[EQAB-list] Re: Air Curtain Destructors and open burning

[Ellen Smith]

FYI to EQAB. (The cc addressed to this list was held for moderation.)

-------- Forwarded Message --------
From: Ellen Smith <smithellen at comcast.net>
Reply-to: smithellen at comcast.net
To: Charlie Hensley <chuck188 at comcast.net>
Cc: James O'Connor <JOConnor at cortn.org>, Ken Krushenski
<KKrushenski at cortn.org>, Steve Jenkins <SJenkins at cortn.org>,
agg at bellsouth.net, Jacquelyn Bernard <JBernard at cortn.org>, jane miller
<jane.miller at comcast.net>, millerdj at y12.doe.gov, dxm at y12.doe.gov,
mosby1 at aol.com, smithed at ornl.gov, tbeehan at cortn.org, thayes 37830
<thayes_37830 at yahoo.com>, mbailey at cortn.org, ldavis at cortn.org, EQAB list
<eqab-list at discoveret.org>
Subject: Re: Air Curtain Destructors and open burning
Date: Sun, 13 Sep 2009 18:14:32 -0400

Charlie: 

I don't know why the EQAB recommendation was so brief -- perhaps because
of past requests to "keep it simple". I expect that EQAB representatives
will be able to provide substantial back-up information on the reasons
for this recommendation. (Furthermore, I think there may be additional
reasons for the proposal, including our region's nonattainment status
for air quality standards for particulate matter.)

I do know that the EQAB recommendation was submitted when it was because
the board's regular monthly meeting on Sept. 3 happened too late to get
this letter into the agenda package that was distributed on Sept. 4.

Monday's meeting will hardly be the first opportunity for public
discussion of this item. Since receiving a Council referral on this
topic more than a year ago, EQAB has discussed this in several public
meetings, during which both local land developers and members of the
public have commented on various aspects. (I know this because I was at
some of the meetings, but I believe the meetings are also documented in
minutes that were provided to City Council.) Additionally (although not
in a public meeting), the topic was discussed by the Chamber of
Commerce's developer's forum. It seems to me that one of the benefits of
having advisory boards (and referring matters to them for consideration)
is that they can provide a forum for more extensive public input than
City Council can provide.

Regarding the use of air curtain destructors (ACDs), I believe your
message refers to neighboring residents' complaints about from one air
curtain destructor operation. In spite of the claims made for this
technology and the developer's best efforts, that ACD emitted smoke on a
regular basis (sometimes directed toward homes in the existing nearby
subdivision, including the home of a girl with asthma) and deposited a
layer of ash on nearby properties (for example, inside semi-enclosed
patio rooms). One of my visits to the area was on a day with favorable
meteorological conditions for burning, yet I still smelled smoke
throughout the nearby subdivision and saw both flames and a column of
smoke rising upward from the ACD. 

It is undeniably true that ACDs emit less pollution than open burning
does, but apparently there isn't a lot of good data on ACD emissions. In
2007 US EPA published a research paper that includes a review of the
technical literature on air emissions from air curtain destructors,
"Emissions from the Burning of Vegetative Debris in Air Curtain
Destructors", available online at
http://www.epa.gov/nhsrc/pubs/paperVegDebris080307.pdf . Little
published information on emissions was found. The paper is kind of
long-winded, but an interesting "Comparison of ACD and Open Burning
Emissions" begins on the bottom of page 11 of the PDF; it indicates that
ACD emissions are well below emissions from open burning, but ACDs do
emit pollutants of concern for public health. Also, the authors'
research found that ACDs didn't always behave the way the theory of
their design indicates they should behave. 

The US Forest Service has several fact sheets on ACDs (all very
similar), such as
http://www.fs.fed.us/eng/pubs/html/05511303/05511303.html (PDF at
http://www.fs.fed.us/eng/pubs/pdf/05511303.pdf ) and
http://www.fs.fed.us/t-d/pubs/html/02511317/02511317.htm . One of these
indicated that trench-type ACDs can be tricky (which seems consistent
with the experience in Oak Ridge). It says: "The trench burner can be
easily towed behind a truck to the jobsite. These units will handle more
uneven terrain than the fireboxes and can be mobilized quickly. The
trench allows the operator to easily see the fire and load the pit
without the need to raise the fuel up over the wall. The real minus for
the trench burner is in the construction of the trench. The trench must
be dug correctly or the efficiency of the ACD goes down, increasing
emissions and decreasing thru-put (burn rate). If the trench is omitted
or too shallow, the principle of the air curtain is lost. Ground and
soil conditions become a big factor. A high water table can create
flooding in the trench and cause trench walls to lose integrity if the
soil is too soft. Additional safety factors also must be considered.
Precautions must be taken to alert personnel to the pit’s location to
avoid inadvertently falling in or perching heavy loading equipment too
near the edge of the pit causing the walls to collapse." 

