TL: Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration SO: Greenpeace USA (GP) DT: 1991 Keywords: toxics cement incineration waste disposal health risks us greenpeace testimony gp / [part 1 of 14] ================================================================ D. A. Stein and J. Lowe, "HEALTH RISK ASSESSMENT: INCREASED LIQUID WASTE FUEL FIRING IN THE LEBEC CEMENT KILN, VOLUME I: REPORT," EBASCO Environmental with Dames & Moore; prepared for National Cement Compa-ny, Lebec, California; Revised April 1990. D. A. Stein and J. Lowe, "HEALTH RISK ASSESSMENT: INCREASED LIQUID WASTE FUEL FIRING IN THE LEBEC CEMENT KILN, VOLUME II: REPORT," EBASCO Environmental with Dames & Moore; prepared for National Cement Compa-ny, Lebec, California; Revised April 1990. and accompanying documentation A.C. Bell, "Non-Criteria Pollutant Emissions and AB2588 Testing from the Lebec Cement Plant Rotary Kiln, December 4, 1989 - January 11, 1990," Energy Systems Associates, Tustin, California, March 1990. ================================================================= ==== Prepared by Pat Costner and Joe Thornton Research and Information Unit Greenpeace USA Toxics Campaign 1017 West Jackson Boulevard Chicago, IL 60607 May 16, 1990 ================================================================= ==== CONTENTS Summary .......................................................... 1 Basic Flaws in Project Design .................................... 2 1. Data emissions for 100% Coke 2. Inadequate characterization of hazardous wastes 3. Failure to account for hysteresis effect Incomplete Identification and Quantification of Toxic Emissions... 6 1. Inadequate sampling and analysis of volatile hydrocarbons 2. Failure to account for air emissions that have not been positively identified 3. Failure to account for air emissions during upset conditions 4. Failure to account for fugitive emissions 5. Failure to account for stockpiled kiln dust Failure to Account for Peripheral Risks .......................... 9 1. Transportation risks 2. Catastrophic events Underestimation of Human Exposures ............................... 9 1. Underestimation of food- chain exposures 2. Underestimation of dioxin and furan bioaccumulation factors 3. Failure to assess infant exposure to pollutants in mothers' milk 4. Underestimation of dioxin and furan persistence 5. Failure to address long-distance pollutant transport 6. Failure to address pollutant ingestion by individuals consuming more than average quantities of contaminated food Underestimation of Toxicity ..................................... 12 1. Failure to assess synergistic toxic effects 2. Failure to assess background chemical exposure 3. Failure to address cancer promotion 4. Failure to assess cumulative effects of chemicals with similar mechanisms of toxicity 5. Failure to assess subtle health effects (developmental, repro- ductive and neurological impairment and immunosuppresion) 6. Failure to consider non-threshold effects other than cancer 7. Failure to assess toxicity to sensitive sub-populations 8. Failure to assess toxicity for pollutants with no available reference dose Conclusions and Recommendations ................................. 14 Appendix -- Fugitive Emissions from National Cement ............. 16 References ...................................................... 17 [Greenbase Inventory October 27, 1991 ] =======[#]======= [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 2 of 14] SUMMARY The data contained in and alluded to in National Cement's 1989-1990 health risk assessment and accompanying reports are adequate to sup-port only the following general conclusions: * National Cement's Lebec kiln is a point-source for unknown quan- tities of unknown numbers of heavy metals and toxic chemicals when it is burning petroleum coke, when it is burning 16 percent hazardous waste and when it is burning 37 percent hazardous waste; * Air emissions of gaseous and particulate pollutants from National Cement's Lebec kiln pose significant risks to the public and the environment; and * Based on the incomplete assessment contained in these reports, the public health risks from the toxic pollutants emanating from National Cement's Lebec kiln are well in excess of those requir- ing state and/or federal intervention. Due to the following inadequacies, the information contained in these reports cannot support either the general conclusions or the quantita-tive risk estimates presented in the reports: * Basic flaws in the experimental design; * Incomplete identification and quantification of toxic air emissions; * Failure to address toxic emissions via fugitive releases and via storage and disposal of contaminated kiln dust; * Failure to address peripheral risks including transportation and catastrophic accidents; * Inadequate modeling of human exposure to pollutants; and * Omission of major health effects caused by exposure to kiln pollutants. The information contained in these reports fails to support National Cement's request to increase the quantity of hazardous waste burned in its kiln. Available information in the risk assessment or in the technical literature on hazardous waste combustion confirms that kiln emissions pose a threat to human health and the environment. Waste-burning at National Cement should be discontinued immediately. ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 3 of 14] BASIC FLAWS IN PROJECT DESIGN 1. Data Omissions for 100% Coke Due to apparent oversights and errors in the design of the study, appropriate air emissions data were not collected. For example, the information establishing the identities and quantities of air emis-sions during the burning of 100 percent coke are admittedly "based on previous Lebec kiln test data" from studies in 1983 and 1985. More-over, some data were taken from a 1984 study of a Puerto Rican cement kiln that is a "wet process kiln" as opposed to the Lebec kiln, which is a dry process kiln. (1) To establish the applicability of the data from these earlier studies in characterizing air emissions and, subsequently, quantifying health risks from burning 100 percent coke at the Lebec kiln, the following information, which was not presented in these 1989-90 reports, would be essential: * Data showing that the petroleum coke burned as fuel during 1983 and 1985 is identical in content -- particularly in respect to chlorine, organics and metals -- as the coke burned during collection of air emissions data from the burning of 16 percent and 37 percent hazardous waste; * Factual evidence proving that all other operating parameters -- kiln feed content and feedrate, fuel feedrate, stack gas flow rate, excess oxygen, temperatures, etc. -- were identi- cal with those in effect during collection of the 1989-90 data or that these factors have no effect on air emissions; and * Data showing the sampling and analytical protocols used during the 1983 and 1985 studies to be comparable in accuracy and reliability with those of the 1989-90 study. For example, with recent advances in sampling and analytical techniques, it seems unlikely that a thorough study of a 100 percent coke burn would result in either `no-detect' or `no data available' for 35 percent of the organic pollutants of concern, as shown in Table 7 of the risk assessment. * Factual evidence that fuel, kiln feed, feedrate and other operating conditions at the San Juan kiln were identical with those during the 1989-90 Lebec study, and, further, that air emissions from wet process kilns are, in general, similar in identities and quantities with those of dry process kilns. [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 4 of 14] 2. Inadequate Characterization of Hazardous Waste The hazardous wastes burned during the 1989-90 study were inadequately characterized. Information provided in the study do not indicate that any effort was made to ascertain, much less to hold constant, such sensitive parameters as chlorine content of the fuels or hazardous waste burned during the study. For example, a so-called "typical analysis" of hazardous waste listed a chlorine content of 3.1 percent and only one metal, lead, at 300 parts per million (ppm). A compari-son with the "Representative Documents of Tender," copies of five hazardous waste manifests, shows a wide variation in chlorine content and the number and quantity of metals. _________________________________________________ Constituents in Hazardous Waste, as Detailed in "Representative Documents of Tender," Appendix E (2) Parameter Average Range Chlorine, percent 3.4 0.5-4.8 Metals, ppm Barium 1,700 300-3,000 Chromium 287.5 100-700 Iron 1,575 200-3,200 Titanium 1,875 400-3,700 Zinc 312.5 100-900 _______________________________________________ These data can also be compared with metal concentrations of hazardous waste presented in the 1989-90 study, shown in the table below. In comparing these data with those of the manifested wastes above, it is noteworthy that chromium levels in some manifested wastes were 133 percent of the chromium concentrations used in risk assessment calcu-lations. It is also interesting to note that iron, titanium and zinc were present in the manifested 6wastes in concentrations exactly equal to the "acceptance criteria" of the hazardous waste supplier, Systech. (1) With the exception of one metal (nickel), reported or acceptable levels of all the metals listed are higher in the hazardous waste than in the coke fuel. For example, arsenic concentrations in the hazard-ous waste can be 83.3 times higher than those in coke; lead, 714.3 times higher; and titanium, 1,947 times higher, as shown below: _________________________________________________________ [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 5 of 14] METALS IN WASTE FUEL, COKE AND KILN FEED (1,2,3) Kiln feed Liquid Waste, Petroleum Coke Metal Ratio Metal ppm ppm* Coke, ppm Coke/Waste Arsenic 33.1 50 0.6 83.3 Barium NDA 5,000 215 23.2 Beryllium 0.51 1 0.24 4.2 Cadmium 