Questions and Concerns About the Frederick County Incinerator
These incinerator concerns have been sent to officials, politicians and candidates in Frederick County, Carroll County and the State of Maryland; the Northeast Maryland Waste Disposal Authority, and others.
Health and the Environment
More from Marion County, Oregon
Sent 07/05/10:
The following is part* of comments submitted as testimony for a 1/20/10 public hearing held by the Marion County Board of Commissioners to consider adoption of the 2009 Marion County Solid Waste Management Plan from Joseph Miller Ph.D Member, Board of Directors Oregon Chapter, Physicians for Social Responsibility (812 SW Washington Street, Suite 1050 Portland, Oregon 97205) and Associate Professor of Psychology Emeritus Saint Mary's College Notre Dame, Indiana 46556:
CONTINUED RELIANCE ON INCINERATION IS AN ECONOMIC THREAT
Incinerators pose major economic threats to communities. Early this month the Mayor of Harrisburg, Pennsylvania indicated that the city could run out of money in three months, largely because of payments that are due on $288 million in debt the city has racked up across time on its WTEF incinerator and various retrofitters and incinerator retrofits [5]. While trade industry proponents assert that the current Harrisburg incinerator -- retrofitted and operated by Covanta -- is "among the world's most innovative" and "state of the art," one proponent notes that "bottom line [the incinerator] is not making enough revenue to cover operations and debt." [6]
Harrisburg's financial status and the financial status of any other city or county that owns a WTEF incinerator will take additional hits in coming years as federal and state regulators tighten regulations on large industrial combustion facilities to reduce emissions that contribute to global warming, smog, and health impairment. Peter Montague made exactly this point in 2006 in his chronology of the Harrisburg incinerator when he noted that "if regulations on ultrafine particles, or mercury, or other emissions from the incinerator are tightened at any time during the next 30 years -- as seems inevitable -- additional retrofits and additional debt will become necessary" [7].
Stricter federal regulations are exactly what is playing out as the EPA announced in September, 2009 proposals to reduce greenhouse gas emissions from large, stationary industrial facilities [8,9]; proposals in January, 2010 to strengthen emission standards for pollutants that contribute to smog [10,11]; and preliminary remediation goals for dioxin in soil in January, 2010 [12,13]. The EPA also announced earlier this month that it is "working to complete a dioxin risk assessment that has been under review for years. The goal is to have the assessment finished by the end of 2010. When it’s finished, the EPA will use it as its scientific foundation for future decision-making about dioxins in the environment" [12].
The EPA dioxin risk assessment currently in progress is partially due to a call by more than 100 organizations to President Obama in January of 2009 to mandate the EPA to evaluate previously blocked federal regulations for dioxins [14]. Such regulations can be expected to further increase the pollution control and operational costs of, and cost projections for, incinerators and ash monofills, and impact the feasibility and cost projections for proposals for the "beneficial use" of incinerator ash. If Continuous Emissions Monitors (CEMs) for dioxins [15] were mandated in the United States as they are in some parts of Europe, WTEF incinerators would be even more costly to operate, but they would also emit fewer dioxins.
Contracts and the need to pay operational expenses and retire debt require that incinerators receive at least a stable and minimum amount of waste. Changes in our economy and society, however, increasingly threaten the ability of communities to meet their contractual obligations to supply a mimimum amount of waste to feed incinerators. Under such conditions, communities have to either pay higher tipping fees, import waste from greater distances, and/or pay financial penalties. Interrelated factors that jeopardize the ability of communities to meet their contractual obligations to feed incinerators include:
- decreases in the magnitude of the waste stream due to changes in the economy, employment and consumption
- decreases in population resettlement due to the economy
- increased commitments to conserving resources, energy, and water by residents, businesses and consumers
- increased concerns about the health and environmental effects of pollutants and global warming gases
- decreases in the production of goods and the size and weight of packaging
- increases in extended producer responsibility for packaging
Re the above, The Washington Post reported last April that in a number of communities across the nation, disposal is down and reuse and repair are up [16]. To cite just two additional examples, San Bernardino County, CA reported a 19 percent decline in the total waste tonnage between 2005 and 2008 [17], and "towns served by the Connecticut Resources Recovery Authority’s Mid-Connecticut trash-to-energy facility in Hartford will see their tipping fees ... increase to $69 per ton starting July 1 because the volume of garbage the plant takes in is down [by 8%] compared to last year" [18].
