Recycling or Disposal? 
Hazardous Waste Combustion in Cement Kilns 

VIII. Endnote References

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1. Cement and aggregate kilns are classified as "industrial furnaces" under federal regulations. An industrial furnace is defined as any specified enclosed device that is an integral component of manufacturing processes and that uses thermal treatment to accomplish recovery of materials or energy. 40 C.F.R. Sec. 260.10, 260.32 (1991)

2. USEPA Memorandum, Application of Enhanced Public Participation and Stronger Combustion Permitting Requirements, USEPA Doc. No. 530-F-94-017, May 23, 1994

3. Kleppinger, Edward, "Cement Clinker: An Environmental Sink for Residues From hazardous Waste Treatment in Cement Kilns" Waste Management, Vol. 13: p.p 553-572, 1993

4. "Fears Rise Over Wastes As Fuel in Cement Kilns," N.Y. Times July 6, 1993

5. DRAFT Combustion Emissions Technical Resource Document (CETRED), EPA 530-R-94-014, May 1994, Office of Solid Waste and Emergency Response, U.S. Environmental Protection Agency, Washington, D.C. Comparison of Emissions Between Cement Kilns and Hazardous Waste Incinerators (Table), Association for Responsible Thermal Treatment, Washington, D.C. December 8, 1993

6. Comments of Rollins Environmental Services, Inc., on the EPA Report to Congress on Cement Kiln Dust, March 8, 1994, USEPA Docket No. F-93-RCRA-FFFFF

7. USEPA, Doc. No. 530-F-93-015, Hazardous Waste Boilers and Industrial Furnaces (BIFs) July 1, 1993.

8. Protecting Human Health & the Environment While Using Hazardous Waste Fuels in Cement Kilns, Systech Environmental Corporation, April, 1994

9. Draft Strategy for Combustion of Hazardous Waste, May, 1993, USEPA Doc. No. 530-D-93-001

10. Draft Strategy for Combustion of Hazardous Waste, May, 1993, USEPA Doc. No. 530-D-93-001. Between May, 1993 and February, 1994, EPA had initiated administrative enforcement proceedings actions for BIF rule violations against 6 BIFs located in the midwest, a civil complaint against a BIF located in Pennsylvania, and an administrative complaint against a BIF located in California. Draft Strategy for Combustion of Hazardous Waste, Interim Report, May, 1994.

11. Environmental Fact Sheet, Source Reduction and Combustion of Hazardous Waste, USEPA Doc. No. 530-F--93-010

12. USEPA Memorandum: Application of Enhanced Public Participation and Stronger Combustion Permitting Requirements, USEPA Doc. No. 530-F-94-017, May 23, 1994

13. RCRA Expanded Public Participation and Revisions to Combustion Permitting Procedures, Proposed Rule, 59 F.R. 28680, June 2, 1994

14. Draft Combustion Emissions Technical Resource Document (CETRED), USEPA Doc. No. 530-R-94-014, May, 1994, p. 2-2.

15. CTRED, p.p. 2-19, 2-21.

16. All Fired Up - Burning Hazardous Waste in Cement Kilns, Environmental Toxicology International, Inc., 1992

17. Kleppinger, Cement Kiln Incineration of Hazardous Waste, January, 1994, p. 8.

18. USEPA Office of Solid Waste and Emergency Response, Combustion Emissions Technical Resource Document (CETRED) Executive Summary, May, 1994

19. Section 1004 of the Solid Waste Disposal Act (RCRA) defines "solid waste" as "any garbage, refuse, sludge from a waste treatment plant, water supply treatment plant, or air pollution control facility and other discarded material, including solid, liquid, semisolid, or contained gaseous material resulting from industrial, commercial, mining, and agricultural operations, and community activities, .... ." 42 U.S.C. 6903(27). Certain materials not relevant here are excluded from this definition. Solid waste under RCRA thus includes both solid and liquid hazardous wastes.

20. According to the 1987 Toxics Release Inventory (TRI) prepared pursuant to the Emergency Planning and Community Right to Know Act (EPCRA), the top five waste materials shipped off-site for "reuse as fuel" in 1987 (the only year for which such data is available) were toluene, xylene, methyl ethyl ketone, acetone and methanol, all of which are industrial organic solvents. The EPA exempted the reporting of off-site transfers of hazardous waste for "recycling" or "reuse" from the TRI in 1988.

