 Coalition for
Responsible Waste Incineration
June 1, 1999
Document Control Office (7404)
Office of Pollution Prevention and Toxics (OPPT)
Room G-099, East Tower
U.S. Environmental Protection Agency
401 M Street, SW
Washington, DC 20460
Re: Docket Control No. OPPTS-400136
The Coalition for Responsible Waste Incineration (CRWI) is
pleased to submit comments on the Combustion for Energy Recovery
Toxic Release Inventory Reporting; Notice of Receipt of Petition (Federal
Register, March 31, 1999). CRWI represents nine companies with
either captive or commercial hazardous waste incineration interests.
These companies account for a significant portion of the U.S. capacity
for hazardous waste incineration. In addition, CRWI is advised by a
number of academic members with research interests in hazardous waste
incineration. Since its inception, CRWI has encouraged its members to
reduce the generation of hazardous waste. However, for certain
hazardous waste streams, CRWI believes that incineration is a safe and
effective method of treatment, reducing both the volume and toxicity of
the waste treated. CRWI seeks to help its member companies both to
improve their incineration operations and to provide lawmakers and
regulators helpful data and comments.
Under the Pollution Prevention Act of 1990 (PPA), generators
are allowed to report the combustion of their high BTU hazardous wastes
in certain industrial furnaces as "used for energy recovery." On the
other hand, the exact same material sent to an incinerator must be
reported as treatment (either on-site or off-site). CRWI believes that
the burning of high energy wastes in an incinerator constitutes energy
recovery by replacing fossil fuels in the same manner as when burned in
other industrial furnaces. CRWI suggests that any time hazardous waste
is used as a fuel in any facility (incinerator, cement kiln, industrial
boiler, etc.), the generator of that hazardous waste should be allowed
to claim that this material was "used for energy recovery." All
facilities that burn hazardous waste now have to meet similar
standards. With the promulgation of the proposed hazard waste combustor
Maximum Achievable Control Technology rule (expected in late July
1999), any differences between combustor requirements will be even
smaller. From a public policy perspective, providing only part of the
hazardous waste combustors a "recycling" credit for energy recovery for
burning the same material is not warranted, especially after the
promulgation of the hazardous waste combustor MACT Rule. CRWI suggests
that these differences be removed and that any time high BTU hazardous
waste is used to replace fossil fuel, the generator of that hazardous
waste be allowed to claim "used for energy recovery" on their Toxic
Release Inventory (TRI) report.
EPA requested comments on whether the agency should
distinguish between toxic chemicals used to start up incinerators and
toxic chemicals in waste used for maintaining combustion. It is not
common practice to start up an incinerator with waste. Normally, an
incinerator is started on a fossil fuel. When the operating conditions
become stabilized, hazardous waste is then fed to the unit. In fact,
when the operating conditions fall outside the approved range (as
defined by the facility's permit), waste feed is cut off and fossil
fuel is substituted to maintain temperature. EPA has recently allowed a
comparable fuel exemption (63 Federal Register 33781, June 19,
1998) where certain hazardous wastes that meet specifications and are
burned in a qualified unit can be exempted from RCRA. CRWI suggests
that any time a comparable fuel is used, either to start up or to
maintain combustion in an incinerator, that material should qualify for
the "used for energy recovery" category of their TRI report. This is
one example of where high BTU waste materials can replace fossil fuel
in an incinerator. In addition, CRWI believes that any time high BTU
waste materials are used to replace fossil fuels, the "used for energy
recovery" category should be available to the generator.
Thank you for considering these comments. Please contact me
(202-775-9869) if you have questions.
Sincerely yours,
Melvin E. Keener, Ph.D.
Executive Director
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