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Expensive

The cost of construction of the incinerator is currently estimated at $527,185,000.00 (see PDF).

If that amount is paid off over 30 years with a 5% mortgage the monthly payment will be $2,830,000. The total of the construction plus the financing would be $1,018,800,000.00.

Operating expense: The plant operator will charge about $20,000,000.00 per year to run the incinerator. (“The annual indexed Escalation Component of the Base Operation Fee shall be Nineteen Million Eight Hundred Seventy-Eight Thousand Four Hundred Fifty-five Dollars ($19,878,455)” (see “Service Contract (1-26-09 compared to 7-2-09) Pgs. 155 onward: Article XV “Service Fee and other payments.”)

The operating expense would start at $19,878,455 per year and increase 3% per year according to this pattern:

Construction loan and interest = $1,018,800,000.00
Operating cost = $ 945,725,760.22
Total = $1,964,525,760.22

Also, please note that the referenced Article XV is titled “Service Fee and other payments.” There will be additional expenses that could mount up to millions of dollars during the next thirty years. Experience at other incinerators such as in Baltimore or in Montgomery County should lead us to expect expensive maintenance, repairs and mandated upgrades.

The County is anticipating operating revenue from the facility to be sufficient to cover operating expenses and debt service until the debt is paid off. However, there is no guarantee that sufficient operating revenue can be assured during that period to cover all expenses. Any shortfall in operating income will be required to come from County taxpayers.

Incineration is, indeed, a very, very expensive way to manage our waste... particularly when there are less expensive, less wasteful and more environmentally sound means to do so (see below).

Dumping Ground

The incinerator will require a minimum of 1,380 tons of waste daily, 365 days per year. Frederick County will be responsible for supplying 60% (828 tons) of that waste. The difference must be made up by importing waste from Carroll and other counties.

The final draft of the Memorandum of Understanding between Frederick and Carroll Counties with Northeast Authority dated 7/2/09 for the building of the incinerator states that “the Facility is expected to have a design capacity of 547,500 tons per year and will have a minimum processing capacity of 503,700 tons per year of waste, sewage sludge and other acceptable waste materials.”1

547,500 tons per year is equivalent to 1,500 tons per day. 503,700 tons per year is equivalent to 1,380 tons per day.

Frederick County is required to provide 60% (828 tons) of solid waste, 365 days per year. Frederick County currently produces an average of 800 tons per day.2 At our current rate of production, we do not produce enough waste to meet the minimum fuel requirement for the incinerator. If we meet our goal of 60% recycling there will only be 320 tons per day for the incinerator.

The contract specifies hauling in waste from Carroll County. At present they do not produce enough waste to meet their 40% required demand for the proposed incinerator.3 To meet the demands of the incinerator, other sources of waste will need to be found. Waste from other counties will need to be trucked into Frederick County to meet the incinerator’s demand.

Typically waste is hauled in transfer trucks or 20-ton dump trucks. Hauling waste from anywhere to the incinerator burns fuel and increases pollution for Frederick County as well as central Maryland. Hauling up to 1,500 tons of waste each day adds about 2504 truck trips into and out of the proposed facility on Buckeystown Pike. In addition, the trucks will contribute additional traffic burden throughout the day and night to this business and light industry area of the county.5

Competes with Recycling and Composting

The incinerator will compete with recycling and composting. This is a no-brainer: Two consumers — the incinerator and the recycling program — feed on the same waste stream. At lower levels of recycling they do not compete, but since up to 85-90% of the waste stream is recyclable (see below under “Recycle and Compost”) a higher level of recycling will take fuel from an incinerator (see PDF).

Pollutes

Check below to see if your school is within 3 miles of the incinerator's smokestack:

Ballenger Creek Elementary Ballenger Creek Middle Crestwood Middle The Earth and Space Science Center Frederick High Hillcrest Elementary Lincoln Elementary Maryland School for the Deaf

Monocacy Valley Montessori Public Charter Orchard Grove Elementary Parkway Elementary the proposed new St. John’s at Prospect Hall High School St. Thomas More Academy Tuscarora Elementary Tuscarora High West Frederick Middle

Frederick Memorial Hospital is within 3 miles, too.

