Policy Workshop- The Municipal Solid Waste Combustion Moratorium: Sylvia Broude, Toxics Action Center makes a case against lifting the incinerator moratorium.

1.
Sylvia
Broude
Execu1ve
Director,
Toxics
Ac1on
Center
MASSRECYCLE
R3
Conference
Plenary
Remarks
-­‐
Zero
Waste
and
the
Incinerator
Moratorium

2. Case
against
li7ing
the
incinerator
moratorium:
• High
heat
gasifica1on
and
other
forms
of
staged
incinera1on
are
incinera1on
and
have
similar
environmental
impacts
• Gasifica1on,
plasma
arc,
and
pyrolysis
are
pollu1ng
and
threaten
public
health
• These
technologies
do
not
work:
they
have
a
history
of
economic
and
technological
failures
• Gasifica1on
competes
with
recycling
• We
can
solve
our
waste
problem
in-­‐state
without
expanding
incinera1on

3.
“Disposal
of
waste
carries
a
significant
cost
to
the
economy
and
the
environment,
and
represents
lost
opportuni9es.”
-­‐MassDEP
Dra7
Solid
Waste
Master
Plan,
2010

4. An
incinerator
is
an
incinerator
is
an
incinerator

6. Comparing
mass
burn
and
staged
incinerators
(gasificaIon,
plasma
arc,
pyrolysis)
• Very
similar
concerns
around:
types
of
emissions,
impact
on
zero
waste
approaches,
waste
of
resources
and
energy,
jobs,
climate
• Staged
incinerators
may
have
less
air
emissions
than
mass
burn
incinerators
(but
the
same
pollutants)
• Staged
incinerators
would
likely
have
less
boRom
ash
than
mass
burn
incinerators
• Staged
incinerators
would
likely
cost
more
than
mass
burn,
and
thus
have
more
financial
risk

7. “Many of the perceived benefits of
gasification and pyrolysis over combustion
technology proved to be unfounded. These
perceptions have arisen mainly from
inconsistent comparisons in the absence of
quality information.”
The Viability of Advanced Thermal Treatment in the UK,
Fichtner Consulting Engineers Limited, 2004, p.4

8. Staged
incineraIon
is
polluIng
and
harmful
to
public
health
• Heavy metals such as lead, cadmium, arsenic, chromium, and mercury,
halogenated hydrocarbons, acid gases, particulate matter, and volatile
organic compounds such as dioxin and furans
• Nano-particles or ultrafines
• Solid, liquid, gaseous releases
• Discharges to surface and groundwater that may be highly toxic
• Have been accidents and unexpectedly high emissions released in
operating facilities (see examples to follow)

9. GasificaIon
is
a
polluIng
technology

11. 6
-­‐
12
15
-­‐
30
50
-­‐
100

12. Findings
in
report
on
Plasco
Energy
demonstraIon
pilot
project:
• They
say
“there
are
no
air
emissions
during
the
conversion
of
the
waste
to
synthe1c
fuel
gas,”
but
during
their
pilot
program
2008-­‐2010,
they
documented:
• 29
non-­‐compliant
emissions
incidents
• 13
non-­‐compliant
spills
• Their
picture/ar1st’s
rendering
is
misleading,
doesn’t
include
a
smokestack
• They
only
operated
25%
of
the
1me
• They
used
MSW
mixed
with
“high
carbon
feed”
=
plas1c

13. “Plasco's
demonstraIon
facility
is
sIll
in
what
they're
calling
a
"campaign"
phase,
and
hasn't
operated
in
a
sustained
manner.”

14. GasificaIon
faciliIes
have
a
history
of
economic
and
operaIonal
failure
No
commercial
facili,es
in
the
United
States
have
succeeded
at
using
gasifica,on,
plasma
arc
or
pyrolysis
to
generate
energy
from
MSW.
Pilots
and
plants
worldwide
have
been
plagued
with
problems.
This
is
because
of
two
problems
inherent
in
MSW
gasificaIon:
1. Gasifica1on
needs
a
consistent,
homogenous
material
for
feedstock
–
which
garbage
is
not
2. MSW
does
not
have
enough
high-­‐carbon
material
to
produce
energy
or
fuel
–
especially
if
all
the
paper,
cardboard,
and
plas1c
were
removed
for
recycling.

