BLUE RIDGE ENVIRONMENTAL DEFENSE LEAGUE
www.BREDL.org
~ PO Box 88 Glendale Springs, North Carolina
28629 ~ Phone (336) 982-2691 ~ Fax (336) 982-2954
~ Email: BREDL@skybest.com
To: Citizens for
a Safe Environment
From: Louis
Zeller
Re: GWI response
to questions about gasification
Date: April 12,
2002
Thank you for
providing to me a copy of Global Waste
International’s March 28th letter
to the Duplin County Board of Commissioners. I
write to provide additional information on
gasification and to show that GWI’s answers
are incomplete and misleading.
I have addressed
questions 3, 4, and 5 below.
3. GWI said that
"starved air gasification is distinguished
from mass burn incineration by the EPA." GWI
admits gasification is "technically
incineration" but that it is held to
different standards. In fact, the US EPA
distinguishes mass burn incinerators and starved
air gasification units by the amounts of
pollution emitted; that is, both mass burn and
gasification combustors emit the same pollutants
into the atmosphere, but in different amounts.
For example, EPA data show that gasification
units emit more nitrogen oxides and dioxins than
incinerators, and equal amounts of mercury.1
Compared with
incinerators, gasification combustors emit 28%
more nitrogen oxides. NOx
contributes
to smog, or ground-level ozone pollution.
According to EPA, children and adults with
lung disease or asthma, and those who work or
exercise outdoors risk lung damage from NOx
pollution.4 Mercury air emissions from
gasification units and mass burn incinerators are
equal and would be 204 pounds per year at a 100
ton/day combustor. NC toxic air pollutant
regulations indicate that mercury is unhealthy
above 0.6 parts per billion.5 The US ATSDR states,
"Even at low levels, metallic mercury can
cause health problems. Metallic mercury
exposure can cause harm before symptoms arise."
6
Gasification
units emit 83% more furans and dioxins than mass
burn incinerators. Dioxin is one of the most
toxic substances known; there is no safe level.
Dioxin is a "known human carcinogen."3
4. In Mr.
Gavin’s letter, GWI "certifies that the
volume reduction of the MSW is approximately 90%
with 100% recovery of all aluminum, other metals,
and glass." To find out more about recycling
with gasification, we interviewed C. Lowell
Miller, a gasification fuel systems expert with
the United States Department of Energy. Asked
about metal and glass reprocessing after
gasification, Mr. Miller said, "It seems to
me a difficult thing to do. The materials would
be in one great big clump."2 He said that high
temperatures would also fuse sand or earth in the
waste into glass. He added, "It could be
difficult to process the ash because of the
components [in the slag]."2 We asked if recyclable
materials could be recovered. Mr. Miller said,
"Aluminum would not, it would be
melted."2
5. GWI states
that ash would not meet the definition of
hazardous waste as defined by the EPA. According
to solid waste fuel studies, ash produced by the
burning of solid waste contains on average the
following elements in parts per million (ppm):
lead 220 ppm, chromium 92 ppm, cadmium 6 ppm.
Assuming GWI’s 90% reduction of waste volume
at a 100 ton per day unit, 3650 tons of ash and
residue, or 7.3 million pounds, would be produced
annually. (100 tons x 365 days x 0.1 = 3650) The
gasification unit’s annual ash output would
contain 44 pounds of cadmium, 671 pounds of
chromium, and 1,606 pounds of lead. If it is
not considered hazardous waste, the ash could be
buried in a nearby solid waste landfill where it
would contaminate leachate and groundwater.
Further, the safety of use of ash containing
toxins in building materials is debatable; the
question is controversial in communities
throughout the United States.
Incineration and
gasification are two sides of the same coin. Both
have smokestacks which emit pollution into the
atmosphere. Both burn the same type of fuel:
municipal solid waste. Both expose waste to
similar temperatures: 1000 to 1600 degrees F.
Therefore, it should be no surprise that the
lists of toxic air pollutants emitted by both are
identical. Pound-for-pound comparisons of the
levels of emissions from gasification units and
incinerators are for some compounds higher, some
identical, and some lower, but in every case
represent an unnecessary risk to environmental
quality and public health.
Enclosure: Incineration and
Gasification: A Toxic Comparison: a
detailed investigation of air pollution emissions
from mass-burn incinerators and starved-air
gasification combustors.
Footnotes
1. US Environmental
Protection Agency, Compilation of Air Pollutant
Emission Factors, Volume 1, Fifth Edition, AP-42
2. C. Lowell Miller
telephone interview with Louis Zeller on March
29, 2002
3. Report on
Carcinogens, Ninth Edition, Revised January
2001, U.S. Department of Health and Human
Services, Public Health Service, National
Toxicology Program
4. US Environmental
Protection Agency, Office of Air & Radiation
http://www.epa.gov/air/urbanair/nox/hlth.html
5. NC Air Pollution
Control Requirements, 15A NCAC 2D.1104
6. 7. National
Alert: A Warning About Continuing Patterns of
Metallic Mercury Exposure, Agency for Toxic
Substances and Disease Registry and USEPA, 7. http://www.atsdr.cdc.gov/alerts/970626.html
7. Refuse-Derived
Fuel Processing, Floyd Hasselriis,
Appx C, Source: US Bureau of Mines Publication RI
8426
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