Zero Waste 4 Zero Burning Comments on Proposed Revision to Ontario Guideline A-7

Note: the following text is not an endorsement of incineration in any form. However, by taking advantage of the opportunity to influence Ontario government policy on incinerator approvals we could possibly be making incineration harder to establish in Ontario.

Comments on proposed Guideline A-7 - Air Pollution Control, Design and Operation Guidelines for Municipal Waste Thermal Treatment Facilities (EBR 010-5887).

On behalf of the signatories to

Thank you for the opportunity to comment on the proposed Guideline A-7 - Air Pollution Control, Design and Operation Guidelines for Municipal Waste Thermal Treatment Facilities.

ZeroWaste4ZeroBurning.ca is a grassroots initiative in Durham Region to educate residents about the benefits of waste reduction as well as the health and financial risks associated with energy-from-waste incineration plants. We have gained experience participating in the environmental assessment study for the ongoing Durham-York Residual Waste Study which is recommending thermal treatment (mass burn incineration) of the regions' residual waste in an EFW incinerator proposed for the Municipality of Clarington.

1. Limits stated as concentrations

The Ontario Ministry of the Environment's Statement of Environmental Values states that approvals must consider an "ecosystem approach to environmental protection" and "cumulative effects on the environment" and the "effects of its decisions on current and future generations, consistent with sustainable development principles" (MOE-SEV, Section 3, Application of the SEV). The A-7 guideline should give proponents and the public more precise and prescriptive guidance on the overall environmental considerations that will be applied to a project.

Considering only the point of impingement approach of Ont. Reg. 419/05 fails to take into account the long term effects of persistent organic pollutants (POPs), deposition of airborne contaminants on land and water, and long range transport of POPs adsorbed on fine and ultrafine particles. This shortcoming is discussed in Commoner, 1996, section I. The Dioxin Problem.

Attempting to control pollution solely by limiting the in-stack concentration of contaminants is generally protective of the environment but does not reassure the public that health and the environment will be adequately protected. The approach fails to account for the current burden on the environment (air, land, water) as well as pre-existing contaminants carried in the bodies of residents, plants, fish, insects and animals in the vicinity of a proposed incinerator.

Emission limits should be stated as a cap on total yearly emissions, expressed in units of mass or volume, in a format compatible with Environment Canada National Pollutant Release Inventory (NPRI). The cap should be linked to the pre-existing burden and the total acceptable burden in the vicinity of the incinerator. The amount of waste burned in the incinerator should only be a secondary factor in setting the emission cap. In other words, a large incinerator would be held to lower concentrations of pollutants to avoid exceeding the cap on its total emissions.

2. Maximum Available Control Technology (MACT)

The emphasis for verification of compliance by continuous emissions monitoring (Section 3) is welcome however there should not be a choice between sampling and continuous monitoring. If technology is available to continuously monitor a parameter, that should be the default. As a second choice, a continuous sampling system with periodic analysis (bi-weekly or monthly), for example the AMESA cartridge system for dioxins and furans should be mandated. Finally, periodic sampling should only be acceptable if no monitoring or sampling system is available.

Measurements from CEMS instrumentation must be made available promptly to the public via the Web, daily email bulletins, or other means of rapid dissemination. Results from longer term sampling like the AMESA cartridge or stack sampling should be posted as soon as the laboratory analysis is complete. The lag between measurement and publication should be minimized in the interest of transparency and to maintain public confidence in the safe operation of the incinerator.

Additional contaminants of potential concern, notably metals and selected organic compounds are now able to be monitored continuously (Ewall 2009, Energy Justice 2009) and appropriate limits should be added to Table 1.

Certificates of Approval are based on emission limits which are in turn derived from the capabilities of maximum available control technology. As technology advances, air pollution control and monitoring equipment should be updated after a suitable grace period for retrofit work. Certificates of Approval should have well defined sunset time limits for periodic review. These timeframes would provide the public with a reasonable expectation of protection, and owners/operators with sufficient notice for financial and operational forecasts. The sunset clauses would also ensure a review of the effects of contaminants released in light of new scientific findings and offer an opportunity to improve protection of the public.

