The front page story of today’s Vancouver Sun takes on Metro Vancouver’s waste incineration facility in Burnaby. The Fraser Valley Regional District has been strongly opposed to a new proposed incinerator planned by Metro, and likewise has expressed its concerns about air quality in regards to the Burnaby facility. Its operating permit is up for renewal, but with a narrow window for public comments. CCPA was not able to comment within this time frame, but I was emailed the submission of the Burke Mountain Naturalist society, which did make a submission and does a nice job of summarizing the process and pollution challenges. What follows is from Elaine Golds, their Conservation/Education Chair.
December 20, 2013
Government of British Columbia
#200-10470 152 Street
Surrey, BC V3R 0Y3
Transmitted via email: [email protected]
To Whom It May Concern:
Re: Operational Certificate (OC) 107051- Metro Vancouver Waste-to-Energy Facility (WTEF)
The Burke Mountain Naturalists are a group of approximately 200 members who reside mainly in the Coquitlam and surrounding areas of Metro Vancouver. Over the past two decades or more, we have taken a keen interest in all aspects of protecting the environment. We are pleased with several commitments that Metro Vancouver has made to adopt more sustainable policies especially as regards improving air quality and seeking to reduce waste.
1. Public Consultation Process:
One of our concerns is with regard to the timing for this permit. Given that comments are not due until December 21 but the Certificate must be issued by December 31, we are concerned there will not be sufficient time to consider comments from the public.
The operation of this WTEF is not only complex but it has also been a controversial component of Metro Vancouver’s Waste Management Plan. In this regard, we feel that Metro Vancouver has not provided an adequate process for comprehensive review and consultation with the public regarding the OC. For example, we think Metro Vancouver should have solicited public comments regarding the OC by holding an open meeting where people could ask questions and receive answers as well as submit comments. A public opportunity specifically to discuss the operation of the WTEF would have been invaluable. In addition, Metro Vancouver should have clearly advertised on their website that a public comment period for the OC for the WTEF was underway. The only advertisement of which I was aware was published in the print media where it appeared to have been posted by the provincial agency. The fact that this OC was pending should have also been included as an information item in the agenda of the most recent Metro Vancouver Zero Waste Committee meeting. If the public is to have confidence in the operation of this WTEF, then a full commitment to transparency, willingness to provide information and respond to public comments is essential.
2. Inadequate Site Description:
A site map has not been provided for the WTEF site at 5150 Riverbend Drive in Burnaby. Given that local emissions are a concern, it is important to provide such information as well as data regarding prevailing winds and details on surrounding land uses. Within a 1 km distance of the site, land use has changed dramatically since the time the incinerator was first permitted in 1988. In our view, a thorough site description should be supplied as part of the permitting process especially given that nearby areas include residential areas, agricultural land and public parks.
While Metro Vancouver’s website states that no waste water is discharged from the WTEF, no information is provided about on-site stormwater management. Because the immediate area around the WTEF can experience periods of noticeable airborne particulates when, e.g., trucks are loading ash, it is reasonable to assume that such particulates will deposit on surfaces and eventually be washed into drainage ditches. We assume, in order to protect fish habitat, such drainage ditches are directed towards a sedimentation pond where particulate matter can accumulate and be retained (and then recovered) prior to discharge of stormwater to the nearby Fraser River. We request testing be undertaken of the stormwater and pond sediment retained in this manner and that such information be posted to Metro Vancouver’s website. Given that some recent tests for cadmium (Cd), a toxic chemical associated with kidney disease and which is known to bioaccumulate in aquatic organisms, especially shellfish, indicated unacceptably high levels in the bottom ash, we recommend these tests be conducted in a timely manner as further action may be required.
3. A Need for Soil Tests:
A long-standing and contentious issue with the public is the absence of any soil tests in the vicinity of the WTEF site since 1990. The history of these tests for toxic chemicals (i.e., heavy metals, trace elements and polycyclic aromatic hydrocarbons (PAHs)), is that they were conducted for 4 years (1987-1990) when the incinerator was first built. The PAHs are a group of organic chemicals which include a number of known carcinogens and mutagens. Unfortunately, these studies were discontinued because, in 1992, a GVRD Technical Review Committee (names of participants never provided) inaccurately concluded that “To date, there is no evidence to indicate that incinerator emissions have had any measurable adverse impact on soil and vegetation trace elements or PAH levels at the representative monitoring sites used in this sampling program”.
