Recovering Energy from fuel quality hazardous wastes is stringently regulated.
USEPA stringently regulates emissions of hazardous air pollutants from hazardous waste combustors, such as cement kilns. In accordance with the Clean Air Act, these Maximum Achievable Control Technology (MACT) emission limits are set at the levels achieved by the best-performing technologies in each source category and they regulate emissions of many hazardous air pollutants, including metals and chlorine, at very low levels.
The Cement Industry has been very successful reducing and controlling its emissions.
Over the years, the cement industry has made significant investments in research to understand the nature of its emissions and as a result has succeeded in learning how to control and reduce those emissions. For example, since 1990, dioxin emissions from kilns that recover energy from hazardous waste have been reduced by 99.3%. The cement industry’s research, which was corroborated by USEPA research, also revealed that the formation of dioxins occurs in a post-combustion reaction that is unrelated to whether a kiln uses hazardous waste as fuel.
The quality of cement product and the environmental properties of cement kiln dust by-product are unaffected by the type of fuel used to fire the kiln.
In 1995, USEPA considered the question of whether cement product quality was affected by the use of waste-derived fuel (WDF) and concluded that "It is not substantiated that burning WDF increases risks posed to end users of cement." (USEPA response to TSCA petition - Fed. Reg. July 24, 1995.) USEPA also extensively investigated cement kiln dust and concluded in 1993 that cement kiln dust is a high volume/low toxicity material that is not significantly affected by the use of alternative fuel. (Report to Congress on Cement Kiln Dust, Vol. 1, December 1993)
The Process of Recovering Energy from Secondary Materials is Protective of Human Health and the Environment.
In developing the current Clean Air Act (CAA) Maximum Achievable Control Technology (MACT) standards which our facilities comply with, USEPA evaluated the protectiveness of the energy recovery process. USEPA determined that the combination of the MACT standards plus an evaluation of whether a site specific risk assessment is needed “meets the requirements under RCRA Section 1006(b) that such standards be protective of human health and the environment.” [Final Rule Preamble, 70 FR 59510-59512, No. 196 (October 12, 2005)]