and oil. By this measure, we are already twice as large as nature. Nature mobilizes 63 million tons of nitrogen each year but, through fertilizers and fuel combustion, humans release 215 million tons; here we are already more than three times as large as nature, and gaining. Small wonder that sulfur and nitrogen, combined, have changed the character of rain on a vast scale, making it as acid as vinegar across the eastern U.S., southern Canada, and northern Europe.

By some other measures, we humans dwarf nature. For example, we inject twice as much arsenic into the atmosphere as nature does, seven times as much cadmium, and 17 times as much lead. Measured by the metals that nature moves into the oceans via river discharges, we humans mobilize (through mining) 13 times as much iron as nature does, 36 times as much phosphorous, and 110 times as much tin. Small wonder that we find ourselves destabilizing the planet's mineral cycles, disturbing weather patterns, distressing vast regions of water and vegetation. We are like a giant blind mechanic, hammering the planet with our technology. Yet we are dependent upon nature for everything we own and everything we are. It is past time to take stock, to cut back, to get smart.

There are two basic ways to control pollution: (1) contain it all ("zero discharge"); or (2) wait until someone is harmed and can prove they have been harmed, then control whatever caused the harm. This second way ("prove harm"-see RHWN #154) is being tried by the industrialized world today. This strategy is failing in the sense that the planet is rapidly deteriorating as a fit place for humans to live. Furthermore, the deterioration is accelerating. The total stress on the planet seems to be increasing between 5% and 6% each year, year after year. Figure 1 shows what this looks like.

Figure 1 shows "total ecological demand" that we humans are putting on the earth, starting in 1880 and projecting forward to the year 2020. The demand of 1880 is one unit, so Figure 1 shows, for example, that total human demand on the environment in 1980 was 258 times as large as it was in 1880; by 1990 it will be 448 times as large; by the year 2000 it will be 776 times as large. By 2020, it will be 2333 times as large. That is the consequence of exponential growth (see RHWN #149). The total demand doubles every 13 years.

Zero discharge of materials from our mining, agricultural, and industrial processes would buy us two major benefits: dramatically reduced pollution, and an indefinitely expanded resource base through recycling. In the absence of serious controls on what we release into the environment, we will destroy the earth's ecosystems and we will deplete our supplies of essential minerals. Both pollution and depletion are already far advanced.

The most equitable and least disruptive program to achieve zero discharge would set mandatory dates for terminating emissions some distance in the future but would penalize delay in voluntary adoption of zero discharge by imposing chronologically graduated emissions taxes. That is to say, we must set the goal of zero discharge (as we did in the Clean Water Act of 1972, which set the goal at 1985). But in addition, we must tax emissions, to give polluters a constant incentive to cut emissions. The tax must increase steeply with time.

The "prove harm" alternative to zero discharge allows us to pollute until harm is proven; then we force a cutback. But this is an expensive way to go because (a) it guarantees that we will have many pollution victims before we have controls; and (b) it is cheaper to design a facility for zero discharge ("closed loop" technology) than it is to design it for no controls, then fix it up ("retrofit" it) to meet initial control standards, then fix it again when the standards tighten.

Zero discharge is understandable by anyone. It is unambiguous. Furthermore, it is the only strategy for which the costs and consequences can be determined now and which can be carried out using the knowledge we have now.

Support for the strategy of zero discharge draws its strength from our common experience that people up to now have not recognized pollution-caused dangers until it is too late to prevent major disruption. Acid rain, the greenhouse effect on global climate, ozone depletion, and the massive problem of chemical and radioactive waste cleanup that we face--these are just the most obvious manifestations of a pollution strategy (first prove harm, then take remedial action) that has not worked and cannot work.

Justifiable fear of pollution damage--and the perception that the authorities are risking our lives and the lives of our children recklessly--are resulting in confrontations, mistrust, and stalemate. The situation can only get worse as the century progresses. A commitment to zero discharge offers hope of solving those problems.

Finally, zero discharge overcomes the worst aspect of "prove harm" strategies: acceptance of defeat. Under a "prove harm" program, we are always fighting our way back after damage has taken place, and we are forced to accept continuing damage at some reduced level instead of watching damage come to an end and new growth begin. Under a "prove harm" strategy, we expect to pay enormous sums of money to reduce pollution, yet we do not expect to reverse the deterioration. It is a thoroughly depressing strategy which drives people to despair. Zero discharge offers humans real hope.

