Hazardous waste: Who creates it? Who destroys it? 

Almost all of us produce hazardous waste. If you have a cell phone or a computer, or use batteries, unclog your drain with a drain cleaner, or equip your home with a smoke detector, or use oil in your car, or paint your house, or use pesticides on your lawn, you deal in hazardous waste. We all need a safe, responsible and highly regulated place to dispose of it. That’s what we do at Norlite. The Norlite Team helps society and our community to safely and effectively manage hazardous waste.

Hazardous wastes are created by common products that many of us take for granted: cosmetics, detergents, pharmaceuticals, household paints and cleaning products, phones, televisions, garden pesticides, computers, gasoline, and even light bulbs. They can be liquids, solids, gases, or sludges. More than 200 million tons of hazardous waste is generated in the United States each year by dry cleaners, automobile repair shops, hospitals, exterminators, chemical manufacturers and others.

The U.S. EPA has determined that, when performed properly, the elimination of hazardous waste by thermal destruction — the process Norlite uses — is the Best Demonstrated Available Technology (BDAT) for most organic hazardous waste because the process safely and effectively destroys the hazardous constituents in the waste. 

Norlite takes this beneficial process one step further: We recover the energy in the waste and use it — reducing our reliance on fossil fuels — to power our kilns, which create an environmentally beneficial product that is coveted by builders who value sustainability and energy efficiency. By safely managing and extracting the energy value of hazardous wastes, we are protecting the environment and our community while making a product that helps buildings use less energy. That’s a win-win-win.

A small number of Norlite critics continually seek to sow doubts about the safety of combustion as a means of hazardous waste management, ignoring that both federal and state environmental regulators have long permitted and vigorously oversee these activities. We asked James Berlow, a former senior U.S. EPA executive with extensive experience in the various regulations that apply to Norlite and similar operations, to explain how and why the regulations were formulated, their purpose and their effectiveness. We hope you find his analysis, found below, to be valuable and informative.

Combustion is the safest, most responsible and
most reliable treatment available for many wastes.
The evidence is indisputable.

Analysis by James Berlow

Summary: Without combustion to address toxic organic compounds, the current system for effectively managing hazardous wastes in the United States does not work.

When I joined the U.S. EPA as a staff engineer in the mid-1970s, the country was overrun with examples of poor waste management, presenting significant risks to human health and the environment. Love Canal, in Niagara County, was the most visible example of environmental degradation by industry, but it was by no means alone. 

From toxic discharges to our rivers and lakes, to contaminated groundwater and air, considerable work was needed to reduce the risk of exposure to toxic chemicals to our people, especially children and other vulnerable populations.

In the 1970s and early- to mid-1980s, Congress responded to public demands with major pieces of environmental legislation that established detailed prescriptions for addressing the risks from exposure to toxic chemicals resulting from industrial releases or use of certain products. While most of these new laws and regulations relied on science-based tools and measures known as risk assessments to establish exposure limits and health guidance, Congress recognized that court challenges and other procedural delays were inevitable as risk-based rules were parsed and debated — and wasn’t willing to wait. Instead, the EPA was directed to evaluate best available environmental control technologies currently in use, and to base its standards and limits on the premise that all facilities would adopt those best technologies.

Having implemented these new policies, the EPA was still required to evaluate whether the standards were resulting in adequate risk reductions and were consistent with EPA’s mission to protect human health and the environment. That’s where I, and people with similar skills and training, came in. My first role at EPA was to develop technology-based standards for discharges to rivers and lakes, known as effluent guidelines. I later was part of developing treatment standards for hazardous waste disposal on land and air emission standards for hazardous waste combustors.

All of us who have devoted our careers to environmental science and protection have wrestled with the treatment dilemma, a recognition that every process that requires treatment of some sort creates residuals that have the potential to impact other environmental media. Wastewater treatment, for example, can create sludges and resins that require disposal on land or volatile emissions to the air. The most technologically advanced emissions control equipment can produce traceable discharges to the air or water. Landfills must prevent leakage that might contaminate groundwater.