Oddly, the original, independent reports on which this erroneous conclusion was supposedly based did, in fact, indicate problems. For example, the 1990 study produced by Soilcon Laboratories states, “For several of the sites, the soil total element (i.e., metal) and PAH concentrations noticeably exceeded the BC Ministry of Environment (MoE) criteria for Managing Contaminated Sites – ‘A’ Levels.” This report went on to state, “Of particulate note were the Cd concentrations in surface soils layers at site 5. These concentrations approach the MoE ‘B’ level. (The ‘B’ level is the remediation concentration for agricultural, residential and recreation uses.)” In addition, “the 1990 site 6 surface soil total PAH concentrations noticeably exceeded the MoE ‘A’ level while those at site 7 exceeded the ‘B’ level.” The report went on to document a number of other concerns including high concentrations of trace metals in some vegetables which were presumably destined for human consumption.
Finally, this 1990 report made five specific recommendations:
“1) The GVRD undertake a detailed evaluation of the ambient (i.e., air, dustfall, soil and vegetation) and stack monitoring program results within the context of other influencing factors (i.e., meteorology, other local contributing sources of pollution).
2) A routine soil and vegetation monitoring schedule be established. (It is important that a sound data base is established during the initial years of the incinerator operation.)
3) The appropriate health officials be updated regarding the 1990 agricultural vegetation Cd (i.e., 5spinach), Ni (2grass), Hg (i.e., 5spinach and F (i.e., 4blueberry) levels. Several of these elements have been elevated since the pre-operational monitoring program.
4) An evaluation be conducted on the merits of PAH “fingerprinting” as a tool to investigate sources(s) of soil PAHs.
5) A region-wide soils and vegetation monitoring program be established to investigate whether the elevated trace element levels found in the sampling program are an isolated situation or whether they are typical of others area in Greater Vancouver.”
To the dismay of the public, these recommendations were buried (by the publication of the 1992 report) and ignored by the GVRD. The lack of any followup up soil testing has been a matter of public distress and distrust for many years. The need for soil tests has also been discussed by Metro Vancouver’s Solid Waste Committee in the past. In the meantime, technology has improved tremendously which should make such tests less expensive to conduct than they were 25 years ago. In addition, there is now a better understanding of how these contaminants move through food webs. In this regard, in addition to soil tests, it may be far more sensitive to test organisms such as the small mammals which eat earthworms and other soil invertebrates directly exposed to soil contaminants. Earthworms, for example, are reported to be very sensitive to small concentrations of cadmium in the soil and can be an important link in pollutant transfer to terrestrial food webs. Regardless, in our view, there is an urgent need to design a program to conduct such tests. It is now known, for example, that metals and organic pollutants can be carried by very small particulates – particulates sufficiently small that they would not be trapped in a conventional baghouse. After a quarter century of WTEF operation with all the ongoing concerns raised by members of the public, a full investigation of this issue is long overdue. Needless to say, such testing must be carried out by fully independent investigators with a complete release of all data to the public.
4. Require more information to be posted to Metro Vancouver’s website:
We recommend the OC require Metro Vancouver to post information to their website with regard to the up-to-date composition of bottom and fly ash as well as its reuse. Some of this information is posted but it appears to be out of date and makes no mention of the recent findings of unacceptably high levels of Cd (cadmium) in this ash. Is such ash still being used in road construction as stated on the website? (We hope not.) Metro Vancouver should be required to provide current information on their website as well as results of all tests conducted. Is there, for example, a requirement to test for dioxins in the ash? Will the Bottom Ash Management Plan, anticipated to be in place by June 30, 2014, also be made available for public comment?
In addition to this information, we recommend the OC require the posting of the following:
a) The amount of natural gas burned at the WTEF per year which is needed to provide optimal temperatures for incineration to minimize the generation of toxic and carcinogenic chemicals.
b) CEMS (i.e., continuous emission monitoring) data of the temperatures reached during incineration including shut-down and start-up periods. We are concerned that, at present, managers are allowed to exclude data during such periods.
c) Information as to when and for how long the incineration units are shut down or not functioning.
d) Regular testing of all three units for both dioxins/furans and PAHs, etc. (not just one unit once per year). Such tests should be conducted by an independent third party without advance notice to avoid fuel loads being pre-selected to eliminate material that contributes to the generation of carcinogens and other toxic material. We were dismayed to learn that only 10 tests on single units (normally 3 are always in operation) have been conducted since 1988. This hardly seems sufficient. We note the technology for continuous sampling to conduct dioxin/furan analyses now exists; we recommend consideration be given to requiring continuous sampling for this WTEF. Testing for these toxic chemicals is important because they can be created during the combustion process if the appropriate pre-cursors are present and temperature is not properly controlled.
e) Full posting of all data on emission testing. Currently, no data is shown on the website for 2012 and no data is shown at all for PAHs and that group of carcinogenic compounds.
f) A value for the annual number of cubic meters of gaseous emissions generated by incineration. If, for example, it is around a billion cubic meters per year, this means that an emission level of only a 1 mg/cubic meter would amount to the release of a tonne of a given pollutant over a year. It would be helpful for the general public to understand the relationship between what seems to be a small permitted level and the amount emitted over the course of a year. It is important that Metro Vancouver be encouraged to be as transparent and helpful as possible to residents who view their website.
g) We recommend the Annual Monitoring Report submitted by Metro Vancouver to the Regional Manager, Waste Protection also be posted to Metro Vancouver’s website.