It's clear that Council will need to deliberate on this proposal at some
length, both in general and specifically as it applies to ACDs, but I
don't think that our full deliberation needs to happen Monday evening. 

Ellen Smith

On Sat, 2009-09-12 at 14:25 +0000, Charlie Hensley wrote:
> Fellow City Leaders:
> 
> On an issue this controversial, I feel that we should have the
> opportunity to see what reasoning and background information is behind
> the recommendation for the resolution. In the information presented, I
> see no data on economic impacts or health data to support of refute
> either side of the issue. 
> 
> If the potential open burning discussion at the meeting has the
> potential to begin a decision making process by our instructing staff
> to draw up a resolution, then developers and others who are most
> impacted, have not had adaquate notification and time to prepare their
> comments.
> 
> I have objected as strongly as anyone, in the past, to open burning,
> but also feel that the air curtain-incineration process is not
> adaquately understood. The recent problems that occurred with it's
> recent application, in Oak Ridge, resulted from some mis-understood
> process parameters, and mis-location of the burn pit. I personally
> object more strongly to wood burning fireplaces than to the air
> curtain process on construction sites. But I don't have adaquate
> information yet, either.
> 
> In my opinion, it is not appropriate to accept or reject this
> communication without the prescribed ten days of opportunity for
> public awareness.
> 
> Sincerely,
> Charlie Hensley
> 
> 
>  
> ----- Original Message -----
> From: "James O'Connor" <JOConnor at cortn.org>
> To: agg at bellsouth.net, "Jacquelyn Bernard" <JBernard at cortn.org>, "jane
> miller" <jane.miller at comcast.net>, millerdj at y12.doe.gov,
> dxm at y12.doe.gov, mosby1 at aol.com, smithellen at comcast.net,
> smithed at ornl.gov, chuck188 at comcast.net, tombee1 at BELLSOUTH.NET, "thayes
> 37830" <thayes_37830 at yahoo.com>
> Cc: "Ken Krushenski" <KKrushenski at cortn.org>, "Steve Jenkins"
> <SJenkins at cortn.org>
> Sent: Saturday, September 12, 2009 9:21:41 AM GMT -05:00 US/Canada
> Eastern
> Subject: Re: PROPOSED ADDITIONS TO 9/14/09 AGENDA
> 
> It should be noted we are accepting this as a communication and not
> endorsing anything at this point. Of course Council can direct us as
> requested to draw up the resolution but that is not required. 
> 
> ----- Original Message -----
> From: Anne Garcia Garland <agg at bellsouth.net>
> To: Bernard, Jacquelyn; D. Jane Miller <jane.miller at comcast.net>; D.
> Jane Miller <millerdj at y12.doe.gov>; David Mosby <dxm at y12.doe.gov>;
> David Mosby; Smith, Ellen (comcast); Smith, Ellen (ornl);
> LCharlesHensley; Tom Beehan <tombee1 at bellsouth.net>; Tom Hayes
> Cc: O'Connor, James; Krushenski, Ken; Jenkins, Steve
> Sent: Sat Sep 12 09:10:21 2009
> Subject: Re: PROPOSED ADDITIONS TO 9/14/09 AGENDA
> 
> Dear Folks,
>  
>     Can we accept the recommendation from EQAB at this council meeting
> and solicit public opinion and information for the entire month before
> entertaining a resolution by the council next month?  We wouldn't be
> voting one way or the other on open burning at this meeting and it
> would be a good start to public discussion of the issue.  I believe
> the basic change to current ordinance here affects developers.
> Thanks.
> Anne
>  
> 
> 	 
> 
> 	The staff recommends the following additions to the September 14,
> 2009 City Council agenda:
> 
> 	 
> 
> 	*	Under Communications 
> 
> 	 
> 
> 	Attached is a resolution adopted by the Environmental Quality
> Advisory Board at its meeting on September 3, 2009.  The resolution is
> requesting that City Council direct the staff to prepare for the
> Council’s consideration an ordinance that bans opening burning,
> including burning or incineration with an Air Curtain Destructor.
> This communication was received too late for inclusion in the agenda
> packet.
> 
> 	 
> 
> 	@cortn.org. 
> 
> 
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