3. Ultrafine and nano-particulate matter emissions

There is mounting evidence that particulate matter smaller than 1μm in diameter and on the order of 0.1 to 0.01μm presents a risk to health (Somers et al. 2004). Nanoparticles are also suspected of carrying adsorbed contaminants and carrying them deep into the lungs. They are also suspected of being small enough to cross the alveolar barrier and being transported in the bloodstream (Gatti et al. 2007, 2009). The proposed A-7 guideline is vague in its treatment of particulate matter. With forewarning of an emerging but uncharacterized threat to health, the precautionary principle should apply and additional abatement methods should be required to minimize the emission of ultrafine particulate matter.

4. Certificate of approval process in the presence of changing guidelines, legislation and policies

The environmental assessment and certificate of approval process can be protracted and potentially overlaps revisions to Ontario policy on waste management, energy and pollution control. The revised guideline should offer guidance on how the ministry will incorporate expected changes to policies and legislation affecting the application. The applicant and community stakeholders should have a clear understanding of what regulations will apply, how they will be interpreted, and the extent of any potential "grandfathering".

For example, the Durham-York Residual Waste Study proposal for an energy-from-waste incinerator is currently under way. It is unclear how recent developments will affect the study and subsequent application for a Certificate of Approval. In addition to this review of the A-7 guideline, the recent developments are:
• Green Energy and Green Economy Act, 2009, enacted May 2009
• Discussion paper: Toward a Zero Waste Future: Review of the Waste Diversion Act, 2002 (EBR #010-4676, October 16, 2008)

5. Gaseous by-products

Section 7.2 (Approvals for a site where by-products from thermal treatment of municipal waste are combusted) is problematic:
"No waste approval is required for combustion of gaseous by-products generated through thermal treatment of municipal waste."
This appears to exempt plasma arc gasification plants such as the experimental Plasco (Ottawa) and proposed Sunbay (Port Hope) plants from stringent emission controls on the exhaust gases of the power generation engine. In these plants, high temperatures are used in the absence of oxygen to decompose carbon based matter into flammable gases (Plasco 2009). These by-product gases are then combined with oxygen and burned in a stationary engine powering an electric generator. It is unrealistic to expect that all potential pollutants have been removed from the gas prior to combustion, and furthermore that there is no synthesis of contaminants in the gases cool down phase in the turbine and after exiting. Addtionally, production of NOX is an inevitable by-product of combustion. It is recommended that monitoring and abatement requirements be extended to combustion of gaseous by-products of thermal treatment.

REFERENCES

Ontario Ministry of the Environment. Statement of Environmental Values
(accessed May 30, 2009)

Ewall, Mike, CEMS.XLS – Listing of Continuous Emission Monitoring Systems, Private correspondence, February 2009 (attached)

Energy Justice Network. Continuous Emissions Monitors
(Accessed May 30, 2009)

Commoner, Barry et al. Dioxin Fallout In The Great Lakes (Summary)
Center for the Biology of Natural Systems, Queens College, CUNY, Flushing, New York, June 1996
(accessed May 30, 2009)

Somers, Christopher M. et al. Reduction of Particulate Air Pollution Lowers the Risk of Heritable Mutations in Mice 14 MAY 2004 VOL 304 SCIENCE

Gatti, Antonietta M and Stefano Montanari. Nanopathology: The Health Impact of Nanoparticles, World Scientific Publishing Company, Nov 2007 ISBN 978-981-4241-00-7

Gatti, Antonietta M et al. Nanopathology: Clinical Cases: Lungs
(accessed May 30, 2009)

Plasco Energy Group Technology Overview Ottawa ON (accessed May 30, 2009)

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