1) Here's the Delaware law (see entire text) regarding no siting of incinerators within 3 miles of homes, schools and hospitals:

“Section 4. Further Amend § 6003(c), Title 7 of the Delaware Code, by adding thereto the following new subsection:

"(2) no permit may be granted to any incinerator unless:

“a. the property on which the incinerator is or would be located is within an area which is zoned for heavy industrial activity; and shall be subject to such process rules, regulations or ordinances as the county, municipality or other government entity shall require by law, such as a conditional use, so that conditions may be applied regarding the health, safety and welfare of the citizens within the jurisdiction; and

“b. every point on the property boundary line of the property on which the incinerator is or would be located is (i) at least 3 miles from every point on the property boundary line of any residence, (ii) at least 3 miles from every point on the property boundary line of any residential community, and (iii) at least 3 miles from every point on the property boundary line of any church, school, park, or hospital.”

2) Incineration ("waste-to-energy") turns a solid waste problem into an air pollution problem and water pollution problem with the fallout of mercury and other toxins, and creates a new waste disposal problem in the form of toxic ash that must be landfilled. Ash cannot be safely "recycled" into building materials, as the industry often asserts it can.

So-called "modern" incinerators release significant amounts of acid gases, harmful volatile organic compounds, and toxic dust. The American Public Health Association has expressed serious concern over the health effects of incinerator emissions and has strongly recommended intensive recycling instead. Read here for complete article.

3) The following excerpts are from a presentation by Dr. Paul Connett, Professor of Chemistry, St. Lawrence University Canton, NY 13617 at the 4th Annual International Management Conference Waste-To-Energy, Nov. 24 & 25, 1998 Amsterdam (see entire text.)

“1.3 Toxic metals are released. At the temperatures of combustion many of the toxic metals such as lead, cadmium, arsenic, mercury and chromium are liberated from otherwise fairly stable matrices like plastics. Furthermore, they are liberated in the form of tiny particles or gases, which, if they escape from the stack, vastly increase the potential surface area of contact between themselves and the environment. They also penetrate deep into human lungs, where they are rapidly exchanged with the bloodstream. The traditional method of removing metals from emissions is via particulate control devices such as electrostatic precipitators or baghouses (fabric filters). The former, while being very robust, are less efficient at removing the tiniest particles of concern. The latter are more efficient but suffer from breakage and blockage and need careful maintenance.

“1.3.1 Mercury, a highly problematic pollutant, is difficult to control. A particularly problematic metal has been mercury. At the temperature of combustion it is a gas and evades the simple particulate control discussed above. As a result trash incineration has been a major source of mercury going into the environment (2). Many modern incinerators now employ activated carbon to absorb the mercury. However, this is another expensive item, and the public needs a way of knowing that the activated carbon is being used continuously, because no trash incinerator, that I am aware of, monitors toxic metal emissions on a continuous basis. Mercury removal poses several further questions. What is the fate of the mercury captured on the activated carbon, or the fly ash residues? Is the spent charcoal sent for reactivation, if so where does the mercury go? Is the spent charcoal burned in the incinerator, in which case where does the mercury go, as it can't stay in the incinerator for ever? How does the presence of activated carbon effect the leaching and other characteristics of ash disposed of in landfills? In hot climates will the mercury evaporate from the ash?

“1.4 Dioxins, Furans and other by-products of combustion are formed. Shortly after the infamous accident in Seveso, Italy, (1976) which made the chemical 2,3,7,8-Tetra Chlorinated Dibenzo-para-Dioxin (2,3,7,8-TCDD or the singular "dioxin"), into a household word, Kees Olie and co-workers in the Netherlands identified this same substance in the emissions from trash incinerators (3). They, and subsequent workers, also found many other members of the dioxin family (there are 75 poly chlorinated dibenzo para dioxins, or PCDDs) and members of the furan family (there are 135 poly chlorinated dibenzo furans, or PCDFs) in these emissions. The major response to this discovery from consultants representing the incinerator industry was to claim that as long as the incinerator furnace was operated at a high temperature all the dioxins and furans would be destroyed(4), however these claims were subsequently found to be based on fraudulent manipulation of the data (5).