This weeks' newsletter, and last week's,#154 have drawn heavily (including long unattributed quotations) from essays by John Gofman, who directs the Committee for Nuclear Responsibility, P.O. Box 11207, San Francisco, CA 94101, to which gifts are tax-deductible; and from a book by Theodore Taylor and Charles Humpstone, RESTORATION OF THE EARTH (NY: Harper & Row, 1973), who first proposed seriously that all pollution should be contained and not released. We hope you can get past this book's love affair with nuclear technology; the book contains many useful ideas. Our data on natural vs. human activities are taken from it (pg. 24), from the journal NATURE Vol. 333 (May 12, 1988), pgs. 134-139 and from Carroll Wilson, MAN'S IMPACT ON THE GLOBAL ENVIRONMENT (Cambridge, MA: MIT Press, 1970), pg. 116. Our Figure 1 is derived from Wilson, pg. 22.

Total Ecological Demand
(The Demand of Year 1880 = one unit)
==
==
2400          Figure 1
.
2100          Total ecological demand on Earth's               *
.             resources from mining, industry and
1800          agriculture during the years 1880               *
.             through 2020, assuming continued
1500          growth at 5.5% per year.                       *
.
1200          Total demand is doubling every 13 years.      *
.
900                                                        *
.
600                                                      *
.                                                     *
300                                              *
.                                       *
0   *       *       *         *
1880  .  1990  .  1920  .  1940  .  1960  .  1980  .  2000  .  2020
                      TIME

--Peter Montague, Ph.D.

Descriptor terms: zero discharge; carbon dioxide; greenhouse effect; ldcs; economic development; acid rain; acid precipitation; nitrogen; sulfur; lead; arsenic; recycling; risk assessment; statistics; global environmental problems;

#142: Mr. Reilly's EPA Is Forcing States To Site 90 Hazardous Waste Incinerators.

=======================Electronic Edition========================

RACHEL'S HAZARDOUS WASTE NEWS #142
---August 15, 1989---
News and resources for environmental justice.
------
Environmental Research Foundation
P.O. Box 5036, Annapolis, MD 21403
Fax (410) 263-8944; Internet: erf@igc.apc.org ==========
RACHEL-4CM = DIOXIN FOCUSED DIRECTORY Remote Access Chemical Hazards Electronic Library. Dioxinnz.com ========================Original Source========================

The U.S. Environmental Protection Agency (EPA) has begun an aggressive program to force states to site 90 hazardous waste incinerators. If a state refuses, the EPA says it will cut off all Superfund aid for cleanup of toxic dumps. In essence, the EPA is holding hostages-the victims living near chemical dumps--and is threatening them bodily harm, saying, "If you (state governments) want us to help these unfortunate people, you will have to give industry what it wants, which is 90 incinerators to burn chemical wastes." If Mr. Reilly succeeds in this blackmail, industry will be able to burn all the hazardous waste it wants during the next 20 years, removing a major incentive to cut waste production.

In response, grass roots activists across the country will hold press conferences and demonstrations August 17 at many locations, urging state governments to resist EPA's arm-twisting on behalf of industry. To find out how you can participate in the August 17 activities, phone Linda Wallace Campbell in Alabama at (205) 652-9854. Ms. Campbell is coordinating these demonstrations for the National Toxics Campaign, headquartered in Boston [(617) 482-1477; ask for Michael Stein].

Background: Capacity Assurance Plans

In 1986, industry could see that they were losing the battle to site new chemical waste facilities (dumps and incinerators). The people had spoken at site after site across the country and the message was clear: "Not in anybody's back yard, these things are too dangerous." So industry lobbied Congress to get a new provision added to the Superfund Law. As a result, by October 17, 1989, each state must prove to EPA that their state has sufficient waste management capacity to handle all the hazardous waste that will be created within the state during the next 20 years, or they must show that they have agreements with other states to send their wastes to other states. The proof that a state has sufficient capacity is called a "Capacity Assurance Plan" or CAP. Each state must produce a CAP by October 17 this year.

Naturally there are two ways to get sufficient capacity to manage wastes: build new facilities to keep up with rising waste production, or take steps now to reduce waste so that present facilities can do the job.

