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.
Types of Waste
Why has there been no evaluation of alternative methods to handle sludge?
Sent 04/19/10 to Frederick County Commissioners; Carroll County Commissioners; Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste; Ron Hart, county manager; and others:
"There are risks to banning the land application of biosolids and the residential and commercial use of compost, since alternatives — landfill disposal, incineration, waste-to-energy — all have environmental, health and community impacts."
—NMWDA "Waste Watch" — Summer 2008
So once again, why are we planning to burn our sludge? [See article.]
Recyclable materials
Sent to Chris Skaggs, Deputy Director, Northeast Maryland Waste Disposal Authority:
At the Waste Options forum on Wed. October 28, 2009 those of us in attendance heard two of the speakers (professionals in this field) specifically state that recyclable material should be removed from the waste stream prior to incineration. However, when you were asked why the contract between your agency and Wheelabrator does not account for this common sense requirement, you would not answer the question. Why not?
You directed questions about the contractual obligations to the county commissioners. Our commissioners are not able to answer these types of questions — you are as the Deputy Director of the Northeast Maryland Waste Disposal Authority. (Our pro-incinerator commissioners have not admitted whether they have even read the contract.)
Is it not true that your agency is well aware that recycling requirements are not addressed within that contract? In fact one of the complaints with the Montgomery County incinerator is that there is a "failure to include source separation, waste reduction, and recycling as part of their best available control technology analysis"?
May I please remind you that the NMWDA was formed "for the benefit of the people of the State of Maryland, the increase of their commerce, welfare and prosperity, and the improvement of their health and living conditions..." Mr. Skaggs, within your duties of contract management it seems to me that you have an obligation to the citizens of Frederick and Carroll counties to fully address all of these kind of questions. Full and complete transparency should be paramount within your agency.
You work for the State of Maryland, not the incinerator industry.
Therefore, Mr. Skaggs I find your attempt to pass the buck unacceptable. Please explain why the NMWDA is failing to answer the questions to which all of the citizens of Frederick and Carroll Counties and of the State of Maryland should have answers. I anxiously await your response.
Frederick News-Post, Wed. October 26, 2009 pg. A-2 Clarification A story on page A-5 Tuesday should have stated the Northeast Maryland Waste Disposal Authority will own the waste-to-energy plant on behalf of Frederick and Carroll counties. This is in addition to managing the project, which will be built and operated by Wheelabrator.
Sent 03/06/10 to Frederick County Commissioners, Robin Davidov of the Northeast Maryland Waste Disposal Authority (NWMDA); Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste and others:
Hello BOCC and County Staff,
I agree with Ms. ____'s concerns (below) and am glad that she's written to Ms. Davidov for a solid answer to her question. I hope that she receives an answer.
Starting a single-stream program for residential recycling was definitely a positive step in helping people participate in getting some of the recyclable materials out of their house and into the "resource stream." However, I've heard it stated several times (and Mike and Phil — please correct me if I'm wrong here) that even with the "robust" SS recycling program that's been implemented, the County's actual MRA recycling rate will only go up slightly (I think Phil said at the last SWAC meeting, that the current increase would only equate to about a 2% rise in the rate.) This is due to the fact that residential recycling only makes up about 25-30% of a jurisdiction's recyclable material, I believe.
The County has set a goal of having a 60% rate by 2024 and I truly believe that our staff knows what we need to do to reach that rate (other than using the ash from the proposed incinerator to artificially increase those numbers (like other MD counties do! All "legal," of course.)) Frederick County staff understand that the 2 large areas that the County needs to work toward diverting from the landfill are Food Waste Composting and C&D (Construction and Demolition) materials. PAYT programs have been proven to help, also.
When Ms. Davidov (Executive Director of the Northeast Maryland Waste Disposal Authority), however, was asked on WFMD today how we're going to reach that rate, she answered (I'll paraphrase) that we're going to have to keep "pushing" on the homeowners to get their recyclables into the bins.
I understand that perhaps she wasn't given enough time to fully address the question, but my question to you is this: how can citizens have confidence in the Authority (who works for the County) to handle our solid waste issues in the best economic, environmental, and equitable ways for both our residents and businesses when this State organization (who we pay to assist us in these decisions) answers the question like that? We'll NEVER get to 60% by depending on residential (or, even business) recycling alone. We all know that! Not only are we going to need to put money into education, but we're going to need money for capital costs for commercial composting facilities, C&D facilities, etc. Where will that money come from if we're investing it into the debt service and operating costs for the incinerator?
A couple of us are still waiting on someone to show us where it's written into the service contract that Wheelabrator won't accept recyclable material (even just plastic bottles and cardboard); it's expected that the County implement (and fund) the means of diverting that material.
The bottom line, IMO, is this: either we can choose to carry on with plans for this expensive "silver bullet solution", or we can STOP the process and implement the zero-waste alternatives that are being successfully used in other states for far less money.
Regardless of what's been done up until now, it's still up to you.
Medical waste
During the Feb. 3, 2009 work session, there was discussion about a variety of items, including sludge and FOG (fats, oils and grease) being included as acceptable material. If medical waste is supposed to be excluded, where in the service contract is this stated? See page 21 of the contract. The problem with medical waste is not in the burning but in the transporting of dangerous material through the county to the incinerator.
Response from Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste:
Mike Marschner stated that the Maryland Department of the Environment will determine what kind of waste will be "processed" (burned) at the regional incinerator planned for Frederick County. He cited Maryland Special Medical Waste, [COMAR 26.13.11.02B(11)] is Prohibited at Municipal Solid Waste Combustion Facilities, including the Montgomery County incinerator. However, the proposed incinerator contract for Frederick County does not explicitly state medical waste is disallowed, but that we are depending on state law to stop such materials from traveling across our roads and to prevent them from being burned in the Authority's regional facility.