“1.4.1 Post combustion formation of dioxin. In 1985, the reason why high temperatures alone could not solve the dioxin problem was revealed at the International Symposium on Dioxin held in Bayreuth, Germany. Two groups showed that dioxins could be reformed after the flue gases left the combustion chamber (6,7). It is now well established that if the flue gases from an incinerator are passed through air pollution control devices operating at temperatures in the range 200-400 degrees Celsius, more than a hundred fold increase in dioxin and furan formation can take place (8). A strategy that would essentially minimize post combustion formation of dioxin would require the quenching of the flue gases immediately after they emerge from the combustion chamber. However, this strategy conflicts with the aim of generating electricity, because this requires the flue gases to go through boilers to generate steam to drive turbines, thus delaying the moment when flue gas quenching occurs.

“1.4.2 The fly ash dioxin problem. Without the immediate quenching system, the fly ash collected in the scrubbing devices will be contaminated with dioxins and furans. While some commentators have argued that modern incinerators are net destroyers of dioxins and furans (9) this argument does not hold if more appropriate dioxin levels in the incoming waste are assumed and if the dioxins in the fly ash and the bottom ash are included (10). A hundred times more dioxin may leave the facility on the fly ash, than from the air emissions. However, until recently, regulatory agencies, particularly the US EPA, have turned a blind eye to the dioxins and furans left on the fly ash, even though in some cases the combined ash (a combination of bottom ash and fly ash) is being used as daily cover in some US landfills. In stark contrast, in Japan, as a result of growing concern about the dioxin problem there, the government announced in 1997 that they were limiting the total dioxin emissions (i.e. air emissions plus fly ash plus bottom ash) to 5 micrograms of dioxin International Toxic Equivalents (I-TEQ) per metric ton of trash burned. According to presentations made at Dioxin '97 in Indianapolis, this will almost certainly require the fly ash from Japanese incinerators to be vitrified, which will still further escalate the costs of incineration (11,12).

“1.4.3 No continuous monitoring of dioxins possible. Even when the most stringent precautions are taken to minimize dioxin air emissions it is still very difficult to convince the public that the emissions are low because there is no equipment available in the world capable of monitoring dioxins and furans on a continuous basis. Instead, we have to rely on measurements made on a spot-check basis, with advance notice given to the operator that they are going to be monitored on a particular day. It is very rare for this to occur more than once a year. Indeed, until recently, very few incinerators in the US had been measured more than once in their whole operating lifetime (13). Thus, even with the best designed incinerators, the public is still hostage to how well they are operated, maintained and monitored over their lifetime of 20 years or more. The potential problems are well illustrated by the Indianapolis incinerator. This modern facility went on line in late 1988. Through tenacious sleuthing by a local environmental group, it emerged that this facility violated its permit limits over 6000 times, including by-passing its air pollution control devices 18 times, in the first two years of operation. In addition, the incinerator had 27 boiler tube failures within one year (14). No one knows what the dioxin emissions were like when these events took place. In short, in most countries neither the regulatory authorities nor the industry has been able to put the monitoring of dioxin from these facilities onto a truly scientific foundation. The matter threatens to get worse as these incinerators get built in Southern and former Eastern European countries, where current regulatory control abilities are already low and where they have no facilities to monitor dioxin even on a spot-check basis.

“1.4.4 Rising concern about current dioxin levels. Dioxin emissions have to be put against the backdrop of an increasing public concern about background dioxin levels in the environment, in our food and in our tissues (15). Of particular concern, is the fact that the highest doses of these potent endocrine disrupting chemicals are reaching us from our food and being delivered to the unborn fetus. While industry spokespersons frequently argue that dioxin emissions are extremely low (especially when compared to conventional pollutants), the counter argument is to note that dioxins interfere with several hormonal systems, in which the hormones function in human tissues at part per trillion levels. A critical finding occurred in 1992, when Dutch scientists discovered that even at background exposures dioxin was capable of interfering with the thyroid metabolism of babies at one week of age (16).

