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Exhibit 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711

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Exhibit 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 Exhibit 6 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY RESEARCH TRIANGLE PARK, NC 27711 AUG 102001 OFFICE OF AIR QUALITY PLANNING AND STANDARDS MEMORANDUM SUBJECT: Emissions from Large and Small MWC Units at MACT Compliance FROM: Walt Stevenson c4f OAQPS/SPPD/ESG (D243-01) TO: Large MWC Docket (EPA-HQ-OAR-2005-0117) This memorandum presents information on the overall emissions reductions achieved by large and small municipal waste combustion (MWC) units following retrofit of Maximum Achievable Control Technology (MACT). This memorandum is a companion to the memorandum titled "Emissions from Large MWC Units at MACT Compliance (note a). Consistent with Clean Air Act (CAA) section 129, large and small MWC units completed MACT retrofits by December 2000 and December 2005, respectively. The performance of the MACT retrofits has been outstanding. Emission reductions achieved for all CAA section 129 pollutants are shown below. Of particular interest are dioxinlfuran and mercury emissions. Since 1990 (pre-MACT conditions), dioxinlfuran emissions from large and small MWCs have been reduced by more than 99 percent, and mercury emissions have been reduced by more than 96 percent. Dioxinlfuran emissions have been reduced to 15 grams per year* and mercury emissions reduced to 2.3 tons/year. Emissions From Large and Small MWC Units Pollutant 1990 Emissions (!PY) 20Q5 E,:!1issions (tpy) Percent Reduction ----------_. ----_. .._-------- ._---- ... CDD/CDF, TEQ basis* 4400 15 99+% --f--- -- Mercury 57 2.3 96% Cadmium 9.6 0.4 96% Lead 170 5.5 97% Particulate Matter 18,600 780 96% HC] 57,400 3,200 94% SO} 38,300 4,600 88 % f-- NO, 64,900 49,500 24% (*) dioxinlfuran emissions are in units of grams per year toxic equivalent quantity (TEQ), using 1989 NATO toxicity factors; all other pollutant emissions are in units of tons per year. Internet Address (URl) • http://www.epa.gov RecycledIRecyclable • Printed w~h Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 2 The MACT performance data presented above is from the initial MACT compliance tests from all large and small MWC units. The inventory of large MWC units at MACT compliance identifies 167 large MWC units located at 66 MWC plants (note b). The inventory of small MWC units at MACT compliance identifies 60 small MWC units located at 22 MWC plants (note c). The baseline 1990 emissions data are from the large and small MWC emissions trend memo (note d and e). In combination, the above information defines the 1990 and 2005 emissions for large and small MWC units. notes (a) see docket A-90-45, item VIIJ-B-II. (b) see docket A-90-45, item VIII-B-6 (c) see docket OAR-2004-03"12, "National Inventory of Small Municipal Waste Combustor (MWC) Units at MACT Compliance (Year 2005)", dated November 1,2006. (d) see docket A-90-45, item VIII-B-7 , (e) see docket OAR-2004-0312, "National Emissions Trends for Small Municipal Waste Combustion Units [year 1990 - 2005]", dated June 12,2002. Exhibit 7 Re-birth of the United States Energy-from-Waste Industry Summary ofEnvironmental, Energy Security and Economic Benefits August 2009 Covanta Energy Corporation Summary o Energy-from-Waste (EfW, also called Waste-to-Energy or WTE) has the potential to provide disposal for nearly 270 million tons of United States (U.S.) municipal solid waste (MSW), approximately 40% of projected 2030 U.S. MSW generation. This would prevent the emission of as much as 270 million tons of greenhouse gases (GHG) annually. Etw GROWTH CAPACITY 300 50.0% .s= ~ Millions ofEfW Tons ~ ~ ~ 250 l. --+- % ofMSW Generation 0= 40.0% Q,) E-- .... 200 =Q,) 0 30.0% \,;) ~ 150 20.0% ~ ....=0 100 rJ"j = ~ 50 10.0% .... ~ 0 0 0.0% ~<= 2006A 2020P 2030P Source: 2006 data as per Biocycle and the Emth EngineeIing Center of Columbia University ("Biocycie/Columbia"), "The State of Garbage in AmeIica," December 2008. Please note, however, that on the basis of the U.S. EPA's "Municipal Solid Waste in the United States: 2007 Facts and Figures", the generation ofMSW in 2006 was significantly lower at approximately 250 million tons (versus -415 million tons under the Biocycle/Columbia study) and the MSW combusted with energy recovery (EfW) represented 12.6% of the total U.S. MSW (versus 6.9% under the Biocycle/Columbia study). The EPA data are based on estimates of waste generation, while the Biocycle/Columbia survey is based on the actual volumes of wastes recycled, combusted with energy recovery, and landfilled as repOlted to the Biocycle/Columbia survey by the waste management authOlities of the fifty states. In this report, the Biocycle/Columbia estimates were used. o An expanded EfW industry at this scale would produce approximately 184 billion kWh of electricity, over 3.9% of projected U.S. electricity demand in 2030, up 1 from 0.4% in 2006 : EtwENERGY PRODUCTION GROWTH 200 5.0% ~ EfW Energy Production ~ .