TX Waste Incineration Risk Assessment

Alexander Sagady asagady at sojourn1.sojourn.com
Tue Jun 4 23:44:50 EST 1996

On May 30, 1996, the American Lung Association of Texas
released a report entitled:  
     "Evaluation of the Screening Risk Analysis for the Texas
     Industries (TXI) Faxility in Midlothian, Texas, Written by
     the Texas Natural Resources Conservation Commission and
     Other Materials Related to the Texas Industries Facility"
The report was written by Stuart A. Batterman, Ph.D., Associate
Professor of Environmental Health Sciences, Dept. of
Environmental and Industrial Health, School of Public Health,
University of Michigan; and Yuli Huang, M.S., a doctoral
candidate in the Dept. of Environmental and Industrial Health.
The report illustrates the many defficiencies of a screening risk
assessment conducted by the Texas Natural Resources
Conservation Commission concerning the burning of hazardous
waste at the TXI Cement Plant in Midlothian, TX.
Citizens who are dealing with direct and indirect risk assessments
at waste sites will find the report useful as a guide for developing
criticisms of government and industry risk assessment activity.
Copies of the full 74 page report are available for $5.00 per copy
American Lung Association of Texas
PO Box 26460
Austin, TX  78755
Please make checks payable to ALAT.
The serious deficiencies in the Screening Risk Analysis and
Summary Report indicate that the ability of the TNRCC to
conduct an objective assessment is compromised, and the record
demonstrates significant concerns regarding the effectiveness of
the TNRCC in regulating combustion of hazardous waste at TXI.
The Screening Risk Analysis and the Summary Report are useful
starting points for prioritizing future studies and actions aimed at
protecting public health and the environment.  However if viewed
as "technical support" documents to justify TNRCC declarations
of no substantial risk to public health due to pollution in
Midlothian, they must be criticized due to their many serious
omissions, inconsistencies and inadequate or misleading analyses.
Based on de novo analysis, we conclude that environmental and
health impacts have and are likely to occur in the Midlothian area
from industrial activity, including the combustion of hazardous
waste at TXI.   There is high likelihood that the environmental
and health impacts are significant, as demonstrated by exposures
and risks that greatly exceed U.S. EPA target exposure levels for
a variety of exposure scenarios and source assumptions at a large
number of sites.   Exceedances of acceptable risk levels for
children at all residential locations is especially noteworthy.
Because predicted health risks exceed target levels, continued
waste combustion at TXI requires more stringent controls, e.g.
more effective air pollution control technology, waste feed
limitations, and/or modified operating practices.
The TNRCC must be strongly criticized for its tendency to go far
beyond what is scientifically supportable by the existing data in
making sweeping generalizations regarding the present and future
safety of waste combustion in Midlothian.   Statements with little
or a frail scientific basis show a disregard for the protection of
public health, and serve to diminish the TNRCC's credibility
among the public.
Even a cursory examination reveals many inspection, enforcement
and compliance issues.

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