“1.4.5 Dioxin emissions easily captured in food chains. Any dioxin released from an incinerator, be it in large quantities from badly operated facilities, or smaller quantities from better run ones, is readily captured by grazing animals and fish. In 1986, Tom Webster and I calculated that one liter of milk would deliver as much dioxins as a human would get breathing the air next to the cow for eight months (17). More recent calculations indicate that in one day a grazing cow puts as much dioxin into its body (from dioxin which has deposited on the grass), as a human being would get if he or she breathed the air next to the cow for fourteen years (18). This is not just an academic affair. In 1989, 16 dairy farmers downwind of a huge incinerator in Rotterdam, were told not to sell their milk, because it contained three times higher dioxin levels than anywhere else in the Netherlands (19). This situation continued until 1995 by which time the incinerator had been retrofitted. Nor was this concern put to rest in 1995. In January of this year (1998) three incinerators were shut down in the Lisle area of France, because local milk produced downwind of these facilities had been contaminated with dioxin to levels three times higher than the permitted sale level (5 parts per trillion TEQ in the milk fat) (20).

“1.4.6 Ireland provides an indicator of how large the legacy of dioxin pollution from incinerators has been. A little publicized report from Ireland indicates just how extensive the contamination of the European milk supply from dioxin has been. Dr. Christopher Rappe analyzed 32 cows' milk samples from different parts of Ireland (21). The reported levels ranged from 0.12 to 0.51 ppt. (parts per trillion) of dioxin I-TEQs in the milk fat, with an average of 0.23 ppt. . These levels are much lower than the levels reported in Switzerland, Germany, Holland, France and the UK. In my view it is significant that Ireland has no trash incinerators.

“1.4.7 Advances in one country do not always translate to success in others. Again and again, optimistic reports about how well one particular country, or one particular incinerator, has done with limiting dioxin emissions, has been used to promote the building of incinerators in other countries, where the operators are neither as conscientious nor the regulators as competent. For example, long after Swedish consultants and scientists had told the world that Sweden had solved the dioxin emission problem (about 1986), incinerators were built and operated in the US which had extremely high dioxin emissions. For example a 2000 ton per day trash incinerator built in Norfolk, Virginia in 1988, was found in 1994, to be putting out more dioxin (approximately 2000 grams of toxic equivalents per year) than the combined emissions from all of the traffic, incinerators, industry and all other sources in Sweden, Germany and the Netherlands added together (22).

“1.5 The attention being paid to end-of-the-pipe dioxin control on incinerators will not solve the dioxin contamination of the environment. Whether one accepts the need for trash incineration or not, one has to applaud the efforts and success of those who have reduced dioxin emissions from these facilities. However, this effort cannot solve the dioxin problem generated by municipal waste. As long as chlorinated plastics like poly vinyl chloride (PVC) and poly vinylidine dichloride (PVDC) are present in the waste stream, dioxins and furans are going to be generated in every back yard burner, landfill fire, roadside burning and accidental fires in homes, businesses and industry. The reduction of dioxin emissions in northern incinerators, should not make us complacent about the potential dioxin contamination from the building of inferior quality incinerators in southern countries and the continued contamination from the casual and accidental burning of trash in both north and south. In my view, the dioxin problem can only be solved by phasing out the use of chlorinated plastics and the industrial use of chlorine.

