TWELFTH ANNUAL WATER MANAGEMENT SEMINAR
JANUARY 9 16, 1993
SOLID WASTE MANAGEMENT AND WATER QUALITY
MARY P. McCONNELL
Solid waste management policy vaulted to the top of the
agenda for public policymakers in the last decade because of the
"landfill crisis." The landfill crisis was precipitated by the
discovery of groundwater contamination from leaking landfills,
the acute lack of landfill capacity to meet disposal needs and
the inability to site new landfills in highly populated areas.
As communities are faced with finding alternatives to
landfilling, some look to incinerating their solid waste and
others to composting their waste. Still others choose to recycle
and continue landfilling the waste which can not be recycled.
Each one of these alternatives has its own array of
environmental impacts. There are harmful emissions associated
with the drinking systems from paper recycling plants and from
detiners and other metal recycling facilities. Emissions from
waste incinerators such as dioxin, mercury and ash residue are of
concern. There are concerns regarding odors emanating from
compost facilities, the concentration of heavy metals in the
compost product and their availability to the environment. The
risk to our groundwater resources associated with leaking
landfills are well documented.
Waste incineration as a management alternative has been the
focus of most of the controversy recently because of the air
emissions generated by these facilities and their potential
impact on human health and the environment. This paper focuses
on waste incineration as a case study of the issues facing
policymakers trying to balance the need to reduce our dependence
on landfills, which are a potential source of groundwater
pollution, with the need to minimize air toxics and their
potential impact on human health and surface water ecosystems.
The State of Current Solid Waste Management Policy. A
concept known as integrated waste management is the commonly
accepted plan among public officials and solid waste
professionals for dealing with our waste management needs today.6
The integrated approach to management encourages implementation
of a mix of management alternatives, including waste reduction,
recycling, waste-to-energy, solid waste composting and
landfilling. This approach contemplates that varying factors in
different communities dictate different disposal needs and
feasible alternatives. For example, high water tables in
Michigan and Florida may limit the practicality of landfilling.
In more populated states, such as New Jersey and New York, the
limited availability of land and high population densities
discourage landfilling. By contrast, landfilling may make sense
in those states with an abundance of land, sparse population and
low water tables.
The U.S. Environmental Protection Agency (EPA) endorsed the
integrated waste management approach in its 1991 Agenda for
Action.6 The EPA established a list of waste management options
starting in order of preference: waste reduction, recycling,
solid waste combustion and landfilling. The EPA stated that
solid waste combustion played and will continue to play an
important role in the EPA's integrated waste management approach
because the entire solid waste stream cannot be reduced through
source reduction and recycling. The EPA encouraged communities
to choose the mix of solid waste options that are most
appropriate considering local economic, environmental and other
In addition to this federal policy, many states have enacted
legislation which adopts the integrated waste management approach
through a preference list similar to that of EPA's. Some states
have included solid waste composting in the preference list at
the same preference level as combustion.
The integrated waste management approach recognizes source
reduction and recycling as essential components of planning any
waste-to-energy facility. This approach favors appropriately
sizing waste-to-energy plants so that they are designed to
process only the amount of waste remaining after recycling and
In 1991, the European Community also adopted a hierarchy of
municipal solid waste management alternatives similar to the
EPA's. The Community's directive states that appropriate
measures shall be taken to (1) prevent or reduce waste production
and (2) recover waste by means of recycling, extraction of
secondary raw materials or the use of waste as a source of
The challenge for local government is to choose the mix of
alternatives which are not only environmentally sound but also
consistent with other economic and social factors within the
Background on Incineration. There are two types of solid
waste incinerators: the waste-to-energy incinerator, which
captures heat produced from burning garbage, and the non-energy
recovering incinerators. Incineration is an attractive option to
reduce the need for landfills because it results in approximately
a 90 percent volume reduction and a 75 percent reduction by
weight in the solid waste stream.13
There are two types of waste-to-energy plants: mass burn
and refuse-derived fuel. A mass burn plant burns bulk garbage.
Heat is captured to generate steam which in turn can be used in
numerous commercial applications including the production of
electricity, generation of process heat for industrial operations
or in district heating or cooling operations. The refuse-derived
fuel (RDF) facility processes garbage into a intermediary fuel in
the form of a pellet or fluff. The pellets or fluff can then be
burned in industrial or power plant boilers.
