General comments on ALAPA policy applicable in this case:

1. As a public health agency, ALAPA characteristically takes a conservative approach to issues concerning air quality, an approach that has been vindicated by our increasing understanding of the seriousness of respiratory health effects at what would at one time have been considered "low" or "acceptable" levels. This case is no exception.

2. While any individual might be susceptible to the effects of exposure to air pollutants, ALAPA is especially concerned that attention be paid to the potential for exposure and adverse health effects among people in vulnerable populations living in proximity to the facility. High-risk groups include children, the elderly, and persons with asthma and other existing chronic lung disease and heart disease. While many of these will live distributed among the general population, the proximity of uses such as schools, residential communities and health care and personal care facilities to the operation should be carefully considered.

3. The American Lung Association calls for environmental justice: ALAPA supports the equitable treatment of all people with respect to the formulation, execution, enforcement and impact of all health and environmental laws and policies and the location of facilities. All people are entitled to clean air and are to be free of the health effects of indoor and outdoor air pollution. We will work to reduce the disproportionate share of the nation's environmental health burden borne by many economically disadvantaged and politically disenfranchised communities.

4. As a general principle on waste disposal, ALAPA supports reducing the environmental impact of refuse by: first, reducing the use of materials in production, packaging and purchasing; second, reusing materials whenever possible; and third, recycling or composting as much of the remainder as possible. The American Lung Association urges the use of safe non-combustion alternatives to dispose of all remaining waste. If combustion is used, we recommend source separation, maximum achievable control technology on all facilities, and specific monitoring of air quality within the general plume fall zone.

Specific comments for the case of the Harrisburg incinerator; several issues bear closer examination:

1. Recognizing that emissions opacity can serve as a rough surrogate for particulate matter, and noting that the incinerator has posted several violations of the emissions limits for opacity over the past few years, we believe it is important to express concerns here. Particulate matter smaller than 10 microns or less (PM₁₀) is known to be more hazardous than larger particles because, for one thing, smaller particles have access to the farthest reaches of the airway, and to the tiny air sacs known as alveoli where lung self-cleaning mechanisms are less efficient. The Health Effects Institute, funded both by industry and by the U. S. Environmental Protection Agency (EPA), published a study in April, 2000, based on data from nearly 100 cities, in which it concluded that the "results … are generally consistent with an average approximate 0.5% increase in overall mortality for every 10 micrograms/m³ increase in PM₁₀ measured the day before death." And just last summer, American Lung Association President John M. Coruthers, Jr., issued a statement commenting on the Health Effects Institute's release in July of a reanalysis of two long-term epidemiological studies upon whose findings EPA relied to conclude that PM_2.5 (fine particulate matter) was hazardous to health. Coruthers said, "This independent reanalysis vindicates EPA and shows we can improve and lengthen people's lives by reducing air pollution. The longer we wait to take action, the more unnecessary deaths will occur."

2. Dioxin:
   1. More than four years ago, the International Agency for Research on Cancer recognized the 2,3,7,8-TCDD congener as a Class 1 (known human) carcinogen. Other potentially adverse effects have been reported to be associated with exposure to dioxin and related compounds in human populations at or within an order of magnitude of average background population levels. These include delay of developmental milestones, impacts on immune function, interference with regulatory hormones, precipitation of reproductive disorders, and, perhaps, increased incidence of or susceptibility to disease, such as adult onset diabetes.

   2. While much has been made of seemingly how little dioxin - "only nanograms per cubic meter" - is created by the facility, we would stress two points:

      1. Continue to bear in mind that the new federal standard for dioxin for every other facility of this size using electrostatic precipitation for air pollution control is set at 60 ng/dscm - a factor of 15 to 30 times below which the incinerator typically operates, presumably under ideal or near-ideal test conditions, and conveniently a factor of 25 times below the artificial standard of 1500 ng/dscm. Nevertheless, the Harrisburg incinerator appears to be having trouble meeting even this ridiculously lax emissions limit.

      2. Assuming that the dioxin emission concentrations measured over the last several years (on the order of 1000 ng/dscm) are typical, then we would expect the incinerator to produce something in the vicinity of a pound or two of dioxin per year. If that still sounds like a small amount, recognize that this one facility produces on the order of magnitude of a billion times the dioxin intake of an average U. S. adult, that dioxin persists in the environment, and that the American diet accentuates its bioaccumulative properties.

3. Given the frequency and the seriousness of the infractions over the history of the facility, including over the most recent several years, resulting in over $100,000 in fines, even subsequent to the January 13 restart conditions, we would suggest that there is little reason to express confidence that future conduct of the facility will be markedly improved.

4. Given this history and the actual amount of waste processed by the facility in its recent years of operation, we are dismayed that concessions are being made to accommodate the facility's inability to meet the December 19, 2000, operating standards. Why is this being done instead of protecting public health, when even the EPA recognizes that "there is no doubt that [this facility] is one of, and perhaps, the most significant single source of dioxins/furans in the United States"?

Therefore, ALAPA's conclusions, at this stage of review, are as follows:

1. The facility operator, the Harrisburg Authority, should provide information, to the satisfaction of local residents, as to the identity and quantity of the emissions from the facility.

2. The DEP should disclose to the public and explain the findings of all of the emissions tests conducted since January 13, 2001. This disclosure should include not only raw data on which analysis was based, but also results of all tests, including those that were conducted evaluating emissions of cadmium, lead, and mercury.

3. Area residents have a right to know what they are breathing now and will be breathing under the proposed permit. These citizens should receive results of a credible analysis showing how the proposed maximum permitted emissions allowances compare to the requirements of federal regulations that took effect in December, how they translate into airborne concentrations of these pollutants for maximally exposed individuals, and how those values compare with health-based air quality standards, including the Environmental Protection Agency's (EPA's) PM₁₀ and PM_2.5 particulate standards.

4. ALAPA recommends that this facility be operated, if at all, only under a permit that ensures that it meet the most recent standards of maximum achievable control technology, and that sufficiently comprehensively and frequently monitors air quality downwind of the facility. Therefore the requested plan approval should be denied.

Kevin M. Stewart
Director of Environmental Health
American Lung Association of Pennsylvania
630 Janet Avenue
Lancaster, PA 17601-4584
(717) 397-5203
kstewart@alapa.org