“1.6 Modifications to counteract one pollutant can lead to increases in others. The incineration industry has had to develop on the fly. New scientific and environmental findings trigger new pollution control devices and expensive retrofits. Incinerators are built and financed with the expectation that they will operate at least 20 years. However, incinerators operating today look very different from those built 20 years ago. We can anticipate that those operating 20 years from now, will look very different from today's. The trouble with making changes on the fly, is that a solution to one pollutant problem, may make other pollutant problems worse. For example, the demand for higher furnace temperatures and better combustion to combat the dioxin problem, led to higher nitric oxide formation, the greater liberation of toxic metals, and reduced mercury control (less soot available for mercury absorption). Both the desire to capture energy via water boilers and the use of electrostatic precipitators for particulate control, increased the post combustion formation of dioxin. The use of lime and baghouse scrubbing combinations, has led to a more toxic fly ash product. The public has had to live through this ongoing experiment for many years, and continues to do so. For example, in 1993, the citizens of Columbus, Ohio, who were aroused by anecdotal reports of an increase in rare neurological symptoms and other illnesses, including cancer, in the vicinity of a 2000 ton per day incinerator, discovered that measurements made at the facility in 1992, but not reported to the public, indicated that nearly 1000 grams of dioxin TEQs were being emitted from the facility annually (23). This was more than the total dioxin generated in the whole of Germany at that time. The citizens received two further shocks. First, scientists from the US EPA reported at Dioxin '93, that the total quantity of dioxin emitted from all the US trash incinerators combined (about 130 at that time) was between 60 and 200 grams of dioxin TEQs (24), which was less than the single Columbus incinerator by itself. Second, the Ohio Health department reported that a 1000 grams of dioxin (about one half of a Seveso accident) falling annually on their heads and surrounding areas posed no health problems (25).

“1.6.1 In the UK, officials have had to admit that their trash incinerators operating in the '70s, '80s and even into the early '90s, could not meet new European dioxin standards without major retrofits, and that these "old" incinerators had been responsible for putting most of the dioxin into the UK environment, including cows' milk. We have already noted that both the range and the average dioxin level in cows' milk in the UK (i.e. background levels) is much higher than the truer "background" levels in Ireland. Instead of issuing a massive apology for permitting this pollution of the food supply, the UK is currently proposing to build more incinerators as part of their "alternative" energy program.”

An Unsustainable, Out-moded Technology

The proposal for a waste-to-energy (WTE) plant does not recognize that there is a new paradigm in place for solid waste management.

Since the industrial revolution first created enough consumer products that solid waste became a problem, the old paradigm was that of disposal. This paradigm reached its pinnacle in the generation following WWII with the “consumer society.” Disposable, one-time-use products were manufactured to maximize consumption, consumers consumed, and local governments disposed of the residue. Disposal has been dominated by landfilling and burning. However, as technology and prosperity advance, our waste stream has become too large, too complex, too toxic, and too valuable to bury or burn. A new element has been developing in the past generation: the environmental movement. Starting in the late 1960’s, the level of environmental awareness in the general population has steadily become broader and deeper. Concerns about environmental degradation combined with the related recognition of the limits of fossil fuel, permeate every aspect of our society. Like it or not, every citizen is touched by the concern for the environment and the overwhelming majority have come to embrace the concepts of environmental concern.

The effect of this growing awareness has been seen most strongly in the realm of municipal solid waste. As local governments have made recycling available during the past twenty years, it has spread to communities across the country. Recycling provides each individual an opportunity to express environmental concern. Hundreds of millions of tons of resources have been diverted from disposal by the voluntary and even enthusiastic actions of individual citizens. Rejection of perceived wastefulness has produced market pressure on industries to modify their products and packaging.1

Manufacturers increasingly use recycled materials to replace virgin resources for both economic and market reasons. Life-cycle analysis clearly shows that the energy investment in bringing virgin resources to a factory is generally ten times higher than that for recycled materials.2 It is a slow process of change. For example, the paper industry, which may have billions of dollars invested in forests, logging, and pulp mills cannot abandon that investment overnight.

Projections:

• Recycling will continue to expand. Education and incentives will help it expand more quickly, particularly with the inclusion of business, public offices, and schools.
• The waste stream will change. Industry is responding to consumer rejection of wasteful products and packaging.
• Composting will expand. Yard waste, food waste and some contaminated paper amount to nearly one third of our waste stream. Put the carbon in the soil, not in the air.
• More individual responsibility for waste. Both through increased environmental awareness and through economic incentives such as volume-based billing for waste removal.

Conclusions:

• There will be more recycling, less waste in the future.
• Local governments will need to work with the new paradigm by investing in recycling rather than working against it by investing in landfilling and incineration.

 

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