0.45 33 0.1 330 Chromium 15.2 300 9.4 31.9 Iron NDA 3,200 96 33.3 Manganese 194 36.3 4.1 8.8 Mercury 0.46 1 0.02 50 Nickel 16.35 250 530 0.47 Lead 10.38 1,500 2.1 714.3 Selenium NDA 0.1 NDA Titanium NDA 3,700 1.9 1,947 Zinc 68.9 900 11.4 78.9 * These data are described as "liquid waste fuel burner tip accept-ance criteria, Systech, 1990, unless otherwise noted." NDA = No data available __________________________________________________ It must be noted that the metals addressed in this study are not inclusive of all metals that have been identified in studies carried out at other kilns where hazardous waste is burned. Metals that have been detected in scrubber residues and stack gases of waste-burning kilns but were apparently not analyzed for in this report include aluminum, boron, cobalt, copper, magnesium, molybdenum, vanadium and yttrium. (8) Chlorine content of hazardous waste is known to be a critical factor in determining rates of emissions of particulates, emissions of par-ticulate-bound and gaseous metals, and the quantities and identities of products of incomplete combustion. Burning hazardous waste in cement and aggregate kilns has been shown to increase emissions of airborne particulates by 66 percent. Burning wastes containing chlorinated chemicals has increased emissions of airborne particulates by more than 200 percent. (4) As the chlorine content of hazardous wastes burned in incinerators and cement kilns increases, air emissions of many metals also increase, due to the greater volatility of many metallic chlorides. (4,5,6) For example, an increase in chlorine content from 0 percent to 3.8 percent in hazardous waste burned in a rotary kiln increased air emissions of metals as follows: (6) Percent Increase in Air Emissions Metal When Burning Chlorinated Waste Arsenic 58.6 % Barium 10.0 Bismuth 61.8 Cadmium 18.2 Chromium 30.0 Copper 94.7 Lead 96.7 Magnesium 70.0 Further, the presence of chlorinated compounds in burned wastes may also yield higher concentrations of products of incomplete combustion. (7) Chlorinated compounds are generally "more refractory" (more difficult to burn) and "require longer retention times to achieve acceptable destruction efficiency."(7) Given the well-documented effects of chlorine content on the fate of metals, accurate measurements of the chlorine content of all compo-nents burned -- both petroleum coke and hazardous wastes -- are a crucial, but absent, portion of data essential to this attempted health risk assessment. For example, in the absence of constant and well-quantified chlorine concentrations in kiln feed and fuel, whether coke or hazardous waste, the metal "penetration factors" used to calculate metals emissions are meaningless. [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 6 of 14] 3. Failure to Account for Hysteresis In test burns where chlorinated wastes were cofired with conventional fuels in an industrial boiler, chlorinated organics were still present in stack gases long after the introduction of chlorinated wastes had ceased. Forty-three hours after cofiring was stopped, chlorinated organics were present in stack gases at concentrations approximately 50 percent as high as those found during cofiring. In fact, two hours after cofiring ceased, the stack gas concentrations of the chlorinated chemicals that had been burned were greater than the concentrations measured during cofiring. (9) If such hysteresis effects are found to be ubiquitous in the combus-tion of chlorinated chemicals, current methods of measuring destruc-tion efficiencies and emissions rates are essentially meaningless. As such, the data contained in emissions tests at National Cement while burning coke-only and whil cofiring waste may not be reliable. In assessing the data presented in the study under discussion, hyster-esis effects may explain the presence of PCBs and chlorinated dioxins and furans in stack gases during the 100 percent coke burns, when no known sources of chlorine were entering the kiln. Two of the 1984 tests of 100 percent coke as fuel were conducted within 17 and 40 hours of burning 40 percent hazardous waste. Consequently, the PCBs, dioxins and furans detected during these tests may have been delayed emissions associated with earlier burning of chlorinated wastes. (10) ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 7 of 14] INCOMPLETE IDENTIFICATION AND QUANTIFICATION OF AIR EMISSIONS 1. Inadequate Sampling and Analysis of Volatile Hydrocarbons Violations of protocols in sampling procedures and sample preparation, described in Appendix C, severely limit the identification and quanti-fication of volatile hydrocarbons achieved in the 1989-90 study of air emissions at National Cement's Lebec kiln. Because of these problems, numerous toxic chemicals emitted at rates up to hundreds of pounds per year can have easily escaped detection during the 1989-90 study. Prescribed sampling procedures were not followed in the collection of stack gas samples to be