H.04

Councillors City of Councillors Bruce Beck Lynne Harris Christine Caldwell Abbotsford Dave F. Loewen Simon Gibson Mayor Patricia Ross Moe Gill George F. Ferguson John G. Smith April 9, 2008 File No. 5510-04 TVPE DEPT 6 Mayor and Council

Corporation of Delta ^MMENT 4500 Clarence Taylor Crescent Delta, BC V4K 3E2

Dear Mayor and Council:

Re: Metro Vancouver's plans to build up to Six Waste-to-Energy Plants

Abbotsford City Council, at its meeting of March 31, 2008, considered a report on the potential for six Waste-to-Energy plants to be sited in the Lower Mainland as part of Metro Vancouver's solid waste management program. Council approved the recommendation of the report to distribute it to the other municipalities in the Lower Mainland. The report authored by Councillor Patricia Ross is attached for your information.

The City of Abbotsford is concerned with both the process to examine this alternative to regional solid waste management and the potential negative impacts on human health, the environment and the regional economy, among other things. The City believes that there should be much more investigation in this regard and hopes that your Council will also concur.

If you require further information regarding the attached information, please contact Councillor Patricia Ross at (604)864-5500 at gross i abbotsford ca .

Enclosure

c. Honourable Barry Penner, Minister of Environment and Minister responsible for Water Stewardship and Sustainable Communities Honourable , Acting Minister of Public Safety and Solicitor General and Minister of State for Intergovernmental Relations Honourable Michael de Jong, Minister of Aboriginal Relations and Reconciliation Mr. , MLA, -Sumas Mayor and Council of Metro Vancouver Municipalities Mayor and Council of Fraser Valley Regional District Municipalities Metro Vancouver Board Fraser Valley Regional District Board ASO 32315 South Fraser Way, Abbotsford, BC V2T 1W7 a^- Telephone: 604-864-5500 Email: mayort'erguson@abbotsford. ca Facsimile: 604-853-1934 www.abbotsford.ca COUNCIL REPORT ABBOTSFORD

March 26, 2008 Executive Committee

To: Mayor and Council From: Councillor Patricia Ross Subject: Metro Vancouver's plans to build up to Six Waste to Energy Plants

RECOMMENDATIONS

THAT the attached Report, dated March 26, 2008, from Councillor Ross, regarding Metro Vancouver' received; s plans to build up to Six Waste to Energy Plants, be

THAT Council and/or the Fraser Valley Regional District request to be on the panel at the Metro Vancouver Council of Council meetings and public information meetings; and

3. THAT a copy of this report and the related Council resolution be forwarded, as information, to lower mainland municipalities to provide a balanced prospective. Discussion:

The purpose of this report is to provide an update and further recommendation to Council regarding Metro Vancouver's plans to build up to six Waste to Energy (WTE) plants in the lower mainland. In addition, I wanted to provide information for Councillors so they will be prepared should they choose to attend the Council of Council meetings or public meetings.

As has already been discussed, these plants have the potential to significantly deteriorate the air quality in the Fraser Valley of BC due to our geographic and meteorological challenges which are quite unique in North America. We have a mountainous region shaped like a funnel. The valley narrows from the west to the east restricting both air movement and pollutant dispersion. Pollutants originating in the west and south are often pushed into the upper parts of the Valley, where they become trapped by the wall of mountains, often for very long periods of time. So we must be extremely cautious about adding any additional point sources of pollution. Keep in mind we are not talking about just one incinerator but up to six in one airshed, which is highly unusual if not altogether unheard of, and should be examined very seriously.

On April 19, 2008, Metro Vancouver will be holding a Council of Council meeting regarding options for dealing with the region's waste. They have extended that invitation to all Fraser Valley political representatives. In addition, there will be several public meetings throughout the lower mainland.

In all the literature that has been distributed to date, I am becoming increasingly concerned that so far all information presented is quite favorable to the WTE option and does not present the potential concerns or negative effects. I feel that it is important for Page 2 of 4

Fraser Valley representatives to be up front and express our concerns sooner rather than later. It is also extremely important for the decision makers in Metro Vancouver to hear these concerns so that they can make a more informed decision. It is not clear to me that they are getting the other side of this issue.

In addition, one of my greatest concerns is the process. To date, it seems WTE incineration is the favoured option and the decision has been made to move toward that with little or no meaningful consultation with either member municipalities or the Fraser Valley Regional District. It appears that the consultation process now before us is to be favoring WTE as a foregone conclusion rather than a discussion as to whether it should occur at all in this sensitive airshed. In other jurisdictions, proponents of WTE have convinced local authorities to bypass the Environmental Review process with claims of it being "green technology," which later appeared to be untrue according to Global Alliance for Incinerator Alternatives and GreenAction for Health and Environmental Justice. The process needs to be clarified. Will there be a public provincial Ministry of Environment approval process? If this energy is to be sold on the open grid, will there be a public process pertaining to that? The burden of proof should rest with those proposing these facilities demonstrating that there will be no serious negative impacts on public health, the environment or the economy. It should not be the responsibility of the potentially impacted communities to prove that it will be harmful.

The following are counter arguments to the information being distributed by those in favour of WTE. Proponents of WTE made many claims and I want to determine if they are accurate. In attempting to gather information on WTE, I had a long conversation with 2 representatives of Sierra Club, who specialize in solid waste issues. The other source was a joint paper produced by the Global Alliance for Incinerator Alternatives (GAZA) and GreenAction for Health & Environmental Justice (attached).

Following are the proponents' contentions. The response provides counterpoints.

Contention: This is not incineration. Response: Yes, it is essentially incineration. Because of its negative connotation, it is now referred to as thermal, plasma, gasification or pyrolysis. But these are just different kinds of technology for incineration. Granted though, incineration today can be far less polluting than the technologies of many years ago. But the question still remains as to whether it can possibly be made innocuous enough to be appropriate for this particular air shed. From what information exists so far, it appears that it cannot. It is important that the information comes from independent sources and not solely from the proponents. It will also be important, if not critical, to evaluate each proposal on a site by site basis and consider the current challenges of the airshed.

Contention: We can solve our energy needs at the same time we are solving our waste issues. Response: These technologies require a great deal of energy to operate, and some facilities have consumed more energy to operate than could be produced. Energy savings from waste prevention and recycling is likely greater than the energy produced in these disposal facilities.

Contention : There will be zero emissions. Response: The only people attempting to say this are proponents of WTE and there is no evidence to back this claim. Apparently, some technologies may be able to achieve Page 3 of 4

zero emissions up to a certain part in the process (questionable), but not all the way through. Also, often the publicized emissions ignore breakdowns (which appear to be frequent), start-ups and shut-downs, which will raise the emission levels significantly.

Contention : Any emissions will be offset by getting the trucks off the road that are currently taking the waste to the interior of BC. Response: This is not the case. These trucks are bringing mushroom manure and wood waste from the interior down to the lower mainland and will continue to do so. They will simply be going back empty, which is less efficient. Also, we have been advised these trucks have recently been retrofitted and achieved a 90% reduction in emissions.

Contention : Emissions from WTE compare favorably to coal and oil. Response: One should not compare it to the worst, but rather in a sensitive air shed such as ours, compare it to the best and WTE does not compare favorably to natural gas.

Contention : The favored plant so far, Plasco Energy, has a successful track record already in Ottawa. Response: It has only been in operation since October 24, 2007 as a demonstration/pilot project facility, then only accepting municipal solid waste full scale since January 24, 2008, so it is yet to be seen whether it is successful. For a population of Metro Vancouver's, which is over 2 million people, this is a significant consideration and has not been proven successful on a long term basis for a population this large.

Contention : We should deal with our own waste in our own back yard. Response: Firstly, with WTE, Metro Vancouver would still be exporting its waste, only it will be in the form of air pollution instead of it being hauled away by trucks. Also, this is not a realistic statement as few communities are truly self-sufficient in absolutely every way. Some of us export our sewage to be treated by another, or we import water from another according to need. Secondly, if we were forcing this waste on another community where it was not wanted by the majority, then it would not be a favorable option, but for some of these communities who are soliciting this waste, it is the difference between a ghost town and a thriving community.

Contention : WTE is an efficient way of dealing with our waste. Response: WTE is only an option if we have failed at everything else such as reusing, recycling and composting. If we are truly successful, it is not necessary. Even with incineration, there will still be a need for land filling the residual ash.

Contention: Sending our waste to the interior is no longer an option because the landfill in Cache Creek is closing. Response: The current site is almost full, but there is the very real possibility that it can be expanded. In addition, the Highland Valley Copper mine is another viable option. Admittedly, both of these options have hurdles to overcome in regards to receiving Native band approval, but this is far from a closed door and recent discussions look very promising.

