From Our Readers

Less Than Meets the Eye

[The] Steel Recycling Institute [is] always interested to observe [Chaz Miller's] views. His Circular File column, “Less Than Meets the Eye” [January 2002, page 26] on the U.S. Recycling Economic Information Study and the steel industry does not disappoint. While faintly praising the study, [Miller] shrouds it with carping criticism, which we find unfounded.

The study … recognizes the unique circumstances of steel and indeed each of the materials. Thus, as the national universe of recycling economics is … successfully mapped … the study's assumptions and methodology are on target.

[Miller calls] for “a little consistency.” However, the study … handles an array of recycling materials and industries that defy a one-size-fits-all categorization. Different natural properties and defining economics exist among these materials and industries.

[Miller finds] fault with basic oxygen furnace (BOF) mills being included in the “100 percent recycling” category. BOFs use more than “some” scrap. The scrap charge for BOF in 2000 was [approximately] 31.7 percent recycled content, or 18.8 million tons. [If you] discount 3.5 million tons of pre-consumer “home scrap,” leaving 15.3 million tons or 29 percent recycled content, [it's] still a large post-consumer and post-industrial number.

Secondly, the BOF — as a technological requirement — must include scrap, or the process simply cannot work. It is absolutely appropriate that “100 percent of the jobs … are credited to recycling.” Each person is part of recycling the tonnage described. There are not designated recyclers [in] mills, working side-by-side with groups of virgin material users.

[Miller] also states that BOF mills “generally do not use many, if any, used cans.” … U.S. Steel and Bethlehem Steel are examples of BOF mills, and are large consumers of used steel cans.

It appears [Miller has] outdone [himself] with [his] summary judgment. We would not be so bold as to suggest that [he] might occasionally make controversial remarks for the purpose of stimulating broader reader interest.
— Gregory L. Crawford
Steel Recycling Institute, Pittsburgh

Mr. Crawford argues that basic oxygen furnaces have a “technological requirement” for scrap; that the recycling industry supplies this scrap; and therefore all the workers at BOF mills are recycling industry employees. However, a BOF mill also is technologically dependent on virgin ores. Using Crawford's logic, because the mining industry supplies ores, all the workers at BOF mills are mining industry employees.

Unfortunately, the study exaggerates the number of employees in the recycling industry, and it fails to show the extent to which American industries rely on recyclables as a raw material.
— Chaz Miller

Measuring Mercury

I read the article, “EPA & EREF Measure Mercury Emissions” [November 2001, page 85] … with great interest … While the mercury in some products stays in the products for a long time, it eventually will go to the landfill … I am very concerned about how limited the EIA study will be for several reasons.

First, the study appears to only focus on the gas that goes through collection systems. Only a portion, and perhaps a minority, of landfill gas goes through the gas collection system.

Second, there [is an] assumption … that all mercury at landfills comes out with the other gases of decomposition.

Third, there [is an] assumption … that the gas recovery system, in converting methyl mercury to elemental mercury, is avoiding [mercury's] pollution problem. This is incorrect.

[There is a necessity for a] broader study than what EIA is doing.
— John Reindl, Dane County, Wis.

[The article's point was to] inform readers that a recent study has found mercury in landfill gas (LFG), and other ongoing studies will add to the knowledge of LFG emissions, including mercury emissions.

Mr. Reindl's concerns center on EIA's limited scope of the study. As the article indicates, the study is being performed under a grant to the U.S. Environmental Protection Agency (EPA) from the Environmental Research and Education Foundation (EREF) … Therefore, EPA sets the project's scope, not the foundation.

The EPA and EREF study focuses on the gas that is collected and destroyed in the combustion devices. The study does not address collection efficiency of the gas collection system or mercury emissions at the working face … However, not addressing these concerns does not detract from the study's intended purpose, which is to accurately characterize the constituents in LFG and in exhaust gases from combustion devices.
— Ed Repa and Alice Jacobsohn

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