There are approximately 150 operating waste-to-energy
facilities in the United States which are estimated to burn
approximately 17 percent of the waste generated in this country
by 1995.14 There are approximately 35 non-energy recovery
incinerators operating in 1992.14 Approximately 93 percent of
waste is incinerated in waste-to-energy incinerators instead of
non-energy recovery plants and that trend is expected to
continue.4 The energy produced from waste-to-energy facilities,
excluding RDF facilities, is approximately 2,500 me awatts which
can provide electricity to power 1.3 million homes.
Thirty-four states have operating waste-to-energy plants
with a majority of the facilities being concentrated in the
northeast and the south.14 All but two states in the midwest
region have operating waste-to-energy facilities while 10 states
in the west do not, primarily those states which have an
abundance of land available for landfilling such as Idaho, South
Dakota, North Dakota, Nevada.14
The International Scene. Europe and Japan have generally
been well ahead of the U.S. in solid waste management planning
because of the lack of landfill capacity and the inability to
site landfills in these densely populated countries.
Incineration as an alternative has been relied on heavily in
Europe and Asia for some time. For example, in Denmark,
approximately 70 percent of the domestic waste is burned.13 In
France, approximately 35 percent of the municipal solid waste is
combusted.3 In Switzerland, approximately 75 percent of all
municipal solid waste is burned at 40 combustion facilities.13
In 1987, approximately 73 Percent of Japan's waste which was not
recycled was incinerated.'
Regulation of Incinerators. Incinerators produce a variety
of air emissions including sulfur dioxides (SOg), hydrogen
chloride (HC1), particulates, carbon monoxide, (CO), dioxin,
mercury, and nitrous oxides (NOx).
Air emissions from incinerators are regulated on both a
state and federal level. On the federal level, after years of
study, the EPA issued final rules in 1991 regulating the air
emissions from municipal solid waste combusters.' The rules
identify standard requirements for combustion practices and
require installation of pollution control equipment. The
standards require all affected incinerators to meet emission
limits for particulate matter, dioxin, sulfur SO2, HC1, CO and
Both state and federal rules require the installation of
pollution control equipment to minimize the emission of
pollutants. All affected incinerators are required to achieve an
80 percent reduction in SO2 emissions and a 95 percent reduction
in HC1 emissions. According to the EPA, nationwide emissions of
SO and HC1 are expected to be reduced at an overall control
efficiency of about 94 percent.1 The rules also require all
types of affected incinerators to meet a NOx emission limit and a
dioxin limit which represents an overall control efficiency of
about 99 percent.' Metal emission reductions of about 99 percent
for all metals except mercury are expected. The standards
require that there be continuous emission monitoring on SO2, NOx
The EPA requires the installation of a spray dryer/fabric
filter and denoxification equipment to meet a best available
control technology standard.1 Scrubbers or spray dryers are
installed to control emissions of acid gasses such as SO2 and
HC1. The flue gasses from the incinerator flow through a vessel
where they are "scrubbed" through the addition of lime into the
scrubber. A chemical reaction occurs in the scrubber vessel
between the lime and acid gasses which is effective for the
removal of SO2 and HC1 and also dioxin.
After leaving the scrubber, the gases flow through another
pollution control device called a fabric filter or baghouse.
This equipment is essentially a system of filters which collects
particulate matter. Electrostatic precipitators were commonly
used in the past for removal of particulates through a process of
electrical charging. This technology has for the most part been
replaced by the fabric filter technology because the fabric
filter technology is more efficient and can be used on smaller
The federal rules also require the installation of
denoxification equipment which is effective at removing NOx from
flue gas through the injection of ammonia gas into the furnace
which reacts with NO to form nitrogen.' The nitrogen is emitted
into the atmosphere with no environmental impact.
An activated carbon system is the current state-of-the-art
mercury control device. In this system, activated carbon is
injected into the flue gas before it reaches the baghouse and the
mercury is removed from the flue gas by adsorption onto the
carbon. A mercury removal efficiency between 47 and 97 percent
has been reported with this control technology depending on gas
temperature and carbon concentration.7'18 A variety of studies
show that dioxin is also effectively removed through the
activated carbon system.7 The EPA is also developing emissions
regulations for lead, cadmium and mercury produced from
incinerators as required by the 1990 amendments to the Clean Air
Act.8 The regulations are expected to be published in 1993. It
is expected that activated carbon will be required as best
available control technology by the EPA in its mercury
In addition to regulation at the federal level, many states
have also developed rules and regulations specific to emissions
from incinerators. Some states like Minnesota are proposing
regulations which are more strict than the federal regulations.
