Natick Labs' Medical Waste Incinerator

Is Medical Waste Incineration Contaminating Natick with Dioxins?

Natick Labs Air Pollution Sources

• Medical waste incinerator
• Animal waste incinerator
• Classified documents incinerator
• 1980 PCB transformer explosion
• Heating plant boilers

The Natick Labs operates a medical waste incinerator. The US EPA has identified these incinerators as America's third largest source of dioxins, the most toxic industrial pollutant ever discovered. Medical waste incinerators produce more dioxins than all paper mill boilers, industrial furnaces and boilers, cars and trucks, hazardous waste incinerators, and coal and oil burning power plants combined. The Labs also experienced a PCB-based transformer explosion at building 5 in 1980.

Since 1973 the Labs has operated a Jarvis model 150 pathalogical waste incinerator in Building 42. This was replaced with a similar unit in 1990 in the same building. The unit is permitted to burn up to 876,000 pounds per year of pathalogical waste. Another research animal waste incinerator began operation in 1973 in Building 30 and was retired in 1992. That unit also burned scintilator solvent waste which was contaminated with radioactive materials from wipe tests. An incinerator of unknown type was operated in the T25 area itself and made use of a 60 foot brick smokestack. This was probably the Building 13 classified documents incinerator.

The final remaining potential source of dioxins onsite, in addition to the waste incinerators and the PCB explosion, are the three Erie City Iron Works boilers which are permitted to burn up to 1.3 million gallons per year of fuel containing up to 1 % sulfur. When possible these boilers operate with 25,000 cubic feet per hour (max.) of natural gas. There are also three emergency generators and six space heater units at the Labs which operate from time to time.

Lake-Bottom Contamination

Dioxin-related chemicals have been found in Lake Cochituate next to the Natick Lab's T25 outfall. Microscopic analysis of lake sediment have detected likely dioxin-containing soot particles unlike those associated with traffic and normal air pollutants in the T25 outfall area.

There are very specific types of dioxins associated with medical waste incineration which are not seen in the dioxins which are associated with normal traffic and fossil fuel use. Most particularly, one sees more furans and dioxins with 5 or 6 chlorine atoms attached, versus those with 7 or 8 chlorine atoms which is more typical of fossil fuel use. (There are over 200 different types of dioxin and furan compounds. Different sources produce different mixes of these 200.)

Army Refuses Testing Requests

Despite this evidence the Army has refused to test for dioxin itself at this location. At the same time MADEP has opined that dioxins may well be the most critical chemical of concern in measuring ecological damage from the Natick Labs in Lake Cochituate. As of now, neither the USEPA nor the MADEP have required that the Natick Labs perform the simple dioxin testing at the T25 outfall area that would confirm or deny if dioxins are poisoning the lake and its wildlife. If these dioxins are present, it should be a critical priority to shut down the Medical Waste Incinerator at the Natick Labs. To fail to do so might cause dioxin contamination to inevitably return after any clean up of the T25 outfall area on the lake.

The Army blames their normal parking lot traffic for the extremely high levels of dioxin-related chemicals found in the Lake near their outfall. Yet the Army refuses to perform the one test which would definitively tell us if this were true. Your letters to Robert Campbell of the MADEP and Jerry Keefe of the USEPA would help provide the incentive to have this critical testing performed.

Air Pollutants Exceed Permit Limits

According to USEPA AIRS/AFS data for 1997, the Labs annually emits 21,600 pounds of nitrogen oxides; 2,120 pounds of respirable particulates; 24,000 pounds of sulfur dioxide; and 2,380 pounds of volatile organics from its nine smoke stacks, including the medical waste incinerator. This figure exceed the Labs state air permit level of 1 ton per year of volatile organics.

These figures are in addition to the approximately 26,000 pounds of other hazardous waste generated annually. This waste includes bulk shipments of PCE, mercury, silver, flammable solvents, contaminated groundwater, and lab packs. (1991 - 1995 BRS data) For more information check the Massachusetts Medical Waste Incineration Alert.

What are the Health Effects of Dioxin Exposure?

From,"America's Choice - Children's Health or Corporate Profit - The American People's Dioxin Report, Technical Support Document, November 1999, Center for Health, Environment and Justice - Falls Church, VA. The newest studies on dioxin's effects on human health lead to the following conclusions:

• All American children are born with dioxin in their bodies. The greatest impact of this exposure appears to be to the growth and development of children. Disrupted sexual development, birth defects and damage to the immune system may result.

