Recycling or Disposal?

Hazardous Waste Combustion in Cement Kilns:
An Introduction to Policy and Legal Issues Associated with
Burning Hazardous Waste in Cement Kilns 

MARK A. RICHARDSON, J.D. April 1995

A Briefing Paper of the American Lung Association
Hazardous Waste Incineration Project

TABLE OF CONTENTS

Forward

1. Introduction

2. EPA'S National Hazardous Waste Minimization and Combustion Strategy

3. Expanding Public Participation in RCRA Proceedings

4. Hazardous Waste Combustion in Cement Kilns

1. Cement kiln technology

2. Lightweight Aggregate Kilns

3. Use of hazardous waste fuel in cement kilns

4. Nature of Hazardous Waste Fuel

5. Environmental Concerns Raised by Combustion of Hazardous Waste in Cement Kilns

1. Air pollution

1. Particulate and Metals

2. Organic Chemicals/Acid Gases

2. Cement Kiln Dust (CKD)

3. Cement Products From Waste Burning Kilns

6. Regulation of Hazardous Waste in Cement Kilns

1. Boiler and Industrial Furnace Regulations under RCRA

1. Destruction and Removal Efficiency (DRE) for Principle Organic Hazardous Constituents (POHC)

2. Products of Incomplete Combustion (PICs)

3. Metals, Hydrogen Chloride and Chlorine

4. Particulate Matter

5. Dioxin-Listed Wastes

6. Other Requirements

2. Interim Status Requirements

3. Permit approvals

4. Level of Compliance with the BIF rule

5. Other Regulations

6. Overview of Rule-making - the "MACT" process

7. Major Issues Involved in New BIF Regulations

1. Classification of Hazardous Waste Combustors - General Rules vs. Specific Standards for Cement Kilns

2. Risk-based Standards vs Technology-Based Standards

3. Development of technology-based standards

4. Classification of cement kiln dust as a hazardous waste

5. Regulation of Hazardous Waste Fuel Blenders

6. Waste minimization and recycling requirements

7. Siting requirements

8. Enforcement Issues

1. Trial burns

2. Monitoring and Record-keeping

3. Operations during "upset" conditions

4. Penalties

5. Operator Training

7. Conclusion

8. Endnote References