Mercury. Dioxin and Ash The Debate. Most of the debate
over the environmental impacts of incinerators focuses on the
generation of mercury, dioxin and ash.
Mercury. Municipal solid waste incinerators emit mercury as
a result of combusting waste materials containing mercury.
Mercury is not a known carcinogen but with prolonged
exposure it can cause kidney damage and affect the central
nervous system causing headaches, irritability, depression,
insomnia, memory loss and decreased motor coordination." These
health impacts have prompted the numerous fish consumption
advisories issued in recent years because of the elevated levels
of mercury in fish.
Reports indicate that the Great Lakes region and south
Florida have suffered the nation's most serious mercury
contamination.10 In the Florida Everglades, a large percentage
of large game fish have mercury levels in excess of Food and Drug
Administration action standards.10 Large mouth bass in
southeastern Florida contain elevated levels of mercury.10
Minnesota has issued mercury advisories for over 300 lakes and
rivers in the Boundary Waters canoe area.10 There are mercury
fish advisories that cover all of Michigan's inland lakes.10
In addition to the public health concern, elevated mercury
levels also affect fish and wildlife health and their
reproductive success.10 Mercury in the food chain bioaccumulates
when birds and wildlife at the top of the food chain consume fish
or small mammals which eat fish with elevated levels of mercury
in their bodies. In studies on panthers, loons, mink, otters and
eagles in studies in different parts of the country, there is
evidence of elevated levels of mercury and associated diminished
As a result of the concern about mercury, those sources that
emit mercury into the environment, such as incinerators, have
undergone stricter scrutiny. Although much of the mercury in the
environment is naturally occurring, there is data to suggest that
the primary source of mercury in water bodies is through
atmospheric deposition from industrial sources.4' A recent
report sponsored by the Florida Department of Environmental
Regulation found that natural mercury sources are estimated to
emit about 40 percent of the total estimated mercury emissions in
the state with a majority being from soil degassing.4 The
remaining 60 percent of mercury emissions are from manmade
sources. The report estimates that 14.6 percent emissions are
from resource recovery facilities, 10.7 percent from the
electrical utility industry, 14 percent from medical waste
incinerators, 11 percent from paint application and 5.9 percent
from electrical apparatus.4 A similar study conducted in
Minnesota indicated that approximately 27 percent of the state's
mercury emissions were from coal combustion, 20 percent from
paints and 11 percent from solid waste incineration.3 17
Minnesota's projections of the amount of mercury emissions from
waste incineration goes down to 1.7 percent after it implements
its battery removal program through recently adopted
legislation.17 This estimate is based on EPA's calculation that
approximately 88 percent of the mercury in the waste stream is in
the form of household batteries.5 Minnesota's legislation
requires the removal of mercury in alkaline batteries and imposes
a ban on sales and distribution of nonrechargeable button
batteries containing more than 25 milligrams of mercury.16
A recent battle over the construction of a new incinerator
in Florida, in light of the elevated mercury levels in Florida
lakes, is indicative of the type of debate which is occurring on
this issue. The U.S. Fish and Wildlife Service (FWS) recently
completed a review of the proposed incinerator in Lee County,
Florida. Because of the great concern over mercury contamination
in Florida in light of elevated levels of mercury in fish and
wildlife, the FWS did a comprehensive review of the impact of the
incinerator on federal threatened and endangered species,
including the Florida panther. The FWS concluded that the
mercury emissions from the facility were not likely to adversely
affect the endangered Florida panther or other federal listed
threatened or endangered species.21 The FWS supported this
statement by finding the proposed facility would actually reduce
current mercury emissions by capturing the mercury in the solid
waste in the activated carbon pollution control system proposed
to be installed at the facility.21 The FWS found because the
carbon injection system bonds with mercury, the carbon-mercury
bonded particles are not available to the environment. In
addition, the FWS found the proposed facility would not generate
additional mercury but would more effectively remove mercury that
would otherwise be released into the atmosphere if deposited in
the Lee County Landfill.21 This is so because the carbon
injection system is believed to capture 90 to 95 percent of the
mercury that otherwise would have entered the environment if it
would be dumped at a landfill. Presumably the FWS relied on
evidence which suggests mercury in the waste stream would
volatilize and release its emissions into the air if not
contained. The Lee County facility has subsequently received the
necessary approvals to start construction.