15. GasificaIon
facility
closes
because
of
bankruptcy

17. ¨ “The performance record is poor as demonstrated
by the continuing problems in operation of
Thermoselect and others (billed as Thermodefect by
DerSpiegel) together with the failures of high
profile projects like SWERF and GEM; the delays
with Novera at Dagenham and the lack of
development of even the relatively promising plants
like Compact Power.”[2]
[2]
European
Commission
(2006).
Integrated
Pollu1on
Preven1on
and
Control
Reference
Document
on
the
Best
Available
Techniques
for
Waste
Incinera1on.

18. Gasifica1on
competes
with
recycling
• Records
from
gasifica,on
plants
and
pilots
overseas
and
in
North
America
indicate
that
industrial
waste,
plas,cs,
or
other
materials
are
added
to
MSW
to
make
fuel
or
electricity.
A
chart
of
recycling
and
incinera1on
from
the
five
regions
of
Denmark
shows
an
inverse
rela1onship
between
recycling
and
incinera1on

19. Environment
Commissioner:
“Don’t
Burn
Recyclable
Plas1cs”

20. “Perhaps
Sweden
has
gone
too
far
down
the
incinera,on
route
and
is
not
recovering
enough
materials
by
recycling.”
-­‐
Catarina
Ostlund,
Swedish
Environmental
Protec1on
Agency.

21. We
won’t
have
a
capacity
problem
if
MassDEP
enforces
and
strengthens
exisIng
regulaIons
• For
waste
bans,
a
history
of
lack
of
enforcement
– Recently,
the
South
Hadley
Board
of
Health
documented
viola1ons
of
waste
ban
regula1ons
by
haulers
and
the
landfill
operator
and
complained
to
DEP.
– DEP
issued
a
no1ce
of
non-­‐compliance
but
no
penalty.

22. Problems
with
waste
ban
compliance:
not
only
limited
to
the
South
Hadley
landfill
• Since
August
2009,
DEP
has
issued
only
3
financial
penal1es
• With
approximately
230
waste
disposal
facili1es
in
MassachuseRs,
in
2010
DEP
conducted
only
8
waste
ban
inspec1ons
dedicated
to
waste
ban
compliance;
in
2011
only
5
waste
ban
inspec1ons,
in
2012
only
8.
• Because
no
‘ac1on
threshold’
for
banned
material
has
been
established
for
a
garbage
truckload,
according
to
the
current
waste
ban
compliance
guidance,
a
truck
that
is
2/3
full
of
banned
material
can
s1ll
pass
a
waste
ban
inspec1on.
Fortunately,
DEP
is
working
to
strengthen
waste
ban
regs
and
enforcement.

23. Enforcement
is
also
cheaper
• Developing
disposal
facili1es
uses
public
money.
– By
2010,
Taunton,
MA
had
reportedly
spent
at
least
5
million
dollars
on
land,
consultants,
and
lawyers
to
develop
a
gasifica1on
plant
that
three
years
later
has
not
been
designed
or
built.
– If
garbage
gasifica1on
plants
are
allowed,
DEP
will
have
to
develop
regula1ons
for
facility
performance,
review
proposals
and
draj
permits,
hire
consultants
and
monitor
facili1es.
DEP
resources
would
be
beRer
spent
on
waste
reduc1on
programs.

24. MassDEP’s
own
consultant
recommended
against
lijing
the
incinerator
moratorium
• A
report
by
the
Tellus
Ins1tute,
commissioned
by
MassDEP,
advised
that
MassachuseRs
should
not
pursue
gasificaIon
in
the
Solid
Waste
Master
Plan,
2010-­‐2020.
• www.mass.gov/dep/recycle/priori1es/
tellusmmr.pdf,
p1.

25. MassachuseRs
can
be
a
leader
na1onwide
by
adop1ng
zero
waste
• There
are
ci1es
and
towns
in
MassachuseRs
that
are
leading
the
way
at
waste
reduc1on
and
recycling:
curbside
pick-­‐up
of
organics
in
Hamilton
and
Wenham,
90%
diversion
in
Nantucket,
etc.
• Incinera1on
is
a
bad
approach
to
address
the
problem
of
residual
waste
(material
that
cannot
be
reused
or
recycled)
• Expanding
incinera1on
is
out
of
step
with
zero
waste,
a
move
in
the
wrong
direc1on

26.
www.toxicsacIon.org