EPA prioritized water and air protection and tasked the agency’s hazardous waste specialists with finding the ultimate treatment for both spent materials and other wastes from industrial processes and the residuals from air and water treatment. 

EPA’s chemical experts recognized that some toxic metals were elements. That meant they could not be destroyed but only recovered or converted to compounds that were less mobile or toxic when stored in perpetuity. Recoverable metal concentrations typically were not present in wastes requiring management, and the huge volumes precluded storage in buildings or vessels, so EPA focused on making long-term disposal in landfills as safe as possible.

In addition to setting strict standards for the design, operation and maintenance of these landfills, the EPA was tasked by Congress with identifying the best demonstrated treatment options for the wastes that were sent to them.

Over many years, EPA researchers examined an array of technology options for wastes containing organics; these included combustion, distillation and chemical destruction. And while the other technologies could be useful in some limited situations, combustion was the only technology proven to work at the scale needed for broad collection while providing environmentally protective management of wastes containing toxic organics requiring treatment.

Importantly, however, EPA mandated only that the waste handler mimic the performance of combustion in terms of achieving safe management objectives, to assure that innovation for alternatives would not be stifled. 

Given the importance of combustion to the national strategy for managing hazardous wastes and recognizing the issues that had arisen with poor practices in hazardous waste combustion, EPA embarked on an initiative in the late 1990s to create national, comprehensive emission standards based on the best demonstrated combustion technologies, emission control technologies and operating practices. By statute, new sources were subject to the single best performance in the industry, while standards for existing sources (with fewer options to alter design of their facilities) were based on the results of best-in-class facilities (the top 12%, to be specific).

The results of combustion in successfully managing organics are clear: high levels of destruction (at least 99.99% destruction and removal efficiency from the air pathway, as well as low emissions of metals and other regulated materials), and emissions limits meeting national and site-specific risk assessments for each combustor to ensure compliance with EPA goals and regulations. 

The EPA continued its research, seeking to identify new organics that may have been created in the combustion process, in order to establish additional emission standards for by-product compounds that did not exist in the wastes that were fed to the combustor. These revised standards included comprehensive performance tests every five years for most regulated emissions. In the time between tests, permits specified the steps facilities were required to take to verify compliance, including continuous emissions monitoring and reporting of data to public authorities. Sensors were required to cut off hazardous waste feeds within seconds if emissions approached maximum levels set by EPA. Ten or more cutoffs a month, even if no violations occurred, triggered additional reporting requirements and a written plan to reduce the cutoffs and the remediation methods to be adopted.

Combustion of wastes containing organic compounds is an integral part of the overall strategy to manage hazardous waste disposal effectively in the United States. No other technology option for the broad categories of organic waste requiring treatment has been demonstrated to provide the high levels of destruction and low environmental impact that is provided by properly designed and operated combustion units. Combustion also supports the control of toxic air emissions and waste discharges by managing the residual wastes produced by control technologies needed to protect our air and surface waters.

EPA has ensured that combustion only is used where it is the appropriate treatment technology and that risks are minimized when it is used. To allow for alternative technologies to emerge, EPA does not generally mandate the use of any technology, it only bases performance standards on the results achieved by the best technologies.

Obviously, the ideal solution is for generators not to produce toxic wastes that require careful management. In fact, the expense of disposing of the waste consistent with EPA and state standards provides a strong economic incentive for generators to find alternative manufacturing methods that eliminate toxic waste generation. That these wastes continue to be generated, decades after the large economic incentives to reduce or eliminate them became apparent, proves that such source reduction options probably do not exist today.

Combustion is the safest, most responsible and most reliable treatment available for many hazardous wastes. The evidence is indisputable.

James Berlow is an engineer retired from EPA after 38 years of federal service with two EPA Gold Medals, numerous bronze medals, and EPA’s Distinguished Career Award. During his career at EPA, he served as the senior manager of the EPA teams producing the treatment standards for all hazardous wastes produced in the United States, as well as the air emission standards for hazardous waste combustion. Currently he is a consultant on waste management issues.