Dioxin. Dioxin is emitted from waste incinerators when
chlorine and organic matter are subject to high heat. Dioxin is
also generated by many industrial processes, including paper
production, metal smelting and herbicide production and
application. While dioxin's use has declined in recent years, it
is a pervasive chemical and one that is carried in the fat of all
The debate over dioxin has continued for the past 20 years.
Dioxin was believed to be at one time the most carcinogenic
compound known.2 It was the component of Agent Orange which was
believed to have caused the high cancer incidence in returning
Viet Nam veterans. In addition, there is a very strong
correlation between cancer in laboratory animals and exposure to
dioxin, although this same correlation at low levels in unclear
in humans. As a result, the United States has the world's
strictest limit for the dioxin in drinking water and the lowest
recommended limit for the average person's daily consumption.2
Industry has persistently argued that the standards, particularly
for water, are not supported by scientific data and are much too
expensive to meet.
In a study sponsored by the EPA, a panel of scientists are
reassessing dioxin health affects in light of new studies.
Preliminary results of this reassessment were recently issued.
The panel suggests that the risk to chemical workers handling
compounds containing dioxin and effects on reproduction and
behavior in animals is greater than once expected.2 19 However,
the primary risk to the average American is exposure principally
by eating beef and dairy products and this risk is lower than
previously believed.2' 19
Dioxin produced from incinerators has also been the subject
of debate in Europe. In 1986, a temporary moratorium was placed
on new municipal solid waste incinerators in Sweden because of
concern over dioxin. The moratorium was lifted after two years
when studies determined that dioxin emissions were minimized to
protective levels with the use of modern air pollution control
Ash. The combustion of solid waste leaves a residue in the
form of ash. The components or chemical characteristics of the
ash are directly related to the levels of contaminants in the
waste materials that are combusted. Because of the presence of
mercury and other heavy metals within the waste stream, the waste
ash also has elevated levels of heavy metals such as cadmium and
lead which is of concern because of its potential to leach and
cause groundwater pollution if disposed at a landfill.
There has been an ongoing controversy among the regulators
and the courts with regard to the proper method of ash disposal.
The federal courts reached two conflicting decisions in suits in
New York and Chicago on whether or not the ash should be managed
as a hazardous waste. The cases have been appealed to the U.S.
Supreme Court. The question is whether the ash should be treated
as a solid waste which can be disposed of in a standard Title D
municipal solid waste landfill or whether it should be regulated
as a hazardous waste and disposed of as a hazardous waste.
In September 1992, the EPA issued a memorandum exempting
municipal solid waste ash from hazardous waste regulation.1 EPA
stated that this policy was consistent with its interpretation of
the legislative history and the statutory goals embodied within
the Resource Conservation and Recovery Act (RCRA). This policy
was also supported by data collected from tests across the
country conducted on waste ash from incinerators which show that
in most cases the ash and ash leachate is nonhazardous under EPA
guidelines. This recent EPA guidance is expected to be
dispositive of the Supreme Court case.
Citizen Involvement and Politics. Environmental concerns
are at the core of the public reluctance to support solid waste
disposal alternatives. The major environmental concerns
expressed by opponents of incinerators focus on emissions of
dioxin, mercury and ash. Opponents of incinerators also argue
that recycling and incineration are incompatible because
incinerators will consume recyclable materials that might
otherwise be recycled. In addition, the "not in my backyard", or
NIMBY, sentiment has been prevalent in the siting of all solid
waste disposal facilities including landfills, waste-to-energy
and compost facilities.
In addition to the local opposition often manifested in the
NIMBY syndrome, several national environment groups are active in
their opposition to waste-to-energy incinerators. Clean Water
Action has been very active on a national level and has produced
two substantive research reports on mercury in the environment
pointing the finger at waste incinerators as a primary source of
mercury contamination.9' 10
Most of the citizen group and environmental group opposition
occurs during the permit or environmental review process when
decisions are made to issue or deny a permit or to conduct an
environment impact statement.
In addition to participation during permit and environmental
review proceedings, citizen and environmental groups have made
efforts on both a state and national level to seek enactment of
moratoriums on the construction of new waste-to-energy
facilities. Environmental groups were successful in bringing the
issue of a moratorium to a vote during the hearings on the
reauthorization of RCRA. The moratorium was defeated by a
sizeable margin due in large part to the opposition of public
officials and solid waste managers on a local, state and federal
level.6 The National Association of Counties, the U.S.
