Associate Professor Rybarczyk is back and he’s brought with him with the same tired, meritless criticisms and warnings he brings to nearly every project he wades into. Over the years, he has opposed several green projects across the Midwest, from ethanol plants to windmills to aluminum recycling facilities. His opposition to recycling facilities is particularly ironic as his only publication in his decades-long career as an associate professor is on the leaching of metals from landfills — the very thing the proposed WSP facility would prevent.
Heritage has been in the business of hazardous waste management for 50 years and just last year helped the U.S. safely manage over half a million tons of hazardous waste, successfully protecting human health and the environment from exposure to hazardous substances. Our partner in this venture, Zinc Nacional, is a global leader in zinc recycling and has processed more than 7 million tons of electric arc furnace dust (EAFD) over the past four decades at their nine Waelz kilns in the U.S. and abroad. That’s enough zinc for 65 million cars, zinc that would have otherwise had to be mined or lost to landfills.
What Rybarczyk thinks is a shortcoming of the Waelz process — the variability in the EAF dust — is likely a manifestation of his lack of experience in an industrial setting and lack of knowledge of High Temperature Metals Recovery (HTMR) processes. In reality, the EPA went through a rigorous regulatory process to determine that HTMR is the best demonstrated available technology for managing EAF dust to recover valuable metals.
Despite Rybarczyk’s unsubstantiated claims to the contrary, the makeup of incoming EAF dust is well-known and fully understood by industry and regulatory agencies. The chemistry of EAF dust is fairly consistent and informed by decades of existing zinc recycling operations.
The contents and constituent ranges of the zinc oxide and iron concentrate produced by the Waelz kiln have to meet product specifications to be used in cement, construction, and in a variety of consumer products. That’s why each and every incoming delivery of EAFD at WSP will be analyzed by X-ray fluorescence (XRF) to identify 13 individual constituents, similar to what occurs at SDR in Millport. At SDR, that’s about 320 samples and 4,160 individual analytical results every month, or 3,840 samples and nearly 50,000 individual results each year.
In addition, process samples are also taken of the EAFD as it is being fed into the kiln, every four hours, every day. The zinc oxide and iron concentrate are then sampled every four hours, every day, as they come out of the kiln. That’s another 180-186 samples gathered and 2,400 analyses produced monthly. Any batches that do not meet product specifications are routed back into the kiln.
Finally, every outbound railcar sending zinc oxide to a customer is sampled in four locations. The material is homogenized and a composite sample is analyzed for 13 constituents for another 90 samples per month. The iron concentrate is sampled 180 times a month for 16 analytes: another 3,000 results. Add those together to get an annual total of about 13,500 samples and 175,700 analytical results every year.
Unlike the LMU coal-fired power plant, which was permitted to use 190,435 tons per year — more than double the amount of coal WSP will use — and generated coal ash as a waste product, the anthracite coal used as a reductant in the Waelz kiln gets consumed in the process and becomes part of the iron concentrate product. At WSP there will be zero coal ash generated and no coal ash ponds.
In addition to the continuous opacity monitors, trained specialists provide backup for monitoring opacity. Sensors in the product collector baghouse alert operators in real time of any issues to allow for immediate shutdown. Emergency generators allow emission controls to continue operating in the event of a power outage. Specially coated product collector bags increase the capture efficiency of the process, which have been identified by U.S. EPA as the best technology for controlling emissions from facilities such as WSP.
Rybarczyk also apparently knows little of how the hazardous waste laws operate in this country. The entire foundation of the Resource Conservation and Recovery Act (“RCRA”), the nation’s primary hazardous waste law, is its cradle-to-grave tracking of hazardous waste, as clearly spelled out in 40 CFR 260-273 — that includes EAFD.
Rybarczyk’s lack of practical experience in an industrial setting shines through when he asserts that environmental regulatory agencies do not perform inspections. That is simply not true. The regulatory programs under the Clean Air Act and RCRA have been delegated to the State of Indiana to implement and enforce, with EPA oversight. Both agencies regularly perform a variety of inspections of facilities across Indiana and under the different media programs — air, waste, and water.
Rybarczyk concludes that Cass County will be “burdened” with unknowable pollution, without providing a shred of evidence to support that contention. Despite the uninformed smoke-and-mirror theatrics of a former associate professor, the Waelz process is safe, period.