analyzed for volatile hydrocarbons, in part, because the Lebec kiln baghouse is not equipped with a traditional stack. However, the appropriate alternate method, EPA Method 5D was not followed as prescribed either. Rather than the minimum of 24 sampling points for each run, as called for by this method, samples for volatile hydrocarbons were collected at only one single point. There were also breeches of standard protocol in the preparation of canisters in which flue gas samples were collected. (3) Due to failure to follow specified procedures or to difficulties in sample preparation, Enseco, the laboratory that analyzed stack gas samples for the 1989-90 air emissions tests at National Cement's Lebec kiln was able to identify and quantify only those chemicals that were present at relatively high concentrations. When standard protocols are followed, analyses of stack gas samples by gas chromatograph/mass spectrometer can be expected to allow the detection and quantification of chemicals that are present at concentrations of 1 ppb. Enseco was able to achieve detection limits ranging from 3 to 150 ppb, with an average detection limit of 18 ppb, for the 58 chemicals con-sidered. According to normal practice, chemicals are identified and quantified only when they are present at concentrations at least three times higher than the detection limit. Had standard protocols been followed and, consequently, normal detection limits been achieved, many more chemicals, both principal hazardous organic constituents (POHCs) and products of incomplete combustion (PICs), may well have been identified and quantified in the Lebec kiln stack gases. 2. Failure to account for air emissions that have not been positively identified. EPA has noted that the combustion of hazardous waste may produce up to thousands of different products of incomplete combustion. In the most carefully controlled tests using the most sophisticated sampling and analysis methods available, the agency has been able to identify only from 1 to 60 percent of the mass of synthetic pollutants exiting the smokestacks of hazardous waste combustors. The Agency has argued that many of the 40 to 99 percent of emissions which have not been identified are "undoubtedly toxic." (11) EPA has further noted that that sampling and analytical methods avail-able for use in field test-burns can be expected to identify even a smaller fraction of the pollutants formed and emitted when hazardous wastes are burned. (11) [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 8 of 14] 3. Failure to Account for Air Emissions During Upset Conditions The risk estimates do not reflect the potentially large increases in air emissions caused by combustion upsets, which are known to occur in cement kilns with some frequency. (4, 5) Emissions tests in the 1989-1990 reports were performed only during carefully controlled, near-ideal operating conditions. (1,2) According to U.S. EPA, all combustion devices are subject to upset conditions caused by even small fluctuations in temperature, waste-feed composition, and airflow. (12) Combustion upsets common in kilns include "puffs," when the introduction of volatile wastes results in non-uniform combustion (4,5,13), and "avalanches," in which a large ring of accumulated solids is released and falls through the kiln, reversing airflow direction and changing tempera-ture distribution. (4,5) Burning chlorinated wastes in a kiln may increase the likelihood of an avalanche (5). Toxic emissions during even occasional upsets pose significant incre-mental risks to public health. Kilns operating under upset condi-tions are considered "ideally suited for generating complex chemical reactions and a wide variety of PICs [products of incomplete combus-tion], including PCDDs and PCDFs [dioxins and furans]." (5) Accord-ing to EPA, "only a very small fraction of the total volume of waste needs to experience ... less than optimum conditions to result in significant deviations from targeted destruction efficiencies." (14) 4. Failure to Account for Fugitive Emissions The risk estimates presented in National Cement's 1989-90 study do not include quantification of fugitive emissions and associated risks. Fugitive emissions are released during routine transfer and handling of the hazardous wastes. National Cement has reported to EPA fugi-tive emissions of 29 toxic pollutants at a rate of 35,948 pounds per year (see Appendix I of these comments). The actual total may be significantly greater. (15) 5. Failure to Account for Stockpiled Kiln Dust The risk assessments do not address toxic releases associated with stockpiled kiln dust. The kiln produces large quantities of dust collected in its pollution control devices, which is collected in piles near the plant. Dust from cement kilns burning hazardous waste has been found to contain dioxins and furans,(16) and can be presumed to contain quantities of the many other PICs found in the flue gas, as well. A large percentage of toxic heavy metals fed to the kiln are distributed to the dust -- including lead, mercury, and chromium. (3,4,5) Exposure to toxic contaminants in the dust may take place during both storage and transport. Long-term environmental contamination may take place when the dust is disposed. ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 9 of 14] FAIILURE TO ACCOUNT FOR PERIPHERAL RISKS 1. Transportation Risks Risks associated with the transport of hazardous waste to the Lebec kiln are not addressed in the risk assessment. If the kiln burns waste at 1200 gallons per hour (1) throughout the year, it will receive over 1900 tanker truck shipments of waste per year -- more than 35 per week. The more waste the kiln burns, the more shipments it will receive and the greater the probability of accident. The U.S. Office of Technology Assessment reported more than 78,000 incidents involving the release of hazardous materials during trans-port during 1976- 1984. (17) One probability analysis of potential accidents at a cement kiln burning less waste than is burned at Na-tional Cement found that a tanker accident associated with a major toxic release was likely to occur once oevery five years.(5) Expo-sures associated with such an accident may be significant. 2. Catastrophic Events Risks of exposure during catastrophic events are not addressed in the risk assessment. National Cement is equipped to store up to 3.2 mil-lion pounds of waste onsite at any one time. (1) The storage of large amounts of volatile, ignitable, reactive, hazardous wastes creates the potential for catastrophic events that pose significant threats to public health and the environment. ================================================================= ==== UNDERESTIMATION OF HUMAN EXPOSURES Since National Cement's 1989-1990 risk assessment considers only a relatively small portion of the pollutants emitted from the kiln, its estimate of the doses received by the exposed individuals are also underestimated. In its exposure models, moreover, the risk assess-ment ignores additional factors which may increase the quantity of emitted chemicals received by exposed individuals. 1. Underestimation of Food-Chain Exposures. The document considers bioconcentration -- the accumulation of pollu-tants at magnified doses as they move up the food chain -- for only the following: dioxins and furans, PCBs, PAHs (polynuclear aromatic hydrocarbons), trichlorophenol, and heavy metals. Bioconcentration may make up the major route of exposure for other pollutants detected or not detected (but likely to be present) in emissions from the kiln. The most bioaccumulative kiln emissions will include the halogenated organics (chlorophenols, chlorobenzenes, chlorobutadi-enes, chlorostyrenes, scores of other potential complex chlorinated chemicals, and any complex products -- including polyhalogenated dioxins and furans -- produced in the combustion of brominated, fluorinated, or iodinated wastes). Bioconcentration of these pollu-tants may increase human intake of these pollutants by thousands of times. 2. Underestimation of Dioxin and Furan bioaccumulation factors. The risk assessment uses a bioconcentration factor (BCF) of 5,000 for accumulation of dioxins in fish. In contrast, EPA cites BCFs for 2,3,7,8-TCDD ranging from 159,000 (experimental basis) to 2.4 million (theoretical basis). (18,19) 3. Failure to Assess Infant Exposure to Pollutants in Mother's Milk. For liphophilic chemicals -- those which accumulate in the fatty tissues of the food chain, including the dioxins, furans, and PCBs -- "nursing infants can be regarded as living at the top of the food chain and are exposed to much more than background levels." (20) Of the 27 synthetic chemicals addressed in the risk assessment, 17 are already detectable in mother's milk samples from the general U.S. population. (21) The great sensitivity of developing infants to low doses of chemicals make these exposures especially signifi-cant. 4. Underestimation of Dioxin and Furan Persistence. The risk assessment contained in these reports estimates that dioxins will have a half-life of 12 years in the environment. EPA has re-cently written that available information is insufficient to esti-mate the half-life of 2,3,7,8-TCDD and other dioxins in the environ-ment. Rough estimates of dioxin half-life cited in EPA's report ranged to several decades.(18) Further, the risk assessment does not consider what breakdown products will be produced as dioxins and other chemicals degrade. Both physical and biological degradation of some toxic chemicals is known to produce breakdown products of greater persistence and toxicity. For instance, higher chlorinated dioxins have been shown to break down into the more toxic 2,3,7,8-TCDD, and chlorinated pesti-cides are often metabolized into more toxic forms.(22) Risks from these breakdown products may exceed risks from original emissions. 