Also re the above, OPB recently reported that because of the recession, diminished work opportunities, and other factors fewer people moved into Oregon in 2009 than in recent years [19].
It should be noted that the recommendations in Chapter 6 of the Solid Waste Management Plan are predicated upon more and more people moving into Marion County, and projected yearly increases in the amount of waste each person discards. Both assumptions look increasingly questionable.
THE HEALTH IMPAIRING EFFECTS OF INCINERATORS AND INCINERATOR ASH
Both the national and Oregon Physicians for Social Responsibility (PSR) are signatories along with hundreds of national, state/regional, and local organizations to the "No Incentives for Incinerators Sign-on Statement" [20]. The statement asserts, in part, that: "Incinerators are a toxic technology. Even the most technologically advanced incinerators release hundreds of distinct hazardous byproducts including dioxins, heavy metals, and halogenated organic compounds in the form of toxic air emissions, particulates and ash."
An extensive and growing literature exists on the health impairing effects of the pollutants emitted from municipal waste incinerator stacks and present in incinerator ash. Contributing to this literature have been organizations such as the British Society for Ecological Medicine [21]; Prevent Cancer Now [22,23]; the Global Alliance for Incinerator Alternatives [24]; the Irish Doctors Environmental Association [25]; and a coalition comprised of the Pembina Institute in collaboration with the David Suzuki Foundation, Sierra Legal, Toronto Environmental Alliance, Canadian Environmental Law Association and Great Lakes United [26].
WAYS IN WHICH REGULATIONS (AND CLAIMS) CAN BE INADEQUATE, INCOMPLETE, MISLEADING
Representatives of incinerator corporations assert that the emissions from their facilities meet federal and state regulations, and thus imply that the emissions are safe, and do not impair health or the environment. What they do not say is that there are all sorts of ways in which these regulations are known to be inadequate, incomplete and misleading. For example [27-29]:
- while some pollutants are monitored, other pollutants are completely unmonitored
- monitoring may be continuous, but it may also be only on a six-hour basis once every year. Extrapolations made from such infrequent samples can dramatically underestimate day-to-day emissions.
- interactions and synergistic effects among chemicals are unexplored, even though research indicates such effects can be major
- timing of exposure is sometimes very important, and chemicals may have different effects at different points in development
- dosage effects may not be linear, and low doses can sometimes have greater effects than high doses
Re pollutants that are unmeasured, one of the most health impairing and deadly forms of particulate air pollution -- ultrafines -- are neither regulated nor measured under current regulations, and are released in vast quantities by incinerators. Such particles are incredibly small (between 1 nanometer or billionth of a meter and 100 nanometers, i.e., 1/100,000th to 1/1000th the width of a human hair) and have a very large surface area relative to their volume. Airborn toxins attach to this surface. Such ultrafines then get lodged in our lungs, or enter our blood stream creating various types of respiratory, circulatory and other health problems. [30]
More and more such ultrafine particles are being emitted from incinerators, because more and more products containing nanotechnologically engineered ultrafine sized materials are entering the waste stream. There are currently more than 800 such products [31]. As these products are discarded and incinerated, there is every reason to believe that the increased levels of ultrafine particulates that are emitted, and the properties of these ultrafines, will create increased levels of health impairment.
Engineered nanomaterials have unique properties. The organization Food & Water Watch, for instance, notes in "Sweating the Small Stuff" that "nanoscale materials are very different than their larger counterparts, with distinct electronic, magnetic, chemical and mechanical properties," and that "nanoparticles have the potential to bypass the blood-brain barrier" ... "the potential to pass the placental barrier" .... [and that] "once in the bloodstream, nanomaterials can circulate throughout the body and be taken up by organs and tissues." [32]
"Sweating.... " also notes that "the European Commission Scientific Committee on Emerging and Newly Identified Health Risks reported [3/10/06] that 'experts are of the unanimous opinion that the adverse effects of nanoparticles cannot be predicted (or derived) from the known toxicity of material of macroscopic size, which obeys the laws of classical physics.' " [32]
Because of their nano size and unique properties, and because they are unregulated, many groups have called for urgent precautionary research, regulation and oversight of engineered nanomaterials throughout their cycle of production, use, and disposal. These groups include the Environmental Working Group, the Royal Commission on Environmental Pollution (UK), the Silicon Valley Toxics Coalition, the Project on Emerging Nanotechnologies, the ETC Group, Friends of the Earth Europe, Food & Water Watch, the Soil Association (UK), the Science & Environmental Health Network, and many others [33], as well as former EPA official J. Clarence Davies [34], and insurance companies [35,36].