Contention: Sending the waste to Rabanco in the United States is the best option and there are no current laws to limit the export of waste to the US. Page 4 of 4

Response : Note the word "current" laws. What will happen if that changes and we've closed the door to these other viable options? The State of Michigan recently altered its legislation after the City of Toronto started to send its MSW across the US border some years ago.

Contention : WTE is an effective option for dealing with our waste. Response: For the Fraser Valley, this decision is not simply about how to deal with the regions waste. It should include consideration of the human health effects as well as the impact on ecosystems and the agricultural industry. Regarding the latter, some pollutants have proven to reduce crop production by up to 15% (depending on the crop) and with 60% of the entire province's farm receipts coming from the Fraser Valley, this could significantly impact this important industry. A detailed analysis has not been completed to determine whether the proponents' claims are completely accurate or whether this is a viable option for this particular location.

Contention : It is commonly said that WTE incineration is being used successfully in Europe, so why not here? Response: Even WTE proponents have said that the regulatory framework that ensures the very best technology is used and that any infractions are dealt with expeditiously is very different in Europe than here. In Europe, there are incentives for the best technology, standards are very strict, monitoring and enforcement is extremely diligent and there are heavy fines for any infractions. We do not have that in Canada or the province of BC. Also, I cannot speak to the air sheds where they are located in Europe, but I know ours and I know we cannot tolerate any additional point sources of pollution. I am told however, that the airsheds in which these incinerators are located in Europe do not have the challenges of the Fraser Valley.

Conclusion: This information is by no means comprehensive at this point; however, is intended to flag the need for more information and provide an alert for decision-makers of the potential risks. For me, the bottom line question is whether the potential benefits outweigh the potential risks and considering the fact that there are so many unknowns and not enough of a proven track record to date, it does not. Perhaps one day in the future with advances in technology we truly will be able to achieve zero emissions with incineration, but we are not there yet and it appears to still be a long way off. This air shed is not the place to be testing it.

It is my opinion that we should request that we be allowed the opportunity, at the Council of Council meeting and public meetings, to be on the panel and make a short presentation outlining our concerns and the questions that we require answers for. In addition, I would recommend we distribute this information to all councils in the lower mainland.

Councillor Patricia Ross Gasification , Pyrolysis & Plasma I Incineration

What are waste gasification , pyrolysis, and plasma treatment/ disposal technologies? Gasification, pyrolysis and plasma technologies heat waste materials to high temperatures, creating gas, solid and liquid residues. The gases are then combusted, releasing hazardous pollutants. These technologies are considered "incineration" by the European Union, and are being considered in the U.S. for medical, municipal and hazardous wastes, which could reverse decades of progress in pollution prevention, waste prevention, and recycling. Other forms of municipal solid waste incineration (mass burn and refuse-derived-fuel) are no longer being built in the U.S

Releasing Toxics : The same toxic byproducts can be released from these Read case studies of incinerators as from other incinerators, including dioxins and furans, mercury and gasification, pyrolysis and other heavy metals, particulate matter, carbon monoxide, hydrogen chloride, sulfur plasma incineration that dioxide, and more, as well as toxic contaminants in the char or ash residues, and illustrate concerns about contaminated waste water . Many of these pollutants are carcinogenic and threaten emissions, energy and public health even at very low levels. Recent tests from municipal solid waste expense at (MSW) in a test pyrolysis facility in southern California found more dioxin, VOCs, www.no-burn orf and NOx, and particulate emissions than existing mass burn incinerators in the region. -www greenaction org

Some companies claim that these technologies are "pollution free" or have "zero emissions," but these claims have been shown repeatedly to be untrue. Since 2003 numerous proposals for waste treatment facilities hoping to use plasma arc, pyrolysis, catalytic cracking and gasification technologies failed to receive final approval to operate when claims of the companies did not withstand public and governmental scrutiny. Companies using or promoting these technologies claim that they are not incinerators, ignoring the fact that the toxic gases created by heating the waste are in fact combusted - incinerated.

Wasting Energy : These technologies require a great deal of energy to operate, and some facilities have consumed more energy to operate than could be produced. Like classic incinerators and landfills, energy savings from waste prevention and recycling is likely greater than the energy produced in these disposal facilities.

Technical and Financial Problems : The financial and technical feasibility of these incinerators is questionable. The only medical waste facility in the U.S. that uses plasma arc (the Hawaii Vitrification Facility run by Asia Pacific Environmental Technologies) has had serious and repeated operational problems as well as permit violations. A largest MSW gasification facility (Thermoselect, located in Germany) recently closed after only a few years of operation with chronic technical problems and losses of $500 million.

The Big Picture: Even if gasification, pyrolysis, and plasma arc could be made safe, the question remains: could they be made sensible? As with traditional incineration and landfilling, these approaches lead to exploiting more natural resources, rather than resource and energy conservation. Incineratlonjsdisplsa'1 M.rlrvtn[w'. Y. n O Although we volume ofgarbage appears to be greatly reduced by gasification and incineration, no technology can make anything actually disappear. Mass can neither be created nor destroyed, only changed.` Thegas imoke, andkgxid and soMd wastes that kae a fankty n it have the same mars as the solid maienalr entering the faakry. Masses of gas and particulates will go up the stack, toxic ashes and solid wastes will need to go to landfill, and liquid wastes will also need to be managed: *En

Global Alliance for Incinerator Alternatives (GAIAI: [email protected], 510-883-9490. no-burn.org Greenaction for Health & Environmental Justice: [email protected], 415-248-5010, greenaclion.org California scheming Orwellian language: California's "Conversion Technologies" is a misleading term California is the staging ground for the attempted U.S.

incinerator industry revival. Many local governments arc (ia.iIu It'd .. I "i. bu o,i,it currently considering some form of waste incineration. din Finn Der. inn Since 2003 numerous proposals for waste treatment 1 facilities hoping to use plasma arc , pyrolysis, catalytic "Conversion cracking and gasification technologies failed to receive final Technologies" approval to operate when the claims of project proponents Composting did not withstand public and governmental scrutiny of key claims.

California calls these technologies - and others that claim M:o. II„m, to produce energy from garbage - "conversion Rrfnxc lkrirnl Fool technolo ies" Unfortunately anaerobic digestion of source- separated organics, a form of composting, is lumped in the same category. This "conversion technology" term is only used in California, while other jurisdictions where these technologies actually exist, such as the European Union, consider gasification, pyrolysis, and plasma to be incineration.

This industry wants California to consider incinerator approaches like gasification equal to discard reduction, recycling and composting by saying they will "divert" garbage from disposal in landfills. But these incinerators dispose garbage to the landfill-in-the-sky and actually create new pollutants. The industry even attempts to package garbage as "renewable energy", but waste prevention and recycling actually mnsen'c energy. Current national recycling conserves the equivalent of 11.9 billion gallons of gas annually.

Safe Non-incineration Alternatives for Medical Waste and Pollution Prevention We encourage the use of safer, non-incineration technologies such as sterilization where facilities are properly regulated and well-operated. Pollution prevention, including the use of non-toxic alternatives to PVC plastics and mercury-containing devices, is also essential.

ZERO WASTE Escape the " bury or burn " trap. Please join us in moving towards Zero Waste. Through implementing zero waste practices both upstream (including reducing consumption, product redesign, clean industrial production and processes, reducing packaging waste, encouraging refillable containers, and toxics use reduction) and downstream (including reuse, composting, recycling, and materials recovery), many countries, cities and businesses are making significant progress towards zero waste.

Proven approaches that work: prevent waste and increase recycling and composting • Zero Waste creates jobs and is good for the economy. For example, U.S. recycling and reuse establishments employ 1.1 million people and gross $236 billion in annual revenues. Designing more recyclable, reusable and repairable products means more jobs for a vital industry. • Zero Waste saves natural resources by reducing consumption and making new items from recycled materials. Ruining materials through thermal and combustion processes means more materials need to be extracted from the earth to replace those resources. Zero Waste conserves energy through reducing demand for extraction and processing of raw materials, which is energy intensive. EPA analysis shows that recycling is more energy efficient than combustion.