5.Failure to address long-distance pollutant transport and exposure. The risk assessment contained in these reports considers risks to a "most exposed individual" living near the facility. While nearby communities are exposed to the highest concentrations of kiln emis-sions, airborne pollutants emitted from combustion devices -- includ-ing dioxins, furans, and PCBs -- may be carried "across the hemi-sphere," according to EPA. (12) Pollutants formed in and emitted from waste incinerators -- including those detected in the emissions samples contained in this report -- are already accumulating in air, water, soil, and food, and human tissues across the entire planet. (23) The effects on the global ecosystem of waste incinera-tion at National Cement cannot be quantified. 6. Failure to address pollutant ingestion by individuals consuming more than average quantities of contaminated food. The risk assessment assumes that all exposed individuals consume the amount of area-grown milk, meat, fish, and garden vegetables associ-ated with median rates for rural populations across the nation. (1) No attempt is made to quantify average or maximum consumption rates for the area immediately exposed to kiln emissions. Moreover, median consumption rates are inappropriate for use in either a worst-case or plausible-case risk assessment: half the population will consume more than median quantities, and some individuals will consume significantly more. Those individuals will be subject to greater chemical exposures, especially for the highly bioaccumulative pollutants. ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 10 of 14] UNDERESTIMATION OF TOXICITY The risk assessment contained in the reports does not acknowledge that pollutants emitted from the kiln which have not been positively iden-tified may present a significant health threat. Moreover, the reports omit important health effects and mechanisms of toxicity, resulting in underestimation of total pollutant toxicity. 1. Failure to Assess Synergistic Toxic Effects. Individual chemicals may interact in an organism to produce even greater toxic effects than they have in isolation. (24,25) The presence of one chemical may make another more toxic. The risk as-sessment contained in these reports offers no information concerning the synergistic effects of the many chemicals emitted from the kiln. Researchers at the National Toxicology Program have noted that the many permutations of only a few dozen pollutants may involve millions of synergistic toxic effects. (26) 2. Failure to Assess "Background" Chemical Exposure. Toxic emissions from the kiln will add to dozens of other chemical exposures to which nearby communities are constantly subject (releases from other facilities, automobile emissions, pesticide residues on food, etc.). This point is especially important for health effects assumed to occur only above a certain threshold dose. While emissions from the kiln alone may not exceed the threshold dose, they could act as "the straw which breaks the camel's back," thus triggering signifi-cant toxic effects. Of the 27 synthetic toxic chemicals addressed in the risk assessment, at least 14 have accumulated in detectable con-centrations in the tissues of the general U.S. population. (27) 3. Failure to Address Cancer Promotion. The 1989-1990 risk assessment calculates cancer risks associated only with the direct cancer-causing properties of kiln emissions. Pollu-tants contained in emissions from the kiln -- most notably the dioxins and furans -- not only cause cancer by themselves but also magnify the ability of other chemicals to cause cancer. These cancer-promoting effects may take place at extremely low doses a involve complex inter-actions with the scores of cancer-causing chemicals to which the community is constantly exposed (both from the kiln and from other sources). (28) No data are presented in the risk assessment to quan-tify these effects. 4. Failure to Address Cumulative Effects of Chemicals with Similar Mechanisms of Toxicity. Many chemicals found in emissions from the kiln -- and many more which are likely to be present -- are known to damage living systems by the same mechanisms. For instance, dioxins, furans, PCBs, and chloroben-zenes are all thought to alter enzyme function in the same way (29); together, doses of these chemicals may exceed the toxicity threshold calculated for each chemical in isolation. The risk assessment offers no data to prove that cumulative doses of similar chemicals emitted from the kiln would not exceed reference doses. 