References:
[5] Harrisburg Mayor Linda Thompson inherits a city that's running out of money, according to a consulting firm - The Patriot-News 1/5/10
[6] Trade publication ranks Harrisburg incinerator among the world's most innovative - The Patriot-News 12/8/09
[7] Money to Burn - Peter Montague - Rachel's Democracy & Health News #884 12/7/06
[8] As Hill Debate on Climate Flounders, EPA Plows Ahead on Emission Rules - New York Times 9/10/09
[9] EPA New Source Review: Fact Sheet 9/30/09
[10] U.S. wants to toughen smog standards, putting clamp on Oregon cities - Scott Learn - The Oregonian 1/7/10
[12] Updated story: EPA seeks input on interim dioxin cleanup goals - Midland Daily News (MI) 1/1/10
[13] Development of Draft Recommended Interim Preliminary Remediation Goals for Dioxin in Soil - Superfund - US EPA
[14] Over 100 Organizations Call on Obama to Take Action on Dioxins - Center for Health, Environment and Justice 1/16/09
[15] Continuous Emissions Monitors (CEMs)
[16] A Trashed Economy Foretold: Intake at Landfills Has Been Falling - Washington Post 3/14/09
[17] There's even less trash in this economy - The Press-Enterprise (Riverside County, CA) 2/9/09
[18] Recession has brought decrease in trash, some hikes in fees 5/24/09
[19] Company's Data Shows Fewer People Moving To Oregon - OPB News 1/5/10
[20] No Incentives for Incinerators Sign-on Statement - Global Alliance for Incinerator Alternatives (GAIA) 2007
[22] Incineration and Links to Cancer - Prevent Cancer Now 1/09
[23] Health Effects of Incineration - Prevent Cancer Now 1/09
[24] Incinerators Trash Community Health - Global Alliance for Incinerator Alternatives (GAIA) 6/08
[25] Irish Doctors Environmental Association: Incinerators and their Health Effects 6/15/06
[26] Incineration of Municipal Solid Waste: An Update on Pollution - Pembina Institute in collaboration with the David Suzuki Foundation, Sierra Legal, Toronto Environmental Alliance, Canadian Environmental Law Association and Great Lakes United 5/07
[27] Can Chemicals Be Regulated? - Peter Montague - Rachel's Democracy & Health News #993 1/8/09
[29] Incinerators Trash Community Health - Global Alliance for Incinerator Alternatives (GAIA) 6/08
[30] The Deadliest Air Pollution Isn't Being Regulated or Even Measured - Peter Montague - Rachel's Democracy & Health News #915 7/12/07
[31] Nanotechnology-Related Environment, Health, and Safety Research: Examining the National Strategy - Environmental Health Perspectives, Volume 117, Number 4, April 2009
[32] Sweating the Small Stuff: Nanotechnology Needs Research and Regulation - Food & Water Watch 1/07
[33] Precautionary Concerns about the Potential Adverse Effects of Incinerating Engineered Nanoscale Materials in the Waste Stream (Section 9) - Joseph Miller 1/09
[34] Former EPA Official Calls For New Environmental & Consumer Protection Agency: Technological Advances Require New Oversight - Project on Emerging Nanotechnologies 4/28/09
[35] Nanotechnology: The Smallest Big Risk - Joshua Hackett - Endurance Reinsurance Corporation of America Fall/09
[36] Insurers scrutinize nanotechnology - Environmental Science & Technology 9/24/08
*Edited in part to contain information of general interest. (Emphasis to this excerpt was added by me.) I will forward the complete testimony to anyone interested.
Levels of Emissions
Sent to Commissioner Gray:
Communities all over the world are always promised the "tightest emissions levels" by the incinerator industry and waste authorities which promote them. But judging by the Harford County, MD emissions reports of nearly 200 separate emissions from their facility—everything you can imagine from arsenic to zylene listed—what leads you to believe that Frederick County will be held to another standard?