For more information about zero waste approaches: GrassRoots Recycling Network, www.grrn.org Clean Production Action, www.cleanproduction.org Institute for Local Self-Reliance, www.ilsr.org Eco-Cycle, www.ecocyde.org

. 510-883-9490, no-burn.org Global Alliance for Incinerator Alternatives (GAZA): mwilson@ no-burn.org 5010. greenaclion.org Greenoclion for Health & Environmental Justice: greenaction @greenaclion .org. 415-248- Incinerators in Disguise Case Studies of Gasification, Pyrolysis, and Plasma in Europe, Asia, and the United States

Greenaction for Health and Environmental Justice 415-248-5010 www.greenaction.org

Global Alliance for Incinerator Alternatives (GAZA) 510-883-9490 www.no-burn.org

April 2006 2 Incinerators In Disguise: Case Studies

Table of Contents

Introduction ...... 3 Public Relations Claims Vs. Reality: Problems with Existing Facilities...... 4 The Onslaught of Proposals in the U .S ...... 5

Case Studies Thermoselect (Karlsruhe , Germany) ...... 8 Brightstar Environmental (Wollongong, Australia)...... 12 Hawaii Medical Vitrification (Honolulu , Hawaii, US).... 14 Allied Technology Group (Richland, Washington , US).. 16 Ebara ( Broga, Malaysia) ...... 18

Greenaction for Health and Environmental Justice Mission Statement Greenaction mobilizes community power to win victories that change government and corporate policies and practices to protect health and to promote environmental justice.

Global Alliance for Incinerator Alternatives (GAZA) Mission Statement GALA is a worldwide alliance of non-profit organizations and individuals who recognize that our planets finite resources, fragile biosphere and the health of people and other living beings are endangered by polluting and inefficient production practices and health-threatening disposal methods.

We oppose incinerators, landfills, and other end-of-pipe interventions.

Our ultimate vision is a just, toxic-free world without incineration. Our goal is the implementation of clean production, and the creation of a closed-loop, materials-efficient economy where all products are reused, repaired or recycled back into the marketplace or nature. Incinerators In Disguise; Case Studies 3

Introduction

Incinerators in Disguise: Toxic Threat to Health, Environment, Pollution Prevention, and Renewable Energy

From California to Asia and beyond, communities are facing an unprecedented onslaught of proposals from waste treatment companies and entrepreneurs promoting a new generation of incineration technologies . Not since the waste industry tried to site hundreds of hazardous and solid waste incinerators in the United States in the late 1980's and early 1990's has there been such an intense effort to site new waste treatment facilities.

Today, many dozens of companies are promoting technologies such as pyrolysis, gasification, plasma arc, and catalytic cracking as a way to allegedly eliminate and "recycle" all types of waste into energy. Many of these companies falsely and boldly claim their technology is "pollution-free" and has "no emissions." Aware of the public's opposition to incineration, the companies promoting these technologies all claim these are not incinerators but are a "green" alternative to incineration.

Despite the grandiose claims of industry, the facts prove that these technologies are in reality "incinerators in disguise" that heat the waste materials, and then burn the waste gases and emit dioxin and other pollutants into the air.

Across the United States, municipalities, counties, state agencies and hospitals are now considering proposals for so-called "conversion technologies" This trend is now spreading across the world, with these technologies being proposed in countries large and small.

The stakes are high. If implemented, the countless proposals for these new incineration facilities may very well result in a profound impact on society and the environment from air and water pollution, the threat to public health, and the potential to devastate recycling, pollution prevention and renewable energy programs. These new incineration facilities would reverse decades of progress achieved by communities and the environmental health and justice movement to dramatically reduce the number of waste incinerators across the country and promote pollution prevention, safe treatment technologies and dean, renewable energy.

Exploiting legitimate concerns about emissions from traditional incinerators as well as the ongoing landfill crisis, the waste industry has targeted communities, counties and state legislative and regulatory bodies in an attempt to site these incineration technologies.

California has become a key focus of the waste industry promoting these technologies. There are dozens of actual or pending projects being proposed using plasma arc, pyrolysis, gasification, catalytic cracking, or a combination of these technologies for virtually every type of waste, including solid waste, sewage sludge, tires, fireworks, and medical waste. Many of the companies also claim they can treat hazardous and radioactive wastes. Jurisdictions are considering these technologies as a way to address waste disposal or to provide energy. Incinerators In Disguise: Case Studies 4

The industry and its allies are pushing legislation in California to encourage the siting and financing of facilities. The California Integrated waste Management Board has mode at least one large loan for a catalytic cracking facility proposed by Plastic Energy LLC for Hanford in the San Joaquin Valley despite the lack of any data to back up the company's claims of no emissions. The California Pollution Control Finance Authority is now being asked by InEnTec for tax-exempt bonds to help finance their proposed plasma arc medical waste facility in Red Bluff, located in Tehama County in northern California.

Counties such as Los Angeles and Santa Barbara in California are considering these technologies, but are relying heavily on industry studies. For example, URS Technology released a report in September 2005 commissioned by Los Angeles County that ranked Thermoselect gasification technology as the most promising of the companies URS considered, a curious model as Thermoselect's flagship facility in Germany was a failure and closed in 2004. The URS report refers to Interstate Waste Technologies, the U.S. licensee of Thermosclcet's gasification technology.

Adding to the concern of community members and public health advocates is the fact that the projects seen to date are getting approved in California without Environmental Impact Reports, and in some cases without real public notice or public hearings. Many government agencies and regulators on local, state, and national levels are failing to scrutinize the claims being made by many companies, and are quick to approve and support these so-called conversion technologies. In many cases, the media has repeated the public relations claims of companies without investigation, only to find out later that certain key industry claims, such as "no emissions," were not true.

Public Relations Claims Vs. Reality: Problems with Existing Facilities In the United States, there have been only a few companies using these technologies commercially for waste treatment, and the operations at the two facilities where information is available were plagued with problems. These case studies document the problematic nature of these technologies on three continents.

Allied Technology Group operated a plasma are facility for mixed radioactive and hazardous wastes in Richland, Washington, and the facility closed due to operational problems with the plasma arc equipment as well as financial problems. The Hawaii Medical Vitrification facility run by Asian Pacific Environmental Technologies near Honolulu has also had serious operational problems as well as serious permit violations. For example, the Hawaii Medical Vitrification facility was closed for approximately eight months due to refractory damage in the kiln of the plasma arc equipment.

Both the Allied Technology Group and the Hawaii Medical Vitrification facilities used Integrated Environmental Technologies' (lET) "Plasma Enhanced Melter" equipment. IET and their related company InEnTec claimed on their website that these two facilities were successful commercial operations using their technology, but the facts show that there were severe problems with the plasma arc equipment at both facilities. Incinerators In Disguise: Case Studies 5

A number of facilities have closed due to operational problems, including fheniaoselect's large municipal solid waste (MS' gasification facility in Karlsruhe, Germany and Rrightstar Environmental's flagship MSW gasification facility in Australia. Both facilities exceeded emissions limits for various pollutants during emissions tests. The Thermoselect facility's parent company lost over $500 million due to repeated breakdowns and technical problems and was never capable of operating at expected capacity before it closed in 2004. Brightstar Environmental's facility closed in 2003, and the company no longer exists.

Since 2003 numerous proposals for waste treatment facilities hoping to use plasma arc, pyrolysis, catalytic cracking and gasification technologies failed to receive final approval to operate when the claims of project proponents did not withstand public and governmental scrutiny of key claims.

The Onslaught of Proposals in the U.S.

North American Power Company Pyrolysis Proposal , Chowchilla , California' In August 2003, Greenaction for Health and Environmental justice, a nonprofit organization that works with communities on pollution and health issues, learned from the California Department of Health Services that North American Power Company was about to receive permits for the state's fast pyrolysis facility for medical waste, to be located in the diverse, working class community of Chowchilla in the San Joaquin Valley. The company claimed there would be no hazardous emissions, and the city, state, and Air District regulators were days away from approving the project without ever notifying residents or requiring an Environmental Impact Report. Greenaction researched the technology, confirmed there would be emissions resulting from the burning of waste gases created from the heating of the medical waste, and started notifying residents. After Greenaction met with city officials, the city held off on approving the Conditional Use Permit and requested that North American Power Company provide more information to back up their claims. In response to the city's request and increased community awareness of the proposal, North American Power Company withdrew their proposal at the last minute when they could not back up their claim of zero emissions.

Alameda Power and Telecom Rejects ' Conversion Technologies" In 2003, Alameda Power and Telecom (APT), the public power agency of the City of Alameda, California, began a study to look at technologies that might help generate small amounts of power for future city energy needs. APT spent over $500,000 hiring consultants, who assured city officials, the media and the public that gasification technologies would have no emissions and could generate electricity cleanly by treating solid waste. One of APT's consultants, Dan Predpall of URS Corporation, shocked residents and recyclers when he told the Alameda Public Utilities Board that they would no longer have to recycle, as that would now be unnecessary as a gasification plant would supposedly be the new recycling technology.'