5. Failure to Assess Subtle Health Effects (including developmental, reproductive and neurological impairment and immunosuppresion). The risk assessment contained in these reports considers only cancer and clinically observable "systemic toxicity" (non-cancer effects like liver toxicity, gross reproductive damage, etc.). Scientists, however, are now finding subtle "sub-chronic" effects which manifest themselves too slowly to detect in short- term experiments on laboratory animals. These effects, which have been associated with low doses of toxic chemicals (including lead, PCBs, and dioxin, all of which are emitted from the kiln), include decreased fertility [30], suppressed immune response [31], and impairment of the neurological and behavioral development of children. (32,33,34) Certain chemicals -- including lead and dioxin -- are thought to exert these toxic effects at any dose, no matter how low. (34, 35) 6. Failure to Consider Non-threshold Effects Other than Cancer. These reports assume that all health effects other than cancer take place only above a certain threshold dose. Some non-cancer effects, however, may also operate on a linear, non-threshold model. This hypothesis is widely accepted for effects associated with genetic mutations -- i.e., birth defects. (36) It has been noted that, for some chemicals, the threshold toxicity model may be more an artifact of analytical limitations than a truly safe level of exposure [34]. The threshold model is especially suspect for impairment of childhood neurological developmental and fertility reductions, which may occur at any dose, no matter how low. [30,34] 7. Failure to Assess Toxicity to Sensitive Sub-populations. The risk assessment calculates risks of cancer and other health ef-fects based on potencies and reference doses applicable to healthy adults. Babies, fetuses, the elderly, and the chemically sensitive may be far more susceptible to the toxic effects of kiln emissions. Researchers have noted that risk calculations from accepted cancer potency factors may underestimate the risk to sensitive individuals by as much as 10,000 times, transforming a one-per-million risk into a one- per-hundred risk. (25) 8. Failure to Assess Toxicity for Pollutants with No Available Refer-ence Dose. The risk assessment omits threshold reference doses for several pollu-tants detected in kiln emissions. Exposure to these pollutants was thus asssumed to have no noncancerous toxic effects. These pollutants include benzene, ethylene dichloride, formaldehyde, trichloroethylene, trichloroethane, carbon tetrachloride, and zinc, all of which are known to damage various organs and systems in the human body, includ-ing the liver, lungs, brain, reproductive system, or metabolic proc-ess. (37) ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 11 of 14] CONCLUSIONS AND RECOMMENDATIONS National Cement's 1989-1990 risk assessment omits so many important factors -- multiple pollutants (potentially thousands, ranging from non-toxic to extremely toxic), diverse routes of pollutant release, important pathways by which humans will be exposed to toxic releases, and major health effects associated with such exposures -- that the document offers no meaningful estimate of the risk associated with kiln operations at any level of waste combustion. Flaws in the design and execution of the project undermine the data and analyses used throughout the report. Data used to estimate emis-sions while burning 100 percent coke are essentially meaningless due to probable contamination from waste-burns conducted just prior to these tests. Use of non- parallel data to compare emissions while burning coke only, 16 percent waste, and 37 percent waste undermines any comparative risk analysis of these options: experiments were not adequately controlled for variations in waste-feed composition, kiln materials feed, and operating parameters; for sampling and analytical protocols used to gather data in tests five years apart; and even for the use of an entirely different kiln for some data. The data contained in the report confirm only that the kiln is emit-ting significant quantities of extremely toxic compounds at any level of waste combustion. Toxic emissions from the kiln while burning coke-only may suggest the need to assess use of conventional fuels at the kiln as well. It should be re- emphasized, however, that coke-only emissions tests presented in the report may have been contaminated by delayed emissions associated with waste combustion in the kiln. The unrealistically low estimates of risk to human health calculated in the 1989-1990 reports themselves exceed -- by factors from 1.5 to 9.9 -- those requiring state and/or federal intervention. While in certain cases, U.S. EPA has deferred regulations at a one-per-million risk level, that risk level remains the official "de minimis" standard which governs agency policy. Risks associated with kiln emissions at 0, 16, and 37 percent waste-fuel use all exceed this standard. Since the risk estimated contained in the 1989-1990 report must be considered only a "tip of the iceberg" estimate, it is clear that the kiln poses unacceptable, unquantifiable, and unnecessary risks to human health. Based on available information in the risk assessment and available technical literature, Greenpeace makes the following recommendations: * National Cement's request to increase its rate of hazardous waste incineration should be denied. The risk assessment clearly is