21. All Fired Up - Burning Hazardous Waste in Cement Kilns Environmental Toxicology Institute, Inc., 1992.

22. Kleppinger, Edward, "Cement Clinker: an Environmental Sink for Residues From Hazardous Waste Treatment in Cement Kilns," Waste Management, Vol. 13, No. 8, p. 558 (1993)

23. 40 C.F.R. Part 268

24. RCRA Policy Statement Memorandum: Clarification of the Land Disposal Restrictions Dilution Prohibition and Combustion of Inorganic Metal-Bearing Hazardous Wastes, Elliott Laws, Office of Solid Waste, USEPA, May 23, 1994

25. All Fired Up - Burning Hazardous Waste in Cement Kilns, Environmental Toxicology Institute, Inc., 1992.

26. All Fired Up - Burning Hazardous Waste in Cement Kilns, Environmental Toxicology Institute, Inc., 1992.

27. All Fired Up - Burning Hazardous Waste in Cement Kilns, Environmental Toxicology Institute, Inc., 1992.

28. CETRED, Tables 4.1-1, 4.2-1, 4.3-1, U.S. EPA

29. EPA missed the original deadline for completion of the study by several years. The Report was released as the result of a 1991 consent decree entered in a lawsuit brought by the Environmental Defense Fund to compel the EPA to complete the report.

30. USEPA Office of Solid Waste, Report to Congress on Cement Kiln Dust dated December, 1993 at p.3-57

31. Hazardous Waste Treatment Council Comments on EPA's Report to Congress on Cement Kiln Dust dated March 15, 1994, at p.p. 36-39.

32. A recent EPA study also found that cement kilns which burn hazardous waste dispose of 50 to 87 per cent more CKD per year on average than kilns which do not burn hazardous waste. (Personal Conversation with Bill Schoenborn, Staff Engineer, USEPA Special Waste Branch, October 11, 1994.) A possible explanation for this is that waste-burning kilns are not recycling CKD in an effort to comply with BIF Rule emissions limits. Another possibility is that there are differences between the raw materials or other factors among the kilns studied. EPA has not drawn any official conclusions as to the reason for this rather significant difference in disposal rates.

33. USEPA Office of Solid Waste, Report to Congress on Cement Kiln Dust dated December, 1993 at p.1-11.

34. All Fired Up - Burning Hazardous Waste in Cement Kilns Environmental Toxicology Institute, Inc., 1992.

35. Hazardous Waste Treatment Council Comments on EPA's Report to Congress on Cement Kiln Dust dated March 15, 1994, at p.p. 40-41.

36. Hazardous Waste Treatment Council Comments on EPA's Report to Congress on Cement Kiln Dust dated March 15, 1994, p. 40.

37. BIFs may also be subject to other requirements of the Federal Clean Air Act which apply depending in the geographic area the facility is located in, such as the best available control technology (BACT) standard applicable to major stationary sources under the Prevention of Significant Deterioration provisions (Secs. 161-169), or the Lowest Achievable Emissions Rate (LAER) standard in non-attainment areas (Sec. 171-177). New units are also subject to New Source Performance Standards (NSPS). The relationship of RCRA standards to new CAA Sec. 112 National Emissions Standards for Hazardous Air Pollutants (NESHAPs) is discussed below.

38. USEPA Office of Solid Waste and Emergency Response, Combustion Emissions Technical Resource Document (CETRED) Executive Summary, May, 1994

39. HWTC Petition for Rulemaking Under the Resource Conservation and Recovery Act to Establish Uniform National Performance Standards for All Combustion Facilities Based on The Best Available Technology, USEPA Docket. May 18, 1994.

40. EPA DRAFT CETRED Executive Summary, May 1994; Personal conversation, Fred Chanania, U.S. EPA

41. Hazardous Waste Treatment Council, "Petition for Rulemaking Under the Resource Conservation and Recovery Act to Establish Uniform National Performance Standards for all Combustion Facilities Based on the Best Available Technology," May 18, 1994.

42. USEPA Guidance to Hazardous Waste Generators on the Elements of a Waste Minimization Program, Notice, 58 F.R. 31114, May 28, 1993

43. Draft Strategy for Combustion of Hazardous Waste, USEPA Doc. No. 530-D-93-001, May, 1993

44. Executive Order 12898, February 11, 1994, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, 59 F.R. 7629, February 16, 1994

45. EPA Draft Strategy for Hazardous Waste Minimization, Combustion Document, May, 1994

46. US EPA Memorandum of Hugh B. Kaufman to William Reilly dated December 7, 1990 re: Potential Impropriety in the Development of the Boiler and Industrial Furnace (BIF) Rules to be Promulgated This Month

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