WASHINGTON,  D.C.  20460
January 12, 1994


Subject:     Columbus, Ohio Incinerator

To;            Carol Browner, Administrator

From:         William Sanjour, Policy Analyst, Office of Solid Waste

The Columbus, Ohio Solid Waste Reduction Facility, an incinerator owned by the City of Columbus, which burns trash and garbage to produce electricity, is emitting 2 kilograms per year of dioxin toxic equivalent. This is the highest emissions of dioxin of any incinerator in EPA's inventory. The cancer risk is probably on the order of 10-4, two orders of magnitude (i.e. one hundred times) greater than the level which EPA generally considers an "acceptable" risk.

The radius effected by the fall-out from the incinerator is ten to twenty kilometers (six and a half to thirteen miles). Most of downtown Columbus lies within ten kilometers and most of Columbus and a lot of suburbs, more than half a million people, lie within twenty kilometers. The State Capital is only five kilometers away and Ohio State University is ten kilometers away.

As a consequence of these dioxin emissions, dozens of people in the Columbus area die of cancer every year this incinerator is in operation. In fact the area just down the prevailing wind from the incinerator has the highest cancer rate in Franklin County. Cancer is not the only problem. Many more people are sickened or otherwise affected by the many other effects of dioxin. Pregnant women are particularly susceptible.

Reproductive and birth abnormalities can be caused by exposure to minute quantities of dioxin over a very short time. Recent experiments have shown that male rats are demasculinized and feminized when the mother is fed a single dose of dioxin, too small to do her any harm, on the fiftieth day of pregnancy. The sexual changes in the young males lasts into adulthood. Other reproductive abnormalities linked to dioxin include learning disabilities and aggressive or passive behavior. Dioxin can also affect the immune system which protects the body from attack by many other diseases.

Low levels of dioxin in food has been linked to endometriosis, a painful disease which afflicts millions of American women.

Dioxin can enter the food chain through vegetables, beef, fish and milk. There are dairies in close proximity to the incinerator as well as farms and a river, which means that the dioxin is also poisoning the milk and other food supplies. In addition, the University of Ohio experimental farms are only ten kilometers away from the incinerator.

Both the State of Ohio and the U.S. EPA are in violation of federal law for failing to protect the citizens of Columbus from this facility. The State of Ohio was required to submit an implementation plan by November 1991 (40 CFR 60.23) which would have reduced the dioxin emissions to 60 nangrams per standard cubic meter (ng/scm), from the current value of 17,892 ng/scm (40 CFR 60.36a). The state failed to do so. In the event of the state failure, EPA is required by law (40 CFR 60.27) to issue its own implementation plan. EPA has also failed to comply.

The excuse given for these failures is that the Clean Air Act of 1990 requires "maximum achievable technology" which EPA believes would be 30 ng/scm or less. The regulations to implement this requirement are very very slowly slogging their way through the maze of the federal bureaucracy. (The process is a lot like playing the child's game of "Chutes and Ladders" stretched out over years.) It is estimated that at the current pace, the new standards would not be implemented before the next century. In the meantime nobody, not the State of Ohio nor the U.S. EPA is implementing any standard.

EPA estimates that after the Clean Air Act of 1990 is fully implemented in the next century the 160 existing incinerators should collectively be emitting less than 200 grams per year of dioxin. Yet this one plant is currently putting out 2000 grams per year or ten times what Congress in the Clean Air Act considered necessary to protect the environment from all incinerators.

Thus the people of Columbus will have to live (and die) with 17,892 ng/scm because the State of Ohio and the U.S. EPA do not wish to inconvenience the incinerator operator to meet a 60 ng/scm standard when a 30 ng/scm may be in the offing some time in the future. (Of course the incinerator operator could have voluntarily installed equipment to reduce the emissions to 30 ng/scm, a standard already met by half the incinerators in America.)

This is yet one more example of the policy that EPA frequently follows of placing the interests of the polluters it regulates above the interests of the public it is charged with protecting. This is further illustrated in the way both the U.S. and the Ohio EPA handles citizen concerns about the facility. Citizens have complained on numerous occasions about black soot (which carries dioxin) coming out of the plant. But EPA accepts the word of perhaps the largest polluter of its kind in America over the word of the people EPA is supposed to be protecting from the polluter. This is analogous to a policeman calling the victim of a mugging a liar based on the testimony of the mugger.

cc: EPA Inspector General

William Sanjour's home page

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