It is clear that federal emissions standards will be tightening, and will continue to do so after the Frederick incinerator is built. So what that mean in terms of costs to retrofit pollution control systems? The BRESCO incinerator in Baltimore underwent a $40 million retrofit, according to the NMWDA's own website.
Also, the NMWDA says that our Frederick incinerator will be built according to according to European standards. But the Europeans aren't happy with the performance of their incinerator, either! Here is just one of many websites from the UK, which describes the health hazards of incineration: http://www.chaseireland.org/HealthEffectsDocuments.htm In Newcastle, England, the ash from the Byker Reclamation Plant was considered safe by the government to be "recycled" into paving material. Yet this paving material was later found by independent investigators to have dangerous levels of dioxin.
What about the use of incinerator ash as landfill cover at Reichs Ford Road--I'm sure we are being assured that is safe, as well. Independent chemists and toxicologists such as Paul Connett strongly disagree. "Waste to energy facilities" have a bad history worldwide of being overly expensive and polluting. Despite claims that pollutants will be kept to a minimum, the most potent neurotoxins such as mercury—also lead and dioxin—still are emitted into the air (landing in the water and the soil) on a 24/7 basis. These daily amounts may seem small and therefore "acceptable", but over the years they have a harmful bioaccumulative and persistent effect on the environment and our bodies. This is why states like MA continue their moratorium on building any new incinerators; these plants have a proven history in MA of causing too much mercury contamination.
The residents of Frederick County do not accept assurances that the levels of emissions will be safe from the approved waste incinerator—especially when there are non polluting and affordable alternatives to reduce, reuse and recycle 90% of our waste. Do you think Nantucket could be our model for success instead? If not, what is your reasoning behind this opinion? See their story here (a slide show from the New York Times).
And for everyone's information, Baltimore is still paying on the $41,060,000 bond which was issued to finance a portion of the cost of the installation of air emission control equipment at the BRESCO trash incinerator which was required due to the Clean Air Act Amendments of 1990.
Response by Robin Davidov, executive director of the Northeast Maryland Waste Disposal Authority (NMWDA):
Ms. Eader is mistaken regarding Baltimore City. In fact, the City currently enjoys a remarkably low “tipping fee” at the BRESCO facility, $33/ton, in comparison to the average current market rate for transportation and disposal of trash ($55/ton). In the past two years, the market rate has been as high as $70/ton when fuel costs were higher. The savings to Baltimore City is approximately $5 million/year.
You may find the recent article in the Christian Science Monitor, “Trash- America’s Best Bet for Energy Independence” of interest.
Response by Caroline Eader to Robin Davidov:
I am not wrong about the information I forwarded about the Baltimore trash incinerator. In fact I have a copy of the bond prospectus.
And this handout from the HDR Engineers provides helpful information about the $36.5 Millon (page 2, 3rd paragraph) retrofit which was needed due to the Clean Air Act Amendments of 1990.
I quote from the prospectus,
"The Series 1998 Bonds are being issued to finance a portion of the cost of the installation of air emission control equipment at a solid waste disposal facility....located in the City of Baltimore, Maryland operated by Baltimore Refuse Energy Systems Company...an affiliate of Waste Management, Inc. Full and timely payment of the principal of, and redemption premium, if any, and interest on the Series 1998 Bonds when due is secured by payments to be made pursuant to a Loan Agreement between the Authority and Waste Management, Inc." [emphasis added]
The amount is $41,060,000. The due date is January 1, 2012.
The article you forwarded from the Christian Monitor was an opinion piece from a gentleman whose latest book is on culinary vacations. You using that as justification for NMWDA's regional trash incinerator in Frederick is laughable.
When will your office be forwarding the electronic Excel spreadsheets which several of us have been requesting, please? I include here the pdf versions in order to jog your memory:
- Frederick Carroll Regional Energy Recovery Facility, Conservative Electric Fuel Cost Escalation
- Frederick Carroll Regional Energy Recovery Facility, Conservative Electric Fuel Cost with a 25 percent One Time Increase
Sent 03/17/10 to Frederick and Carroll county commissioners; Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste; and others:
"Needless to say, this would have a disastrous adverse impact on the WTE incinerator’s net present value as compared to the other options you've since dismissed, and makes its financial desirability highly suspect."