It must be obvious to everyone that reducing waste is the better way. Wastes that are never produced can't hurt anyone; they can't harm workers; they can't poison unsuspecting families living near factories or dumps or incinerators. Wastes that are never produced won't require a high-priced EPA bureaucrat to measure them and evaluate their hazard; no EPA engineer will be required to argue with the company that this technology or that technology is the "best available control technology" for this particular waste. Wastes that are never produced won't require an EPA lawyer to take the polluter to court after the polluter digs in its heels and refuses to stop polluting. Wastes that are never produced cannot generate liability lawsuits against the waste generator. Wastes that are never produced do not require the expenditure of huge sums on doublelined landfills and much larger sums cleaning up those double-lined dumps after they start leaking in a few years. Wastes that are never produced are the cleanest, safest, cheapest wastes imaginable. Who would argue otherwise, except some pitiful waste junky hooked on the production of poisons for profit?

The Office of Technology Assessment (OTA)--the research arm of the United States Congress--estimates that 50% of all industrial wastes produced today could be avoided during the next five years with EXISTING TECHNOLOGY. No technical breakthroughs would be needed to cut today's industrial hazardous wastes in half in five years, says OTA. Obviously, with some effort, more than 50% could be cut.

Unfortunately, there are enormous forces pushing EPA to ignore common sense and to require states to build new incinerators, instead of requiring states to hammer industry to reduce wastes. First, the "waste management industry" is now huge and is now dominated by some of America's leading industrial giants. Monsanto, Dow, Westinghouse, GE and many other Fortune 500 companies have all found business opportunities in end-of-the-pipe waste treatment technology. Another factor is the vast army of consulting firms that have sprung up within the last 15 years. These consultants are known as "beltway bandits" because their offices are clustered around the I-495 beltway that rings Washington, DC, and because they charge high prices for warmed over work that they store in their word processor and sell repeatedly to one community after another, merely typing the name of a new client on the cover sheet (in the trade this is called "boiler plate" and even the best firms rely upon it). You know the names of these consulting firms because you've come up against their risk assessments in local fights: "Our state of the art assessment of this state of the art chemical incinerator [or dump or whatever] shows that this facility presents no immediate threat to health and safety; our mathematical models prove that living 100 yards from this [fill in the blank] is safer than eating two tablespoons of peanut butter and anyone who thinks otherwise is a dangerously uninformed, or is motivated by selfishness and greed. That will be $186,000, please.") We are only exaggerating slightly to make a point. The "waste management" industry is now grossing $80 billion per year, so proposals to reduce wastes are not well-received among their ranks. These people's jobs were created by the Clean Air Act, the Clean Water Act, the Toxic Substances Control Act, the Safe Drinking Water Act, and the Superfund Act. No wonder they aren't promoting sensible public policies to start making all these laws obsolete.

In addition, industry doesn't make serious efforts to reduce waste because of simple inertia. Industries that are making money don't want to risk any changes. For years, they have successfully run factories making aspirin tablets or paint or whatever, passing the costs of waste disposal onto future generations. Who knows? If they change how they do things, they may not succeed. At the very least, there would be an uncomfortable period when things were up in the air, which would mean fewer afternoons on the golf links and, when it was all over, who could guarantee it would work as well as the present system, which hums along like a self-propelled money machine?

At bottom, the strongest objection to waste reduction may be simple stubbornness. "Those damn nervous nellie nimbys and those power-hungry bureaucrats in Washington don't get to tell ME what to do!" So there you have it: many persuasive reasons why sensible public policies, like waste reduction, are never tried and, in their place, the EPA is pushing 90 hazardous waste incinerators.

But why would the EPA--especially the EPA headed by a professional environmentalist like William Reilly-turn its back on sensible public policy and cave in to irrational industry wishes? Only George Bush knows the answer. He is the one who gives Mr. Reilly marching orders and he is the one whose next fabulously expensive Presidential campaign begins about 18 months from now.

For an excellent new 66-page booklet on these issues get: Sanford Lewis and Marco Kaltofen, FROM POISON TO PREVENTION (Boston, MA: National Toxics Campaign, 37 Temple Place, 4th fl., Boston, MA 02111); $15 for community groups. For others, price unknown. Phone: (617) 482-1477.
FROM POISON TO PREVENTION describes the EPA's plan for covering the nation with hazardous waste incinerators, details the hazards of these incinerators, offers specific ideas for fighting the plan, and gives detailed recommendations for industrial waste reduction.

--Peter Montague, Ph.D.

Descriptor terms: waste reduction; epa; national toxics campaign; ntc; waste treatment technologies; hazardous waste incineration; air pollution; capacity assurance planning; cap; siting; regulations;