Finally, more information should also be provided regarding the characteristics of the particulate matter with regard to sizes of particle captured/not captured and their composition. Is Metro Vancouver using the latest technology to capture the smallest particles possible? What sizes of particles are escaping? Are these small particles tested to determine if they are carrying toxic or carcinogenic material? Insufficient information regarding this is posted to the website; we recommend this information be added and appropriate tests, if needed, be conducted.
5. Ensure Metro Vancouver adopts best available technology and meets the highest standards.
We request that Metro Vancouver undertake a survey of regulations regarding air emissions from incineration around the world and ensure that we are meeting or beating the best available standards and using the most up to date technology.
6. Improve emissions from incineration by banning some streams of waste (i.e., ensure full compliance with the tipping fee bylaw and Goal 2 of the Solid Waste Management Plan):
Air quality emissions should be further improved by additional screening of the material being incinerated. For example, a simple prohibition on certain items could alleviate some public concerns as well as improve air quality emissions. Items to consider for banning include metal, glass, inorganic and E-waste. We were very surprised to see that such material is anticipated to comprise at least 15% of the waste incinerated in the future even though it has very little thermal value (less than 5% of that of plastics) and has a much higher likelihood of generating pollutants. Simply put, these components of the waste stream are not suited for incineration. This is especially true of some metals which act as catalysts and contribute to the generation of carcinogenic hydrocarbons during the incineration process. We strongly recommend a requirement be added to the OC to require the removal of metals, glass, inorganic and E-waste prior to incineration.
While plastics might appear to be better suited for incineration by those who support incineration because they have the highest thermal value (double that of wood and paper), it is not clear why most of the plastics in solid waste are not diverted to recycling with the exception of polyvinyl chloride (PVC) which cannot be recycled. Thus we were surprised to see that, by 2020, when it is anticipated 80% of the waste stream will be diverted to recycling, plastics will still a very large component (16%) of the waste stream destined for incineration. Once again, the OC for the WTEF must ensure that material which should be recycled does not end up in the incineration stream. Thus, we recommend that the OC also prohibit the incineration of all recyclable plastics according to Bylaw 275, the “tipping fee bylaw”, and Goal 2 of the Solid Waste Management Plan. The OC should stipulate there must be full compliance with this bylaw and require monitoring to be conducted by an independent third party to ensure that it is.
Incineration of PVC is also problematic because this plastic has a very high content of organic chlorine and thus, can generate carcinogenic chemicals when incinerated. It is important to point out that, although PVC appears to consist of only a small fraction of the waste stream (0.04%), this still amounts to the incineration of 433 tonnes per year. Once again, we recommend the OC prohibit the incineration of PVC plastic. Because this type of plastic waste seems suitable only for landfill, we recommend programs be undertaken to minimize its use and facilitate its reuse wherever possible.
7. Adding up the numbers:
We are very pleased that Metro Vancouver intends to recycle 80% of the waste stream by 2020. Assuming we will generate 1.5 million tonnes of waste in 2020 (we need to be also reducing the amount of waste generated /capita), this means as little as 300,000 tonnes could be left for incineration or landfill in the future. Given that the capacity of the existing WTEF is 285,000 tonnes per year, it is difficult to understand why Metro Vancouver is proposing to construct another WTEF to handle up to 380,000 tonnes of waste per year. Given these numbers, it’s not surprising that some people have speculated Metro Vancouver intends to shut down the existing WTEF. Thus, we ask for clarity. Is there an intention to shut down the existing WTEF in a few years? Or, is the intention to recycle far less of our waste stream than we should or could be? These numbers suggest that Goal 2 of Solid Waste Management Plan will not be met. Given the present high proportion of material anticipated to be in the waste stream in 2015 ( 18% paper and paperboard, 24% yard and food waste, 9% wood, 18% plastics) that should be recycled, a system to recover these materials and ensure they are recycled needs to be implemented without delay. It is very important to ensure compliance with Goal 2 of Metro Vancouver’s Solid Waste Management Plan. Again, we recommend that independent third party monitoring of the feedstock for incineration be undertaken.
8. OC permit renewal interval:
It is not clear, once a permit is issued, what length of time will pass before permit renewal is required. Given the existing outstanding concerns, we recommend the OC be reviewed on an annual basis, at least initially.
9. Require Metro Vancouver to post OC on website
Finally, in the interests of transparency, we ask that Metro Vancouver be required to post the OC, once approved, on their website and that, as a matter of courtesy, all members of the public who submitted comments be notified when the OC is issued.
We appreciate this opportunity to comment.
Elaine Golds, Ph.D.