inadequate to support such a request. * Incineration of hazardous waste at National Cement should be discontinued immediately due to unacceptable threats to public health posed by toxic emissions from the kiln. ================================================================= ==== [Greenbase Inventory October 27, 1991 ] =======[#]======= [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 12 of 14] APPENDIX Fugitive Emissions from National Cement Pollutant Fugitive Emissions (lbs/yr) Acetone 2,200 Benzene 41 t-Butyl alcohol 5 n-Butyl alcohol 420 Chlorobenzene 18 1,2-Dichloroethane 66 Dichloromethane 350 Diethyl phthalate 2 Dimethyl phthalate 6 2-Ethoxyethano l44 Ethyl benzene 2,500 Ethylene Glycol 5 Freon 113 59 Methanol 38 Methyl ethyl ketone 4,400 Methyl isobutyl ketone 2,000 Methyl methacrylate 100 Naphthalene 14 Phenol 18 Styrene 690 Tetrachloroethylene 62 Toluene 9,900 1,1,1-Trichloroethane 630 1,1,2-Trichloroethane 12 Trichloroethylene 290 Vinyl acetate 78 Xylene 12,000 TOTAL REPORTED EMISSIONS 35,948 Source: U.S. EPA Toxics Release Inventory on-line database, 1987 data submitted by Systech/National Cement Corporation, (Bethesda: National Library of Medicine, 1990). ================================================================= ==== [] Comments on: National Cement Company Health Risk Assessment and Proposed Increase in Waste-Fuel Incineration [part 13 of 14] REFERENCES 1. D. A. Stein and J. Lowe, "HEALTH RISK ASSESSMENT: INCREASED LIQUID WASTE FUEL FIRING IN THE LEBEC CEMENT KILN, VOLUME I: REPORT," EBASCO Environmental with Dames & Moore; prepared for National Cement Compa-ny, Lebec, California; Revised April 1990 2. D. A. Stein and J. Lowe, "HEALTH RISK ASSESSMENT: INCREASED LIQUID WASTE FUEL FIRING IN THE LEBEC CEMENT KILN, VOLUME II: REPORT," EBASCO Environmental with Dames & Moore; prepared for National Cement Compa-ny, Lebec, California; Revised April 1990 3. A.C. Bell, "Non-Criteria Pollutant Emissions and AB2588 Testing from the Lebec Cement Plant Rotary Kiln, December 4, 1989 - January 11, 1990," Energy Systems Associates, Tustin, California, March 1990 4. R. Mournighan and M. Branscome, "Hazardous Waste Combustion in Industrial Processes: Cement and Lime Kilns," EPA-68-03-3149, 1987. 5. Murphy, B., and Mix, T., "Risks Associated with Waste-Fuel Use in Cement Kilns," Environmental Progress, Vol. III, No. 1, February, 1984, pp. 64-70. 6. G.J. 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U.S. EPA, "Broad Scan Analysis of the FY 1982 National Human Adipose Tissue Survey Specimens, Volume I -- Executive Summary", US EPA, EPA/560-5-86-035, Washington D.C., December 1986. 28. R. Albert, US EPA Carcinogen Assessment Group, testimony to U.S. House of Representatives, cited in P. Merrell and C. Van Strum, "No Margin Of Safety," (Greenpeace 1987) p. II-7. 29. U.S. EPA, "Health Assessment Document for Polychlorinated Diben-zo-p-Dioxins," EPA/600/8-84/014f (September 1985), Washington D.C. 30. Barbara Shane, "Human Reproductive Hazards, Evaluation and Chemi-cal Etiology," Environmental Science and Technology, v. 23, pp. 10 ff. (1989). 31. P. Stehr-Green et al, "Health Effects of Long-Term Exposure to 2,3,7,8-TCDD," in Chemosphere, v. 16, 2089-2094 (1987). 32. G. Fein, J. Jacobson, S. Jacobson, and P. Schwarz, "Intrauterine Exposure of Humans to PCBs: Newborn Effects," report for the U.S. EPA Environmental Research Laboratory, Office of Research and Development, Duluth MN, May 1984, EPA-600/3-84-060. 33. S. Schantz, N. Laughlin, H. van Valkenberg and R. Bowman, "Mater-nal Care by Rhesus Monkeys of Infant MOnkeysd Exposed to Either Lead or 2,3,7,8-Tetrachlorodibenzo-p-dioxin," Neurotoxicology 7:2:637-650 (1986); R.E. Bowman, S. Schantz, N. Weerashinge, M.L. Gross, and D. Barsotti, "Chronic dietary intake of 2,3,7,8-tetrachlorodibenzo- p-dioxin at 5 or 25 parts per trillion in the monkey: TCDD kinetics and dose-effect estimate of reproductive toxicity," Chemosphere, v. 18 (1989), nos. 1-6, pp. 243-252; R.E. Bowman, S. Schantz, N. Weera-shinge, M.L. Gross, and D. Barsotti, "Behavioral Effects in Monkeys Exposed to 2,3,7,8-TCDD Transmitted Maternally During Gestation and for Four Months of Nursing," Chemosphere, v. 18 (1989), ppm 235-242. 34. H. Needleman, "The Persistent Threat of Lead: A Singular Opportu-nity," American Journal of Public Health, v. 79, no. 5 (May 1989), 643-645; H. Needleman, "Lead Exposure and Human Health: Recent Data on an Ancient Problem," Technology Review (1980) v. 82, no. 5, 39-45. 35. P. Merrell and C. Van Strum, "No Margin of Safety: The Need for Emergency Action in the Pulp and Paper Industry," Greenpeace USA, Washington DC, 1987, summarizes available laboratory evidence on dioxin toxicity. 36. M. Kamrin, "Toxicology: A Primer on Toxicology Principles and Applications," Lewis Publishers, Chelsea, MI, 1988. 37. National Library of Medicine, "Hazardous Substances Data Bank," on-line database, Bethesda, MD, 1990. ENDS [Greenbase Inventory October 27, 1991 ] =======[#]=======