The NMWDA has refused to provide the "live" Excel spreadsheets which support their belief that the NMWDA's incinerator is a good deal for Frederick and Carroll Counties:
- Frederick Carroll Regional Energy Recovery Facility, Conservative Electric Fuel Cost Escalation
- Frederick Carroll Regional Energy Recovery Facility, Conservative Electric Fuel Cost with a 25 percent One Time Increase
However, if you use different variables in the assumptions, the financial picture is not as rosy as the NMWDA would like us to believe. (And even with the NMWDA's assumptions, long-hauling our trash is LESS expensive the first DOZEN years the facility is open.)
On WFMD Ms. Davidov said she would "happily" use different assumptions and provide the resulting spreadsheets. She has not followed-thru with her promise.
Commissioners, when will you all hold her accountable?
Sent 02/10/10 to Carroll County Commissioner Michael Zimmer and Frederick County Commissioner Lennie Thompson in addition to state senators and other commissioners:
Commissioner Zimmer,
"Safe" — in case you've not seen this report from the Maryland Department of the Environment (MDE) for the Harford County incinerator, there were nearly 200 toxins released. And when you get to reading the contract you'll see in the Environmental Guarantee there are only about 12 regulated emissions.
"Effective" — It is more effective to reduce, reuse, recycle and compost to the level to which you would have less to landfill than with an incinerator. Please remember you must have a landfill for the 10-15% nonprocessable waste (that which cannot be incinerated), and for the 10-15% leftover (the resulting ash).
And Commissioner Thompson,
Did you read how the lobbyists were there fighting S.B. 228? I read that last year Covanta (who runs Mont. Co's incinerator) spent approximately $500,000 lobbying to keep trash burning defined as Renewable Energy.
And of course you know that pursuant to the Annotated Code of Maryland, Public Utility Companies Article, Title 7 Gas, Electric and Water Companies, Subtitle 7 Renewable Energy Portfolio Standards § 7-704(a)(3)(i):
"Energy from a Tier 2 renewable source under § 7-701(m)(1) or (3) of this subtitle is eligible for inclusion in meeting the renewable energy portfolio standard through 2018 if it is generated at a system or facility that existed and was operational as of January 1, 2004, even if the facility was not capable of generating electricity on that date." [Emphasis added.]
Waste of energy is considered a Tier 2 renewable energy source under 7-701(m)(3), and therefore any incinerator built at this point in Md. would not qualify for any RECs within Maryland. I do understand the credits may be sold outside of the state. However, I think it should be clear the State of Maryland does not continue to recognize WTE as renewable energy in this manner.
Health impact study
Is there a time frame about completing a study on the impact the proposed incinerator will have on the health of the members of our community?
Air quality standards
To Maryland Department of the Environment: In addition to the one-page handout wherein it describes the new EPA NAAQS for lead in the U.S., I attach the EPA's "October 2008 Final National Ambient Air Quality Standards for Lead - General Overview." On page 9 it shows the "Source Sectors of Lead Emissions in the U.S." Sources of lead emissions include:
- Leaded aviation gas used in piston-engine aircraft (45%)
- Metal industries (23%)
- Manufacturing industries (14%)
- Waste incineration (8%)
- Boilers— industrial, commercial, institutional, utility (6%)
- Other (small) categories (5%)
And due to Maryland's dubious distinction of being the home of 3 trash incinerators, I would like to know where to receive the information about lead testing which has been completed in compliance with these new standards.
Follow-up question to Maryland Department of the Environment:
Would you be so kind as to direct me who to contact in your office about whether the trash incinerators in this state have been tested for compliance with the new lead NAAQS? I understand the U.S. national ambient air quality standard for lead (the primary standard) in the air has changed from 1.5 µg/cubic meter per quarter to 0.15 µg/cubic meter per quarter, effective January 12, 2009. (Please see attached.) Mr. Blake from the NMWDA has not answered my question about what (if any) lead air monitoring has been completed on the trash incinerators in Maryland to assure they comply with the new lead standard. I also wonder how Frederick Commissioner David Gray can state the emissions from the proposed trash incinerator for Frederick "...will be the tightest emission levels in the entire world." Perhaps you could please help me understand the basis for such a comment.
I understand that the U.S. EPA already revised, effective January 12, 2009, the U.S. national ambient air quality standard for lead (the primary standard) in the air from 1.5 µg/m3 per quarter to 0.15 µ/m3 per quarter. Has there been lead air monitoring of all of the incinerators in Maryland to ensure they all comply with the new lead NAAQS? (See PDF.)