APT had first discussed siting the garbage plant in a low-income community of color in San Leandro, without discussing this with residents or city officials. Residents and environmental justice groups responded by forming a three-city grassroots coalition that challenged the claims of "no emissions" and advocated for clean, renewable energy, and the mayor of San Leandro spoke strongly Incinerators In Disguise: Case Studies 6 against the project' The Alameda Public Utilities Board expressed reservations about the claims of the city's own consultants and voted against proceeding with further study on these "conversion technologies" until a future time when there might be more verifiable data upon which to base a decision.' The utility also modified its criteria for new electricity sources to exclude anything considered an emerging technology, including MSW gasifications

Romoland Pyrolysis Emissions Higher Than Other Incinerators in Los Angeles Area Neoteric Environmental Technologies and International Environmental Solutions have built a plasma arc/pyrolysis facility in Romoland, located in Riverside County, California. Neoteric is interested in a commercial waste operation at this location, and in having a showcase facility to allow them to market this technology elsewhere. Residents were never fully informed about this facility, which was built without an Environmental Impact Report. The company did not pass test burns conducted in 2004 on sewage sludge and fireworks.' Tests using municipal solid waste conducted in 2005 were declared a success by the company,' but analysis by the South Coast Air Quality Management District determined that the pyrolysis facility emits more dioxins, NOx, volatile organic compounds and particulate matter than the two existing large municipal solid waste incinerators in the Los Angeles area.'

Plastic Energy LLC Loses Permits for Catalytic Cracking Facility Proposals Plastic Energy LLC received permits in 2002 for a proposed catalytic cracking facility in Hanford in the San Joaquin Valley of California. Plastic Energy claimed they would generate electricity and turn plastics into diesel without any emissions. The project was initially approved by the Icings County Planning Department without public notice or an Environmental Impact Report, and was completely exempted from any review under the California Environmental Quality Act. In August 2004, residents and Greenaction challenged the permits and forced the San Joaquin Valley Air Pollution Control District to cancel the permits their agency had previously issued to Plastic Energy due to the lack of data supplied by the company to back up its claims. In November 2004, company officials attended a forum organized by a community coalition, where they admitted their technology would have toxic emissions, admitted they did not have data from similar facilities that they earlier had said they did have, and announced they were temporarily stopping their project. Plastic Energy has not reapplied for permits.

Global Energy Resources Drops Proposal in Sierra Vista , Arizona Arizona has recently become another battleground in this issue, with a company called Global Energy Resources targeting rural areas for a proposed facility. In late 2004, Global Energy Resources began an attempt to site a facility in Sierra Vista, located in Cochise County in southeast Arizona that the company said would use plasma arc technology to treat solid waste and tires. The company claimed their project would have no emissions, and also claimed on their website that they "owned and operated" similar facilities. When challenged on these claims at a meeting of the Cochise County Board of Supervisors during the spring of 2005, their consultant admitted there would be some emissions. It quickly became clear that the company did not and never had owned or operated any such facilities. Faced with increased concern and skepticism from elected officials and residents, Global Energy Resources dropped its proposal."' The company then focused its energy in an attempt to site a facility in Eagar, located in Apache County in rural northeast Arizona. The company has expressed an interest in other waste streams in addition to solid waste and tires. The proposed facility in Eagar is being met with strong community opposition. Incinerators In Disguise: Case Studies 7

Permit for InEnTec Medical Services Rescinded by Appeal Hearing Board Authorities to Construct permits issued to InEnTec Medical Services California LLC for a proposed medical waste plasma arc facility in Red Bluff, California were rescinded in December 2005 by the Tehama County Air Pollution Control District Hearing Board after the permits were appealed by residents and Greenaction.'

The Hearing Board ruled 3-1 to rescind the permits issued to InEnTec, after ten hearings that spanned over three months. The Hearing Board's ruling was based on findings including the fact that there were substantial changes to the project, significant new information had not been evaluated by the regulatory agencies, and there were concerns about the adequacy of InEnTec's datala

The Tehama County Air Pollution Control District did not have a public comment period or public hearing before issuing permits, and approved the air permits for InEnTec Medical Services (related to Integrated Environmental Technologies) in)uly 2005. In December 2004, the Teharna County Planning Commission approved InEnTec Medical Services' project as a power generation facility, without an Environmental Impact Report." Some InEnTec documents claimed their technology was "pollution-free" and did not produce dioxins, despite the fact that their own test results from a research project showed emissions of dioxin and other pollutants.'4 InEnTec also boasted that their technology (Integrated Environmental Technologies LLC's "plasma enhanced melter") was being successfully used at commercial facilities including the Hawaii Medical Vitrification plant and the Allied Technology Group facility (Richland, WA), despite the serious problems at both plants. InEnTec hopes to site similar plants around California, across the U.S and the world, and wants facilities to treat a wide range of waste streams including medical, solid and hazardous wastes.

Endnotes: 'Lisa Aleman- Padilla, "Medical Waste Disposal Criticized," Fresno Bee, 26 Aug. 2003; Patty Mandrell, "Meeting Address. Medical Waste Facility," Chowr hew, 8 Oct, 2003. '- Alameda Public Utilities Board meeting , witnessed by report authors, Alameda, CA, 2004. ' John Geluardi, "Alameda'Gas' Plant Proposal Draws Fire," Al ameda T_ 30 June 2004. 4 Susan Fuller, "AP&T's Trash for Energy Study Comes to a Close," font, Costa Times, Oct., 2004. 'Susan Fuller, "Tnsh-for-Energy Talks likely to End Monday," Conte Times I ' Personal communication with South Coast Air Quality Management Distort, 6 Oct. 2005.e 2004. 7 IES presentation to the California Assembly Natural Resources Committee, 16 Nov. 2005. a Presentation by South Coast Air Quality Management District to California Integrated Waste Management Board, 20 Sept. 2005, available at ha /wwu. 'v b / d l /.4_ g rya n Confumation of this presentation i data being the same as the finalized analysis (with the exception of heavy metal emissions data, which were considered invalid), by personal communication with the SCAQMD, April 7, 2006. Eiji Yamashita, "Citizens Criticize Plastics to Diesel Project Proposal," The Sentinel [Hanford, CA] 16 Nov. 2004; Eiji Yamashita, 'Technology for Plastic to- Diesel is New , Untested ," The Sentinel [Hanford. CA], 17 Nov. 2004. 'O Michael Sullivan " "Memorandum on Plasma Ann's Dead Issue '," Serra Vista H ld [Sierra Vista, AZ] 29 June 2005. 11 Cheryl Brinkley, "Appeal wins on InEnTec," Red Bluff Daily N [Redbluff, CA] 23 Dec. 2005. '=Final findings of the Hearing Board, Tehama County Air Pollution Control District, January 24, 2006. "Cheryl Brinkley,"InEnTec Appeal Date Set"Red Bluff Daily N [Redbluff, CA] 10 Sept. 2005. 14 Integrated Environmental Technologies, LLC, . Incinerators In Disguise: Case Studies a

Case Studies

Thermoselect

Name of facility : Thermoselect Karlsruhe

Owner: Switzerland-based Thermoselect (^^^*nv thcrmn.deer.com) provided the technology for the Karlsruhe Thermoselect facility. The Karlsruhe facility was owned by a subsidiary of a large German energy corporation called Energie Baden-Wurttemberg (EnBW, www.enbw.com). Themtoselect's technology is licensed to Interstate Waste Technologies in the United States and Caribbean region, JPE in Japan, and Daewoo in South Korea.' The technology has also been marketed under the names of Thermolink in Ireland and GADAT in the Philippines.

Location : Karlsruhe, Baden-Wurttemberg, Germany

Technology: Gasification followed by combustion of gases for municipal solid waste

Status: Closed in November 2004. Operated in an extended test phase from 1999 to 2002, in commercial operations from 20022 to 2004.'

Thermoselect's Karlsruhe facility was once one of the world's largest municipal solid waste (MS\X>) gasification incinerators , designed to process 225,000 tons of municipal wastes per year. Recurring operational problems that led local press to rename it "Thermodefect " prevented the facility from reaching full operating capacity.' During its operations the facility was only able to dispose of one- fifth of the total quantity of contracted waste, forcing cities that had contracted with the facility to find new disposal options.' By the time facility -owner EnBW decided to close^T1^h^1ermoselect Karlsruhe in 2004, it had lost at least 400 million Euros (approximately $ 500 million) on MSW gasification.'

