This document is a briefing memo which describes how the burning of hazardous waste in cement and aggregate kilns is regulated. This memo was developed as part of the American Lung Association's Hazardous Waste Incineration Project.
For over 30 years, the American Lung Association has been in the forefront of efforts to protect clean air, control air pollution and ensure that federal and state standards protect the public from deleterious air contaminants.
One part of this effort has involved advocacy on the control of toxic and hazardous air contaminants from a variety of sources. The Association has been an advocate for pollution prevention policies and tiered approaches to municipal solid waste management planning that encourage recycling and emphasize waste combustion as the option of last resort. The Association has advocated stringent best available control technology requirements for municipal solid waste incinerators.
The Association believes that stringent federal and state standards to control emissions of toxic air contaminants, implementation of the Clean Air Act's requirements for Maximum Available Control Technology (MACT), and effective public participation requirements are essential to protect the public's health and environment from the incineration of hazardous waste.
The American Lung Association's Michigan constituent, the American Lung Association of Michigan, began work on the issue of cement kiln hazardous waste incineration in 1991. The work involved ensuring that waste burning kilns in that state complied with federal and state law.
In this document, Mark A. Richardson, an Attorney in the private practice of environmental law, describes how hazardous waste burning in cement and aggregate kilns is presently regulated and potential avenues for citizen participation in how hazardous waste burning is regulated and controlled.
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