DEC 21, 1998 Air Test Results Conducted at BMWNC

March 5, 1999

Denise Lee
Blue Ridge Environmental Defense League
Route 2 Box 286
Wadesboro, NC  28170

Dear Ms Lee:

I have reviewed the additional test results that you sent me from the December 21, 1998 air testing conducted at the BMWNC incinerator.  Based on what I could tell from what you sent me, only one new air sample was taken in this "new" round of testing. This sample was taken during each of 3 test runs at Unit #2. The samples were analyzed only for mercury. All of the other data included in the tables that you sent me were exactly the same as the data reported on the October 1998 Kilkelly Environmental Associates (KEA) report. There was one other change in the tables in this new report. There is no data reported for mercury corrected to 7% oxygen. KEA claims that the air permit standard does not require correcting mercury to 7% oxygen and therefore it is not necessary to do this. Apparently they did not know this in October when they corrected the mercury results to 7% oxygen.

The mercury results for Units #1 and #3 are exactly the same in this current report as they were in the October report. These units were not re-tested. Only Unit#2 was re-tested. The result for Unit #2 shows an average value for mercury for the 3 runs of 0.025 lbs/hour, which is below the standard of 0.032 lbs/hour. The reason for this lower value is that less waste was fed into the incinerator. During the May/August testing, 1,680 lbs/hr were burned in the incinerator. In the December test, only 1,500 lb/hr were burned. Not surprisingly, if you burn less waste, less mercury comes out the stack.

The December 21st samples were taken after the incinerator had been run overnight in order to provide optimal operating conditions during which to collect the sample. Despite this, the mercury levels were still at almost 80% of the standard (0.025 lbs/hy versus 0.032 lbs/hr). This does not leave much room for error, especially when you consider that emissions will exceed the standard during start-up and maximum loading periods as occurred during the earlier testing.

Another concern is the emissions of dioxins/furans which are still substantially in excess of the federal standard. The average value of dioxins/furans for each unit was at least 10 times the federal standard. The value for Unit #3 is more than 20 times the federal standard. Even  though the standard is technically not yet in effect, people are still exposed to this amount of dioxin when the incinerator is in operation. These levels are clearly extraordinarily high and they clearly pose significant health risks to people down wind from the incinerator. The county should not allow this incinerator to operate with such high dioxin/furan emissions.

Other substances that still exceed the applicable standards are hexavalent chromium (all 3 units), and cadmium (Unit #2 ). The hexavalent chromium results were dismissed because the total chromium values were less than the standard and thus, the Mecklenburg County Deartment of Environmental Protection (DEP) felt that "there must be some other factor affecting the measurement of hexavalent chromium" (Feb. 22, 1999 letter from John Barry). This may be true, but the only way to understand what is going on is to repeat the tests and verify the levels of hexavalent and total chromium. Measuring for hexavalent chromium in incinerator stack emissions is not something new. If manganese or other some other metal is interfering with the analysis, then there are ways to avoid this problem. If the analytical lab used by BMWNC cannot separate the metals properly, then another lab should be used who can do this. The resolution of this problem is not to dismiss the results, but to retest the burners using proper analytical methods.

The one test for cadmium (Unit #2) that exceeded the air permit standard is similarly dismissed by the County DEP stating that "subsequent modeling did demonstrate compliance with State AAL limits for the entire facility." No data or information is provided to support this statement. If the county can cavalierly dismiss test results that exceed air permit standards, then what is the purpose of the testing? There is no reason, and certainly no justification, for ignoring this test result.

In summary, the December testing at the BMWNC facility was very limited. Only one sample test was taken during each of three runs at Unit #2. Only mercury was analyzed in these samples. Nowhere is there any explanation for why the testing was limited to mercury in Unit#2. My best guess is that the mercury value for Unit #2 was the only test result from the earlier (May/August) testing that they could not dismiss. This test was taken during optimal operating conditions and the results are still at nearly 80% of the standard. Given that the incinerators will exceed the standard during start-up periods and during periods of maximum loading (the conditions during which the earlier testing was done), significant amounts of mercury will be released into the community from these three burners. In addition, the dioxins/furans levels exceeded the federal standard for all three units by at least 10 times.

Although the standard is not yet in effect, these emissions continue to be released into the community posing a significant public health risk. Questions about the validity of the haxavalent chromium results need to be resolved by additional testing, not by dismissing the results. And similarly, the county needs to provide the data they used as the basis for dismissing the cadmium value that exceeded the air permit standard.

In conclusion, despite the statements by the Mecklenburg County DEP that the BMWNC facility is in full compliance with their air permit requirements, the emissions of dioxins and furans, hexavalent chromium, and cadmium still exceed the permit standards. The county has simply dismissed these violations with minimal or no justification. These emissions, combined with mercury emissions which exceed the air permit standard during start-up and during maximum loading periods, together result in significant releases of toxic chemicals into the surrounding community. These releases pose significant public health risks and should not be allowed to continue.

I hope these comments are helpful. Feel free to contact me if you have any questions or need any additional information.

Sincerely,

Stephen U. Lester
Science Director

--
Center for Health, Environment & Justice
P.O. Box 6806
Falls Church, VA 22040
(703) 237-2249
(703) 237-8389 fax