Thermoselect's promotional material, including its website , makes claims about the technology's environmental performance such as "completely destroys dioxins and furans"a and "harmful substances contained in the waste are also completely destroyed ."" Neither of these statements is true, as plainly shown in the company 's contradiction of itself on the same webpage in a table listing the technology's emissions , including dioxins / furans, sulfur dioxide, carbon monoxide, hydrogen chloride, hydrogen fluoride, total carbon, mercury, cadmium / thallium, and total heavy metals."'

The Karlsruhe facility was forced to close temporarily in 2000 after releases of toxic gas were discovered, and operational problems during the years of test operations included an explosion, cracks of the high temperature chamber's concrete due to corrosion and heat, and a leaking sediment basin that held cyanide-contarninated wastewater ." The regional government admitted that the walls of the chamber were so battered that pieces had fallen off and could have caused an explosion.'2 In the first year of operations it was discovered that the facility had been using an emergency gas release vent, the existence and use of which the operators had failed to mention to regulators and the community during the permit process." Incinerators In Disguise: Case Studies 9

The facility set off emissions alarms for both total organic carbon (rOC) and nitrogen oxides (NOJ in 2002" and exceeded emissions limits for TOC, NO, and particulates during tests in 2000." The gas released from the emergency release chamber exceeded regulatory limits for dioxins, heat77 metals and other pollutants.." Another monitoring sample found dioxins in cleaned gases at above regulated levels, in one case exceeding the limit of 0.1 ng/m by a factor of seven. In two out of three cases within a few days dioxins levels were higher in the "cleaned" gases than in the gases before "cleaning" in pollution control devices." Thermoselect's Karlsruhe facility at times exceeded limits for hydrogen chloride (I ICI) emissions.'" I-ID is a precursor to formation of dioxins.

Thermoselect Kadsmhe's operating difficulties were reflected in energy inputs and outputs, an indication of the facility's energy balance. In 2002 the facility used 17 million cubic meters of natural gas to heat the waste, and did not deliver any electricity or heat back to the grid."

EnBW started construction of another Thermoselect MSW gasification incinerator in the German city of Ansbach, but the facility did not receive operating permits and was never completed because of problems at the sister-facility in (Karlsruhe." After massive financial losses from the Karlsruhe facility, EnBW is currently suing Thermoselect for the costs of dismantling the facility and the facility's loan payments."

The operational problems at Thermoselect's Karlsruhe incinerator followed convictions for environmental violations at the company's first MSW gasification facility in Fontodoee, Italy. In December 1999, the founder and chief engineer of Thermoselect and two board members were convicted in an Italian court for environmental violations including contamination of a nearby lake with poisonous compounds including cyanide, chlorine and nitrogen compounds." The Thermoselect officers were sentenced to six months probation and fines between 50,000 and 100,000 DM. The same facility had operating problems and was unable to operate at full capacity for longer than one month at a time before shutting down."

The websites of both Thermoselect and the U.S. licensee of the technology, Interstate Waste Technologies, mislead the public by stating that the Karlsruhe facility is still in operation and failing to mention the insurmountable technical problems at the facility. As of November 10, 2005 - a full year after the facility was shuttered - the Thermoselect website inaccurately states: "The Thermoselect facility was started up in January 1999 after a twenty month construction period and is today in unlimited continuous operation.""

The use and discharge of water is a critical issue in most communities. Despite Interstate Waste Technologies' claim on its website that the Thermoselect technology has no water emissions is the Karlsruhe Thermoselect facility disposed of approximately 120,000 cubic meters of wastewater into the Rhine River in 2003.26 Further refuting this claim, Thermoselect's officers in Italy were convicted of contaminating a lake with polluted wastewater.

Thermoselect's reputation has been damaged not only by operational problems but also by scandals. In 1995, the company gave DM 100,000 (approximately $85,000 in 2005 U.S. dollars) to the Baden- Wurttemberg CDU (Christian Democratic Union) political party which led the state at the time' The company has also been linked to attempts to bribe politicians to site facilities in Switzerland and Austria.' Incinerators In Disguise: Case Studies 10

The Karlsruhe incinerator inspired opposition from members of the community and local poll ticians. Repeated setbacks and shut downs in Karlsruhe, along with involvement of Karlsruhe community members, helped stop proposed Thermoselect facilities in the German cities of Herten, Bremen, Berlin and Hanau, as well as in Lebanon, Austria, Poland, and Tessin, Switzerland near Thermoselect's headquarters.

Endnotes: =DasUntemchmen@m=D> Th Io ect The Companv (Viewed 21 July 2005) , Thrrm,s,lect1 Process Chanetetisti , < hap://uww.thermoselen . (Viewed 2 Aug. 2005). cfm?(useacuon =Umwdl&m=2> (Viewed 2 °Thtrrnrq,kc The E v' ment, < http: //www.thermoselea.com/index . Aug. 2005). (Viewed 2 mTh 1 T6 Emdronme nt Aug. 2005). ffe]," Die Taveszeimng " Bernhard Baldas, "Magic Gone from Miracle Garbage Weapon [Entzaubene Mullwunderwa [Germany] 28 Aug. 2001. loll theses Jahr halbiert "- F " ki h 1 d i _ g, "Natural Gas Use Should Be Halved This Year [Erdgas -Verbrauch wcrden]," 29Jan. 2003. fe)," Die Tageszeitung 11 Bernhard Baldas , "Magic Gone from Miracle Garbage Weapon [Entzaubene Mullwunderwaf )Germany) 2B Aug. 2001. " Trade Control Office Karlsruhe , Thermoselect emissions data, 2002. )," S July 2000. u S ens 7cionca , "lawsuit Against Thermoselect [Anzeigt gegen Thermoselect . 2000; TUV Pfalz (technical control "Jurgen Dahikamp, "Defective Miracle [Defektes Wunder]," Dr, Sp ica, 25 Sept February and March 2000. association) measurements of combusted refined synthesis gas, tests during Incinerators In Disguise: Case Studies 11

"District Adminisvadon of Karlsuhe (Regiemngsprasidium Karlsruhe), press «Icase, 5 Nov. 1999. '"District Administration of Karlsruhe (Regiemngsprasidium Karkmhc), press release , 5 Nov. 1999. Fr9nkische L ndeszeimn "Natural Gas Use Should Be Halved This Year [Erdgzs-Verhrauch soil diesel ]ahr halhi,m werden];" 29Jan. 2003. 21 Ulrich Rach, "A Prick in the Flesh [Ein Stachel im Fleisch]" Nurn6 g N- h , 13 Sept. 2004. 2' Andreas Muller, The Story of the'Garbage Miracle' Ends in the Courts" ]Die Geschichte des 'Mulluvnders' ended vor Gericht], Stun ner Zititual;-^ fSturrgur, Germany) 20 Oct. 2005. '-' Fmnkfurrer R d h [Frankton , Germany], "Incident Halts Incinerator Project Regulators Want Nov Review fine Technology Planned for Hanau [Stbrfall bremst Mullofenprojecr . BehOrde will die for Hanau geplante Technik emetic prufen)," 22 Dec. 1999. 21 Bernhard Baldas, "Magic Gone from Miracle Garbage Weapon [Entzaubcrte Mullwundcrwaffc];' D's Txesze't [Germany] 28 Aug 2001, '-' Thermoselect Fa in KC an, < http: //www.thermoz (Viewed 21 July 2005). T h 1 _ (Viewed 10 Nov . 2005); lntcrcrate h 1^ ^. (Viewed 10 Nov, 2005). a^ Wolfgang Heininger, "Skepticism from Hanau Opponents Proves Time Karlsruhe Thermoselect Garbage Oven on the Verge of Closing Completely Die Skepsts. der Hanauer Gegner bcst5rigi rich. Karlsruher Thermoselecr- Mullofen droh t endgultiges Aus)," Frankfurter R d h 29 July 2003. '-v Meinrad Heck, "Garbage Miracle Thermoselect Brings Trouble [Mulluvnder Thermoselect bring[ dicke Luft]," Sturrga rrer Z February 7, 2005. The Garbage Debacle in Tessin Pas Kehrichtdebakel im Tessin]," 19 April 1997. "Bernhard Baldas, "Magic Gone from Miracle Garbage Weapon [Entzauberte Mullu'undeewaffe]" Die Tag a . F [Germany) 28 Aug. 2001 ; Jurgen Dahlkamp, "Defective Miracle [Defektes Wunderl," 2000. Der Snienel 25 Sept. Incinerators In Disguise: Case Studies t7

Brightstar Environmental / Energy Developments Limited

Name of Facility: Brightstar Environmental

Owner: Brightstar Environmental (former website: www.brightstarenvironmental.com) was a subsidiary of Energy Developments Limited (www.energydevelopments.com). Energy Developments is no longer pursuing SWERF (Solid Waste & Energy Recycling Facility) technology. Brightstar Environmental is no longer in operation.'