• Dioxin exposure has been associated with IQ deficits, increased prevalence of withdrawn/depressed behavior, adverse effects on attentional processes, and an increase in hyperactive behavior in children. These effects have been documented in 42-month old Dutch children whose exposure to dioxins and PCBs came primarily before birth. The children's mothers were exposed to "background" levels of dioxins and PCBs as a result of the daily ingestion of dioxin in food.

• Dioxin exposure has been associated with alterations in immune function including increased susceptibility to infections and changes in T-cell lymphocyte populations. These effects have been reported in 42-month old Dutch children exposed to dioxins and PCBs primarily before birth. Altered immune function, reported at birth, 3, and 18 months of age, persists to 42 months of age in these children. Reported immune effects included an increase in middle ear infections and chicken pox, and a decrease in allergic reactions.

• There is evidence of both developmental and reproductive effects in children exposed to dioxin. These effects include defects in permanent teeth, adverse effects on thyroid hormones, altered sex ratio (more females than males), and increased respiratory infections.

• Hormonal effects associated with dioxin exposures in humans include a decrease in testosterone in dioxin-exposed workers and a decrease in thyroid hormones following prenatal exposure to background levels of dioxin in infants.

• Dioxin interferes with the hormone insulin and alters glucose tolerance which leads to diabetes. New studies of soldiers exposed to Agent Orange and residents of Seveso, Italy add to the existing evidence from studies of workers that exposure to dioxin increases the risk of developing diabetes.

• The average daily intake of dioxin in food poses a substantial cancer risk to the general American population. The lifetime risk of getting cancer from exposure to dioxin is 1 in 10,000 for the general American population and 1 in 1,000 for highly exposed members of the population. These risks are 100 and 1,000 times higher, respectively, than the generally "acceptable" one-in-a-million cancer risk for carcinogens.

• Updates of ongoing studies of cancer rates in dioxin-exposed workers in the U.S. and Germany, and in residents of Seveso, Italy all indicate increasing cancer rates in the highest exposure groups. These studies provide strong support for the decision by the World Health Organization's International Agency for Research on Cancer (IARC) to define dioxin (TCDD) as a "known human carcinogen." This decision is further supported by evidence from animal studies and data on dioxin's mechanisms of action in the body.

• Nearly all Americans are exposed to dioxin through ingestion of common foods, especially meat and dairy products. Dairy cows and beef cattle absorb dioxin by eating dioxin contaminated feed crops. The crops become contaminated by airborne dioxins that settle onto soil and plants. Dioxins enter the air from thousands of sources including incinerators that burn medical, municipal, and hazardous waste, chemical processing facilities that use chlorine to make products such as pesticides and PVC plastic, and metal refining and smelting operations.

• The average daily intake of the American people is already well above two federal guidelines for "safe" exposure. The American average daily intake is more than 200 times higher than the Environmental Protection Agency's cancer risk guideline and over twice the Agency for Toxic Substances and Disease Registry's lowest adverse effect level.

• Some groups of people are at higher risk of exposure to dioxin. These groups include children, nursing infants, some workers, people who eat fish as a main staple of their diet, such as some indigenous peoples and fishermen, and people who live near dioxin release sites. These groups of people are likely exposed to at least 10 times as much dioxin as the general population.

• The average daily exposure of dioxin and dioxin-like chemicals in the U.S. is approximately 3-6 pg TEQ/kg body weight per day. Nursing infants ingest about 50 times this much each day.

• Dioxin accumulates in biological tissue. The average tissue or "body burden" level of Americans ranges from 36 to 58 ng TEQ/kg lipid (36-58 ppt). Approximately 10% of the population may have tissue levels as much as three times higher than this level.

• There is a small difference between the body burdens of dioxins that cause adverse non-cancer effects in animals and average levels in the general human population. Some people who have above average levels are already suffering from the adverse effects of exposure to dioxin.

• While TCDD is the most toxic form of dioxin, 90% of the total toxicity resulting from exposure to dioxins is due to dioxin-like compounds other than TCDD.

• There is an extensive body of high quality, published information on the toxicity of dioxin. This body of data indicates that dioxin is a potent toxin which produces a wide variety of adverse effects in animals and that some of these effects are likely already occurring in people.

Dioxin is an ubiquitous poison that is in our food and causes many toxic effects in people and animals. The neurodevelopmental and reproductive effects observed in children may be the most disturbing new evidence of dioxin's toxicity. These small shifts in cognitive ability or thyroid levels may be just the tip of the iceberg of our understanding of the impact of dioxin on the general American population.

Related Sites

U.S. Army CHPPM Hazardous and Medical Waste Program

Massachusetts Medical Waste Incineration Alert

Center for Health, Environment and Justice The American People's Dioxin Report