Conference of Mayors and the Solid Waste Association of North
America were very active in working for the defeat of the
moratorium effort arguing that incineration was a critical
component of an integrated solid waste system essential in many
State moratoriums have also been proposed in Florida,
Minnesota, New York City, New Jersey, Wisconsin, Rhode Island and
A new citizen phenomena developing is known as YIMBY/FAP -
"yes in my backyard for a price!" Communities are accepting
landfills, waste-to-energy plants and approving the import of
waste from other jurisdictions when a facility developer offers
financial benefits to the host community coupled with
demonstrating that the facility can meet all state and federal
pollution control standards.12 Financial incentives come in the
form of host community fees, construction of public improvements
and infrastructure including parks and roads and wells and a
guarantee of property values for all homeowners within a certain
distance of the facility.12
Finally, the controversy over siting solid waste facilities,
including waste-to-energy facilities, has resulted in a political
paralysis. Politicians put off planning for long term solutions
to solid waste needs because of the controversy. A new acronym
has emerged to describe this gridlock, NIMTOO for "Not in My
Term of Office."20 Meanwhile, landfills continue to reach
capacity and communities spend millions of dollars transporting
their waste great distances to avoid taking responsibility for
their own wastes in their own regions.
Solid waste management planning decisions are some of the
most difficult issues facing public policy makers today. The
debate over incineration is similar to the debate over the impact
of solid waste composting and landfilling on our water resources
and environment. The challenge to decision makers is to reach a
sound balance of the competing issues taking environmental,
social and economic factors into account.
1. 40 C.F.R. Parts 51, 52 and 60 (1991)
2. BNA. October 1, 1992. Scientists' Review of New Studies
Finds Dioxin Remains Major Health Threat.
3. ICF Kaiser Engineers. 1992. Understanding the Sources,
Trends and Impacts of Mercury in the Environment.
4. KBN Engineering and Applied Sciences, Inc. 1992. Mercury
Emissions to the Atmosphere in Florida. Prepare for the
Florida Department of Environmental Regulation.
5. Assessment of Mercury Contamination in Selected Minnesota
Lakes and Streams. 1989. Report to Legislative Commission
on Minnesota Resources.
6. Charles, M. 1992. If It's Not Broken Why Fix It? Waste
Age, November, 1992.
7. Clarke, M. 1991. A Review of Activated Carbon Technologies
for Reducing MSW Incinerator Emissions.
8. Clarke, M. 1991. Targeting Toxics in the Waste Stream.
Waste Age. May 1991.
9. Clean Water Action. 1990. Mercury Rising: Government
Ignores the Threat of Mercury From Municipal Waste
10. Clean Water Action. 1992. Mercury Warning: The Fish You
Catch May Be Unsafe to Eat.
11. Environmental Protection Agency. September 18, 1992.
Exemption for Municipal Waste Combustion Ash From Hazardous
Waste Regulation Under RCRA. Internal Memoranda.
12. Katz, M. 1990. Yimbyism is Coming, But Waste Age.
13. Kiser, J. 1992. Municipal Waste Combustion in North
America: 1992 Update. Waste Age, November, 1992.
14. Kiser, J. and Burton, B. 1992. Energy From Municipal Waste:
Picking Up Where Recycling Leaves off. Waste Age, November,
15. Levenson, H. and Wagner, K. 1990. Japan Manages Waste --
Their Way. Waste Age. November 1990.
16. Minn. Stat. 115A.9155, subd. 2 (1991).
17. Minnesota Pollution Control Agency. June 4, 1991. Mercury
Emissions in Minnesota.
18. Nebel, K. and White, D. 1991. A Summary of Mercury
Emissions and Applicable Control Technologies for Municipal
19. Schneider, K. 1992. Panel of Scientists Finds Dioxin Does
Not Pose Widespread Cancer Threats. New York Times.
September 26, 1992.
20. Specter, M. 1991. Incinerators: Unwanted and Politically
Dangerous. New York Times. December 12, 1991.
21. U.S. Fish and Wildlife Service. 1992. Fish and Wildlife
Service Completes Review of Lee County Solid Waste
Incinerator. News Release. August 7, 1992.