Location: Wollongong, New South Wales, Australia

Technology : Gasification followed by combustion of gases and oils (pre-processing included autoclaving) for municipal solid waste

Status: Closed in April 2004. Commercial-scale facility operated in test phase from 2000 to 2004.

Brightstar Environmental's gasification technology was called the Solid Waste & Energy Recycling Facility, or SWERF. Although both Brightstar Environmental and its parent company Energy Developments Limited aggressively promoted the SWERF technology in many countries, only one facility was ever constructed. The facility was designed to dispose of 30,000 tons of municipal waste per year, and the company planned to expand in order to dispose of 150,000 tons per year 2 By the time Energy Developments decided to close the facility, it had lost at least Au$175 million (LS$134 million) on SWERF.'

Brightstar Environmental intended to operate as a commercial facility and had a processing agreement with the city of Wollongong, but repeated technical problems prevented the technology from moving out of test phase. After two years of test operations, an Energy Developments press release stated that "a run of 50 hours [has] been achieved " but that the facility was having problems with "minor material handling issues."'

The SWERF technology had additional technical problems with the following components: • Replacement of second gasification unit for char (solid residues)' • High levels of fine particles in the char gasification unit' • Gasifier feeding system' • Preprocessing drying system"

Emissions tests in 2001 observed the following problems: result for sulfuric acid mist and/or sulfur trioxide was found at nearly twice the allowable limit in the facility's permit'; arsenic exceeded the limit in the facilities permit'"; NO, emissions were high (tests showed 190-300 mg/m'; as a comparison, the German NO, limit is 200 mg/Nm'), ' and carbon monoxide emissions were very high (tests showed 681 mg/m'; as a comparison the German CO limit is 50 mg/Nm').'2 The same tests found emissions of dioxin, hydrogen chloride, hydrogen fluoride, polyaromatic hydrocarbons, Incinerators In Disguise: Case Studies 13

hexachlorobenzena, heavy metals, and other chemicals of concern. Brightstar's website admitted to emissions of dioxins, heavy metals, NOx and other chemicals of concern.'

Energy Developments unsuccessfully tried to sell Brightstar Environmental in 2003 and in mid-2003 Energy Developments announced it would stop funding SWERF development activities." In April 2004, Energy Developments abruptly announced the closure of the Wollongong facility. The city of Wollongong had invested over US$1 million in the facility, however it inherited the buildings on the site once Brightstar Environmental left. The site will become a green waste facility and transfer station.,, 11,

Before closing it, Wollongong facility, Brightstar had entered negotiations with the Australian cities of Gosnell and Salisbury, as well as the cities of Kent and Derby in the United Kingdom. The company also tried to site facilities in a number of cities in India and the U.S.. All have now been cancelled." of these contracts

Endnotes: Phil Stubbs, "SWERF recycling plan is binned," Derhv Event T I h ]UIC] 4 Mar. 2005. Energy Developments Limited, "SWERF: Amendment ofAgreemenr with the City of Wollongong;' June 2002. press release, 13 a Rod Myer, "EDL Prepared to Give Up on Recycling Project," T&9ee IAusualia] 23 July 2003. 4 Energy Developments Limited,'Whyges Gully SW'ERF Technical Performance Update - Progress cress release, 13 Dec. 2002. Encouraging;' gEnergy Developments Limiied, "EDL Board Approves New SWERF Char Gasifier;" press release, 7 June 2002. 6 Energy Developments Limited, "EDL Board Approves New SWERF Char Gasifier," press release ° Energy Developments , 7 Junc 2002. Limited, "Half Yearly Report of EDL's SWERF Business," press release, 25June 2001. Energy Developments Limited, "Hal (Yearly Report of EDL's SWERF Business," press release 25June 2001. Brightstar Envi onmennl. "Emissions Data from Solid Waste and Energy Recycling Facility (SWERF)," 1-2 Mar. 2001. 1O Brightstar Environmental, Emissions Testing from July 3 and 18, 2001, presented at the Whytes Gully SWERF Community Consultation Committee Meeting, 15 Nov. 2001. s t Brightstar Environmental, Emissions Testing from July 3 and 18, 2001, presented at the Whytes Gully SWERF Community Consultation Committee Meeting, 15 Nov. 2001. 12 Brightstar Environmental, Emissions Testing from July 3 and 18, 2001, presented at the Whytes Gully SWT,RF Community Consultation Committee Meeting, 15 2 Nov. 2001. Brightstar Envivonmennl , < http: //www.brightstaremironmentalcom> (Website is now closed. A cached version from 24 Jan. 2005 from Google is available at htrp://uw le .com/search ?q=c2chc :y o-]1'blg] VUJ: &hl ighEstar"vironmental , e%2520set/envte com/hurl /env`/o2S20fram enwexthtm+ site:bdghtsta em r nmental .com&hl=en=cn I. 14 Energy Developments Limited, "ENE to cease SWERF development expenditure and focus on traditional energy business," press release, 21 July 2003. 1a City Council , "Disappointment at End of SWERF Project," press release , 31 Mar. 2004. t6 Minutes of the meeting of the Wollongong Neighbourhood Committee ? No. 7, 17 Feb. 2005, http://aw.wollongong.nsw.gov.2u > (Viewed 4 Aug. 2005). Brightstar Environmental , (website is now closed . Cashed versions of the website pages are available from Google at V tp:// u.gcom/search. 2005 ? q-site:brightstarenvironmenmlcom&,hl=en&h=&start =50&,sa=N; iewed 4 Aug. 2005). Incinerators In Disguise: Case Studies 14

Hawaii Medical Vitrification Facility/Asia Pacific Environmental Technology

Name of Facility : Hawaii Medical Vitrification

Owner: Asian Pacific Environmental Technology

Location : Honolulu, Hawaii

Technology: Plasma Arc ("Plasma Enhanced Melter") from Integrated Environmental Technologies (IET) for medical waste

Status: Commercial medical waste facility

Asian Pacific Environmental Technology (APET) operates the Hawaii Medical Vitrification (HMV) facility. The facility was built in 2003 in response to the closure of a large medical waste incinerator and a demand for new waste disposal options. APET uses the "Plasma Enhanced Melter" plasma arc technology of Integrated Environmental Technologies LLC (IET). APET told the Honolulu Advertiser newspaper in March 2002 that the plasma arc technology was an electrical energy process that "breaks items down to their basic components, hydrogen and inert material "! The article failed to mention the issue of emissions of hazardous pollutants.

Despite several years of commercial operations, as of October 2005 there had never been air emissions testing or monitoring of air ernissions at the facility. The State of Hawaii and the United States Environmental Protection Agency did not require testing or monitoring of emissions due to the small amounts of waste being treated at the plant,' despite the fact that tests done by the manufacturer of the plasma arc equipment, IET, documented emissions of dioxin and other pollutants.' HMV has submitted a new permit application requesting permission to increase the amount of medical waste they treat.

In May of 2004, the State of Hawaii Department of Health (DOH) filed a complaint against Asia Pacific Environmental Technology/Hawaii Medical Vitrification for serious violations, including the storage of excessive amounts of untreated infectious medical waste which violated the state's solid waste rules. The Department of Health imposed a penalty of $60,270 for these violations .' According to the DOH complaint, between April and October of 2003 APETs HMV facility illegally stored between 9,724 and 90,239 pounds of untreated infectious medical waste at their facility. The facility had continued to accept waste even though its permitted storage capacity was exceeded when the plasma arc system was out of service and could not process the waste. Information submitted by HMV to the Department of Health indicated that the PEM system was out of service from May 27 to August S, 2003. Daily reports submitted by the company to the State DOH show that the company continued to exceed its permitted infectious waste storage capacity from October 29, 2003 through March 12, 2004.'

The company also violated permit conditions by failing to test their end products quarterly, and instead had tested only once for microbial cultures and heavy metals . APET/HMV failed to allow Incinerators In Disguise: Case Studies 15

the I-Iawaii Deparmaent of I leaf rh (DOl-I) to conduct a complete inspection of the faclDry in 2003. Sam Liu, president of Hh1V, told regulators that they could not take pictures of a pile of sharp containers because it was a problem and would look bad.'

From August 2004 to April 2005 (a period of approximately eight months), HMV was shut down for "refractory damage" to the plasma arc equipment, according to Nolan Hirai at the Hawaii Department of Health.' Columbia University's Earth Institute also cited electrode issues that prompted the closure!