Follow-up question:
Is it in the best interest of the citizens of this county to amend the proposed contract to assure that despite what any law may state over the next 30 years, such material will not be allowed — ever?
Fats, Oils and Grease
Sent 02/12/10 to Frederick and Carroll county commissioners:
Commissioners,
Why are we planning to burn FOG (fats, oils and grease) in the proposed trash incinerator when our Solid Waste Management Plan states that we are to follow the EPA hierarchy?
Industrial uses in this EPA pyramid include "providing waste oils for rendering and fuel conversion..."
Think of it as the "3 R's" for food — reduce, reuse, and recycle. The good news is that food waste reduction, recovery and recycling is already occurring across the country. State governments are encouraging businesses (e.g., supermarkets, restaurants, institutions) to separate excess, uneaten food for donations and to compost the remainder. Reducing, reusing and recycling excess food can have a major impact on "greening" both your bottom-line and the environment. [full article]
AND we have local companies working on this technology. (Advanced Biofuels, Not So Big Oil, etc.)
Used mattresses
Sent 10/15/09 to Frederick County Planning Commission and Kevin Demosky, deputy director of the Frederick County Division of Utilities & Solid Waste:
Since there was discussion about burning used mattresses) and Division of Utilities and Solid Waste Management states they want to follow the EPA's waste hierarchy (which puts recycling of materials before incinerating recyclable resources), should the amended Solid Waste Management Plan add language acknowledging and researching the technology about mattress recycling? Especially a SWMP update which would allow and encourage small business in Frederick County? (See article.)
Sent 02/11/10 to Frederick and Carroll County commissioners:
Why are Frederick and Carroll Counties planning to burn old mattresses when other communities are not?
"St. Vincent de Paul staff and board members then became aware of the potential of deriving reusable goods from the waste stream." [Full article]
Sludge
Sent on 02/08/10 to Robin Davidov and Chris Skaggs of NWMDA, Frederick and Carroll county commissioners and Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste:
The service contract for the proposed trash incinerator specifies it can burn "up to 50,000 tons per year of biosolids."
Why is it that Frederick wasn't given the option of processing sludge like the Baltimore City Composting Facility (pg. 2) for the treatment of sludge into EPA approved compost which is...
"a soil amendment and fertilizer that is approved for residential, commercial and agricultural uses and available through retail and wholesale outlets" as an alternative way to handle our sewage sludge.
"... sewage sludge, which is the untreated semi-solid residue resulting from an early stage of the wastewater treatment process..." versus "...biosolids, which is the accepted term for the EPA approved fertilizer and soil amendment that results from the extensive treatment of sewage sludge."
"There are risks to banning the land application of biosolids and the residential and commercial use of compost, since alternatives - landfill disposal, incineration, waste-to-energy—all have environmental, health and community impacts."
Thank you for any explanation you can provide.
Follow-up sent 02/09/10:
And how about this as an alternative? Wastewater Plants As Green Power Producers (Nov. 2009 Biocycle magazine). I didn't see this discussed in the RW Beck or the RTI Reports.
Construction materials
Sent 06/17/09 to County Commissioners President Jan Gardner:
If 25% of our waste stream is residential MSW, what amount of our waste stream (by tonnage) is from C&D?
What’s more, because C&D waste contains only the smallest amounts of food (a few bites of a burger tossed out by a construction worker), the waste is very clean and produces little odor.
Where construction and demolition waste comes from
Construction and Demolition Debris, or C&D, comes from demolition (50%), renovation (40%), and new construction (the rest) (Source: EPA).
Why is construction and demolition waste so easily recyclable?
C&D is comprised of materials that can be easily reused and recycled. The most common materials found in C&D includes: Cardboard / Paper Carpet • Concrete • Dirt • Metal • Plastics • Reusable Materials • Wallboard • Wood
Yes, I do know Maryland does not count C&D recovery in its recycling rates. However, the purpose of the discussion here is to evaluate how we can proceed on a trash "diet" to decrease the amount of waste going to Reich's Ford and/or being long-hauled.
Sent 10/15/09 to Frederick County Planning Commission and Kevin Demosky, deputy director of the Frederick County Division of Utilities & Solid Waste:
Also, I understand there is some interest by local entrepreneurs to be allowed to operate a local Construction & Demolition recovery facility. Could an amendment to the SWMP be considered to allow such businesses in Frederick County?
Sent 02/15/10 to Frederick and Carroll county commissioners; County Manager Ron Hart; Kevin Demosky, deputy director of the Frederick County Division of Utilities & Solid Waste; Mike Marschner, director of the Frederick County Division of Utilities & Solid Waste:
"Deconstruction, salvage and selective demolition methods divert large amounts of materials from disposal and provide business opportunities within the local community." — John Gundling, LEED AP, President of Eco One Solutions.
I have attached a PowerPoint presentation I attended at the GRRN National Recycling Conference — Construction & Demolition Recycling (C&D) 95%+
The Connecticut Example:
Question: To Equal the Overall Reduction of Landfill (per capita basis and goals) by 2024, what is the percentage of increase in C & D recycling statewide that we would have to achieve?
Answer: Only 5%. Increasing C &D Recycling by only this percentage can have the same impact as [Connecticut's] overall 15 year plan!
And here is a one of the responses I rec'd about my earlier email concerning how the state of Wisconsin has chosen to handle its C&D waste:
"Your updates and informative research is really valuable. That one seems so very logical."