~ -= 160 4.0% .i: --+- % of U.S. Electricity ~ ~ ..::: eJ .s= ~ ~ .... 120 3.0% eJ 0 ~ ~ "0= 80 2.0% rJ"j 0 = ~ l. ;§ .... ~ ~ 40 1.0% 0 ~<= 0 0.0% 2006A 2020P 2030P Source: U.S. Depmtment of Energy, Energy Infonnation Administration, U.S. ElectIicity Supply Data, APli12009. Note: Assumes 550 kWh energy produced per ton of MSW processing capacity in operation as of2006. Assumes 700 kWh energy produced per ton ofMSW processed from new EfW plants. I U.S. Department of Energy, Energy Infonnation Administration, U.S. ElectIicity Supply Data, ApIi12009. 2 o Expansion ofEfW capacity is compatible with both increasing recycling rates and decreasing landfilling rates. By 2030, recycling could account for more than 45% of U.S. MSW generation, with EfW processing just over 40%. According to the U.S. EPA, the U.S. recycled 85 million tons ofMSW in 2007 and such recycling 2 reduced emissions by 193 million tons of C02 equivalent • Assuming 2030 projected U.S. MSW generation, a 45% recycling rate and the EPA's recycling/OHO emission reduction factor (i.e., 193 million /85 million = 2.27), the recycling of ~300 million tons ofMSW in 2030 would reduce emissions by approximately 680 million tons of C02 equivalent. % of MSW Generation - 2006A EfW -6.9% Landfill-14.0% Landfill - 64.5% Landfill- 36.9% Source: 2006 data as per Biocycle and the Earth Engineering Center of Columbia University, "The State of Garbage in America," December 2008. o The construction and operation of new EfW facilities could provide over $518 billion of construction phase economic impact from 2010 through 2030 and create nearly 1.2 billion full-time equivalent construction jobs and nearly 54,000 good­ paying permanent jobs: Note: All dollar amounts expressed in 2009 dollars. 2 "Municipal Solid Waste in the United States: 2007 Facts and Figures," U.S. Environmental Protection Agency, November 2008. 3 Overview of Energy-from-Waste Energy-from-Waste (EfW) is a process that takes MSW, i.e., household trash, and transfers it into combustion chambers where it is burned at high temperatures and reduced to 10% of its original volume. The heat generated from the combustion chambers heats up water in steel tubes that fonn the walls of the combustion chambers. The water is converted into steam and sent through a turbine that continuously generates electricity. EfW plants operate on a 2417, or "baseload", basis without regard to prevailing weather conditions. Thus, EfW capacity can be productively located in any region or state within the U.S. EfW is currently classified as a renewable source of electricity by the Energy Policy Act of2005, the U.S. Department of Energy and by 24 state governments and the District of Columbia. Please see below for list of jurisdictions defining EfW as renewable as of January 1, 2009. Alaska Maine New York Arkansas Maryland Oregon California Massachusetts Pennsylvania Connecticut Michigan South Dakota District of Columbia Minnesota Virginia Florida Montana Washington Hawaii Nevada Wisconsin Iowa New Hampshire Indiana New Jersey The 87 EfW facilities in the U.S. collectively process more than 90,000 tons ofMSW each day, supply electricity to more than 2 million U.S. homes and provide stable, good­ 3 paying jobs to approximately 6,000 Americans . America's EfW facilities collectively generate "enough electricity to light all of the homes in Maine, New Hampshire, 4 Vennont, Rhode Island, and most of Massachusetts ." The U.S. EfW industry has been in existence for more than 25 years and has developed state-of-the-art technology making it one of the cleanest fonns of energy generation, meeting or exceeding all standards set by the U.S. Environmental Protection Agency (EPA). The need for and relevance ofEfW in the U.S. has never been stronger, but most EfW capacity was constructed 15 or more years ago and no new plant has been brought online in the U.S. in 13 years. In fact, according to EPA reports, the amount of annual MSW produced in the U.S. has increased by more than 40 million tons since the last new EfW plant was constructed. 3 "Waste Not, Want Not: The Facts Behind Waste to Energy," Integrated Waste Services Association (IWSA), September 2008. 4 "America's Own Energy Source," Published by the American Society of Mechanical Engineers, The U.S. Conference of Mayors, The Solid Waste Association of North America, and the Integrated Waste Services Association, December 2006. 4 Because local governments often sponsor EfW facilities, they directly benefit from the provision of state and federal government incentives for EfW capacity development, e.g., by enjoying stable waste disposal costs and expanded employment and tax bases. The situation in the U.S. contrasts sharply with what is going on elsewhere in the world, however, as EfW usage and capacity additions grow strongly throughout Europe and Asia.
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