Despite the serious problems at the facility , including the refractory damage in the plasma arc equipment that caused the facility to close for eight months , Integrated Environmental '1'echeolcgies and InEnTec claimed on their website that this facility is a successful commercial operation when in fact it has not been a success.

Endnotes: 'Scott Ishikawa, " City Officials fooling into Alternative Waste Solutions " Honolulu Advertiser 2005

Allied Technology Group

Name of Facility : Allied Technology Group

Owner: Awed Technology Group

Location: Richland, Washington

Technology: Plasma Arc Gasification from Integrated Environmental Technologies (IET) for treatment of radioactive and hazardous wastes

Status: Plasma Arc equipment Closed (2001)

Allied Technology Group Limited (ATG) owned and operated a commercial waste treatment facility using plasma arc gasification, but the facility was closed in 2001 due to operational and financial problems.

ATG started treating low-level radioactive and hazardous wastes in the late 1980s, a decade before adding the Plasma Enhanced Melter (PEM) to its Richland facility. Designed by Integrated Environmental Technologies (IET), the plasma arc technology was supposed to "take low-level radioactive wastes laced with dangerous chemicals and turn them into a benign glass."' The technology was supposedly able to reduce any type of mixed waste to a vitrified state, including PCBs, while a final cleansing stage would supposedly break down emissions and reconstitute them into "harmless carbon dioxide and steam."2

In reality, tests from the technology provider parent company IET revealed that in fact the PEM technology does have emissions of toxic pollutants including dioxins.'

With anticipated contracts from both commercial customers as well as the Department of Energy (DOE), ATG began construction of the IET plasma gasification system within the Richland plant in 1999. The system, which ATG called GASVIT, had problems from the start. According to a Tri- City Herald news report, the "system routinely shuts down because of problems with the emissions equipment".' The plasma gasification system was not able to operate nonstop as expected.

ATG continued to delay state and federal agencies' observations of tests of the plasma arc technology, postponing a scheduled test run from November 2000 to early 2002.' Problems with the system resulted in a buildup of untreated waste while the processing system was not operating properly. "The bottleneck is the size of a medium house. The radioactive wastes clogged behind it could fill a small lake... The problem is the sophisticated equipment keeps shutting itself off. That means Allied Technology Group cannot conduct a demonstration for state and federal regulators, whose approval is needed before the so-called GASVIT system can operate at full speed. Its official test run is now 10 months behind schedule.'

Due in large part to problems with the plasma arc equipment, ATG filed for bankruptcy and laid off most of its workers. According to an ATG filing with the Security and Exchange Commission, "ATG's operations will not generate sufficient cash flow to allow the company to Incinerators In Disguise: Case Studies 17

meet its past due obligations under the hank ],,,,If it cannot immediately modify or refinance this debt, it may be required to seek bankruptcy relief or to otherwise reorganize or sell substantial ly all of its assets."7

ATG went on to fide bankruptcy on December 3, 2001 before ever obtaining the needed pernuts to operate at full capacity. "ATG terminated most of its 120 Richland workers last November and declared bankruptcy Dec. 3 because of massive debts and an expensive waste glassification facility that doesn't work... ATG sunk at least $40 million into building it, and the emissions purification equipment kept shutting down on its own." Whale the facility tried reopening in 2002, the plasma arc equipment did not start up again."

Despite the fact that the ATG facility rising IET's technology closed due to operational and financial problems, the website of IET's wholly -owned subsidiary InEnTec claimed this was a "successfully operating" commercial system." IET continues to heavily market its plasma arc gasification technology for medical and other waste streams.

Endootes: ' John Stang , " Radioactive Red Ink - Glitches Stall Progress at Allied Technology Group Metter, But Officials Still Optirraistic," I ' H Id 23 Sept. 2001. 'John Stang, "Radioactive Red Ink - Glitches Still Progress at Allied Technology Group Metter, But Officials Still OP'imutic," ?.-City He rald 23 Sept. 2001. William J. Qmpp and David Lamar, Integrated Environmental Technologies, LLC and Nick Soelberg, Idaho National Engineering and En vironmental Laboratory, ' Waste Gasification - Test Results From Plasma Destruction of Hazardous, Electronic, and Medical Wastes,' May 12, 2003; Environmental Technology Evaluation Center (EvTEC), CERF/ IIEC. "Environmental Technology Verification Report for the Plasma Enhanced Metter;' May 2002. 'John Stang, "ATG I'll Off 55 Workers, Delays Testing ofGlassifcation System" T i- i H nl 27 Sept. 2001. 'John Stang, "ATG Lays Off 55 Workers, Dela s Testin of Glassificstion - Hy g Iu System"2001. 27 Sept. John Stang, "Radioactive Red Ink Glitches Stall Progress at Allied Technology Group Melteq But Officials Still Optimistic;"7d-C'ry H Id 23 Sept 2001. ' John Stang, " Union says ATG owes severance pay," T'-C'ry H Id 21 Nov. 2001. a John Stang, "ATG getting back to business," Tri-City Herald 6 Ms X 2002. 1 InEnTec, " Commercial Systems ," http://w.inenmecom /comerciathml, viewed 16 March 2005. Incinerators In Disguise: Case Studies 18

Ebara

Name of facility: Ebara

Owner: Ownership of this facility is unclear. The technology provider is Ebara Corporation, a Japanese engineering company that has constructed at least six municipal solid waste gasification facilities in Japan as well as traditional municipal solid waste incinerators.

Facility location: Broga, Malaysia

Technology : Fluidized-bed gasification followed by combustion of gases and ash for municipal solid waste

Status: The Broga facility is still in the planning stage. An appeal of the project's Environmental Impact Assessment and strong local opposition have stalled the project.

In 2002, the Malaysian government proposed the construction of a municipal solid waste (MSW) gasification incinerator to treat an average of 5,000 tons per day. The plant was originally planned for construction in Kampung Bohol near the Malaysian capital of Kuala Lumpur. Because of wide- spread public protest, the project was cancelled and relocated to the city of Broga in the state of Selangor.'

In February 2003, Tokyo-based Ebara Corporation was awarded a contract through an internal bidding process to build a gasification facility in Broga, which would be the world' s largest municipal waste incinerator.2 Ebara Corporation is an environmental engineering company that claims to have a zero emissions concept with a commitment to sustainable development, clean air and clean water.'

Ebara proposes to install a fluidized-bed gasification furnace technology that the company claims has "zero emissions".' Despite this claim, Ebara's website admits that its gasification technology does release dioxins.' Indeed, an Environmental Impact Assessment (EIA) for the proposed Broga facility noted concern for public health and safety, and raised the possibility that dioxin emissions and accidents could cause cancer."

Ebara's track record of contaminating water with dioxins in Japan conflicts with its proclaimed corporate philosophy of "zero emissions." A traditional mass-burn incinerator run by Ebara Corporation in Fujisawa, Japan was dosed in 1999 after regional environmental regulators discovered that wastewater containing 8,100 times the regulatory limit of dioxin was being pumped into a stream leading to the Hikichi River.' Because of Ebara's negligence, contaminated wastewater from the Ebara incinerator was discharged into the Hikichi River for at least seven years and portions of the river contained at least 16 times more dioxins than Japan's national standard.' Shortly after discovery of the contamination was announced, Japan's Environment Agency stated "it has become clear that the inappropriate release of wastewater [from incinerators] may not only pollute public waterways, but also have a large impact on the health of surrounding residents."' Incinerators in Disguise: Case Studies 19

Details about the contract between Ebara and the Malaysian government have been withheld from the community. When questioned about the government contract, an Ebara spokesperson stated, We have agreed to abide by the secrecy requirement in the contract and are unable to describe these terms.""' Community members have expressed frustration with the lack of transparency regarding the project and 85% of the local community opposes the incinerator project." Local residents have formed groups such as the Broga No Incinerator Action Committee to appeal to the Malaysian government and the Japanese government to end the project.

The question of financing and what financial burden will be carried by Malaysian taxpayers and the local community is of special concern. Due to the failure of several gasification incinerators in Japan, the Ebara Corporation lost 27 billion yen (US$247 million) in 2002 alone.'" In the same year, Ebara spent 6.8 billion yen (US$62 million) to repair similar plants in Japan, an amount far exceeding projected expenses. "

Financial backing for the project has not been disclosed. In 2003, the Malaysian government claimed that the project would be financed through a soft loan from the Japanese government, however the Japanese government denied the claim. The capital costs of the facility are estimated to be RM 1.5 billion (US$395 million). Annual operations are expected to cost nearly RM 200 million (US$53 million), which could pass on substantial financial burdens to ratepayers."

Rising costs for the Broga proposal have similarities with a recent Ebara scandal in Japan. Kick backs from the construction of a gasification incinerator and other scandals led to fines for Ebara from the Tokyo Regional Taxation Bureau in April 2004 for failing to declare a total of 1.3 billion yen (US$9 million) in income. Of this amount, Ebara received 300 million yen (US$2.7 million) from a subcontractor during construction of a gasification facility in Nagareyama, Japan."

Ebara is already suspected of breaching other portions of its contract with the Malaysian government, including failure to transfer technology to local vendors and failure to maximize use of local materials for the project. '6

Other blemishes on Ebara's record include a bid rigging investigation by Japan's Fair Trade Commission, announced in August 2005. Ebara and other engineering firms have been accused of selecting bid winners at predetermined prices to win sewage and water treatment facility contracts from local governments."

Endnotes: ' Arfa'eza Aaiz, "Selangor DAP Sends Memo on Incinerator to Minister;" Malaysiakini.com, 23 June 2003. a Theophilus, Claudia, "Japan 's Ebara Corporation Wins Contract to Build Broga Incinerator;" Malaysiakini.com 27 March 2003. Incinerators In Disguise: Case Studies 20

a Ebara Corporation Zero Emissions , < hrrp: //waw.cbara .co.ip/en /pro0lc /zerocmission .html>. Viewed 3 Aug 2005. Claudia Theophilus,' Japan's Ebara Corporation Wins Contract to Build Broga Incinerator ," Mala,sialun ' cum 27 Mar. 2003. s Eha a Corporation Ebara Engineer rag Resdew No.201 Oct 2003 The Abstract of F_bnra Enjineering Rcvicw, < http://www.eb2m .co.ip/en /product/tcch/al)stract /201 _cn,html>. Viewed 23 Sept. 2005. "Claudia Theophilus, " Broga Incinerator: MA Report Reveals Fear of Dioxins , Cancer;" Ma l vs ak,n' c m 26 December 2003. a Claudia Theophilus, " Kanagawa Gov't Explains Ebara Incinerator Mishap;' hi l ys a kin' c m 28june 2003. a "Dioxin in Fujisawa river 16 tines official standard ,"Lpan Times 28 March 20(10. "Prefectures to examine incinerator waste water,"lapan Times 29 Mar. 2000. Claudia Theophilus , "Incinerator Contrctoe Our Lips Are Sesicd," Malavsiakini .com 7 May 2003. " Claudia Theophilus, "Broga Incinerator: EIA Report Reveals Fear of Dioxins , Cancer," Malavs; kini.com 26 Dec. 2003. ° Claudia Theophilus,Tbara' s Shady Past Being Questioned by Broga Opponents .' Malaysiak -d com SJune 5 2003. Claudia Theophilus, "Ebara', Shady Pass Being Questioned by Bro1a t Ipponents," Malavs kin' m SJune 2003, 'a Claudia Theophilus, " Reveal Incinerator Contract Details, Gov) Told," Malaysi:ddni.com 6 July 2004. 's "Ebara Fined Over Kickbacks," Yomiuri Shimbun 29 April 2004. Claudia Theophilus "GoVt'Upset' with Japanese Incinerator Contractor," Malaysiakini om S July 2004. " Mike Gimlet, "Japanese Firms in Bid Rigging Raid," Llovd's List 3 Aug. 2005. Refers to Item H.04 Mayor Council Regular Meeting - From: Boomhower, Pat [pat.boomhowergvancouver.ca] April 28, 2008 Sent: Friday, April 18, 2008 1:41 PM !.^ To: postmaster@.ca; mayor_council@coquitlam .ca; Mayor & CoLncil; djoyal@ Iangley.ca; feedback @ coquitlam .ca; [email protected]; Clerks; tarthur ®langleycity.ca; enquiries @mapleridge.ca; [email protected]; [email protected]; [email protected]; infoweb @ dnv.org; jrudolph@pitimeadows .bc.ca; [email protected]; [email protected]; [email protected]; [email protected]; rbeauchamp@westvancouver .ca; [email protected] Cc: Belanger, Lynn; Sanderson , Sherrill; Imai, Charlene Subject: City of Vancouver COUNCIL DECISION to. Greater Vanc. Regional Solid & Liquid Waste Management Plans Attachments: csb3_dec_Itr.pdf

Importance: High

Hello,

RE: Proposed Amendments to the Greater Vancouver Regional Solid ft Liquid Waste Management Plans

It would be greatly appreciated if you could forward the attached letter as soon as possible to Mayor and Councils and Board members of the Greater Vancouver Sewerage & Drainage District and appropriate staff. This letter relates to a recent City of Vancouver Council decision pertaining to solid & liquid management plans; a topic which I understand will be discussed at an upcoming GVS&DD members meeting in the very near future.

Thank you.

<>

Pat Boomhower Meeting Coordinator Office of the City Clerk City of Vancouver tel: (604) 873-7015 fax: (604) 873-7419 e-mail: pat. [email protected]

INFORMATION TO COUNCIL

DATE_44/...J._!- CITY OF VANCOUVER CITY CLERKS DEPARTMENT Public Access and Council Services

VanRIMS No.: 13-6000-10

April 18, 2008

Attention: Mayor and Council Greater Vancouver Sewerage & Drainage District Member Municipalities

RE: Proposed Amendments to the Greater Vancouver Regional Solid and Liquid Waste Management Plans

Following the Standing Committee of Council on City Services and Budgets meeting on April 17, 2008 , Vancouver City Council approved the following:

A. THAT Council advise the Greater Vancouver Sewerage & Drainage District (GVS&DD) Board and the Minister of the Environment that Vancouver does not support the GVS&DD's process for major amendments to the Solid and Liquid Waste Management Plans (WMPs), or their content , for the following reasons: • The proposed process does not comply with the Ministry of Environment's (MOE) requirements for major amendments to WMPs in their Environmental Management Act, Guide to the Preparation of Regional Solid Waste Management Plans by Regional Districts and Guidelines for Developing a Liquid Waste Management Plan. • The proposed process provides inadequate opportunity for technical review of waste management options, input by municipal stakeholders, and consideration by municipal Councils within an appropriate timeline. • The proposal does not include an evaluation of the financial implications of the waste management options in conjunction with other significant regional capital spending priorities such as drinking water , transportation, and housing.

• The proposal to prepare a Solid Waste Management Plan (SWMP) that provides only strategic direction, without specific timelines and commitments, may commit the region and its member municipalities to unrealistic and undeliverable programs.

• There has been no technical , scientific or engineering analyses conducted to support the proposal that waste-to-energy (WTE) is the sole appropriate strategy for handling all of the region ' s solid waste. • There has been no analysis of the sensitivity of the operating costs for WTE to the quantity of waste processed . The significant capital expenditures for WTE facilities also requires consideration.

City Nall 453 West 12th Avenue Vancouver BC V5Y 1V4 vancouver.ca City Clerk's Department teh 604.873.7276 fax: 604.873.7419 • There has been no analysis of costs or benefits to support the proposal to prematurely close the Vancouver Landfill by 2020 and exclude options such as continuing to use its remaining capacity while extending its life through waste reduction initiatives. There are significant differences in the operating cost for the Landfill and those estimated for WTE facilities.

B. THAT Council advise the GVS&DD Board to work with municipal staff through the Regional Engineers Advisory Committee, Regional Financial Advisory Committee and Regional Administrators Advisory Committee structure to develop appropriate processes for amending the Solid and Liquid WMPs.

C. THAT Council request that the Minister of the Environment require the GVS&DD Board to seek the MOE ' s approval of an appropriate process for amending the SWMP which meets the requirements of the MOE's Act and guidelines.

D. THAT Council forward these resolutions for information to the Councils of all other GVS&DD member municipalities.

E. THAT Council advise the GVS&DD Board that, in light of the Tripartite Agreement, which has a term ending in 2037 and acknowledges that Vancouver and Delta each require autonomy in the disposal of their solid wastes as a condition of the current SWMP, it is not appropriate for the GVS&DD to carry out public consultation on a draft plan to prematurely close the Vancouver Landfill (except as a residuals facility) in 2020 without any consultation with or input from Vancouver or Delta.

F. THAT the process for amending the Liquid Waste Management Plan include an exploration of sewage treatment technology options , while maintaining that improved sewage treatment must be expedited.

G. THAT the establishment of a citizen advisory committee on waste be referred to the City Manager for further information.

Yours truly,

Pat Boomhower Meeting Coordinator Phone: 604.873.7015 City Clerks Office email: [email protected]