Impacts of Co-generation Plant Proposed by Orora Limited, Matraville

How is NSW to deal with the ever-increasing quantities of plastics and other materials separated from municipal waste streams that was previously exported to other countries – particularly given the scarcity and high cost of land fill?


  1. Opal (previously known as Orora) and SUEZ Group, (a waste management company) are proposing to build a high temperature waste incinerator as part of a cogeneration plant to provide steam for Opal’s Botany Paper Mill. Opal’s paper mill is located in Botany Road Matraville, near to the intersection of Bunnerong Road.
  2. The major driving factor for this project is undoubtedly the high price of the natural gas used to fire Opal’s boiler and while it may save Opal money in terms of energy costs, the emissions from the high temperature incineration of plastic waste will cause severe, long-term impacts to the environment and the health of residents living in the Greater Sydney area.
  3. Today Matraville is not an industrial suburb, but a highly urbanised area with residents living a mere 130m away from Opal’s proposed co-gen plant and as such this represents a serious long-term health risk to all residents and an unacceptable loss of amenity due to increased noise levels – just when a promised reduction in noise levels from the new mill had been realised.
  4. Importantly, waste incineration represents the greatest threat to the creation of a sustainable, circular economy in NSW and a move into the past where air pollution in the Sydney basin will inevitably become much worse, causing the adverse environmental and human health impacts that successive NSW governments have worked so hard, for so many years, to reverse.
  • The solution to this crisis lies in government leadership to foster a robust recovery and recycling industry able to provide thousands of permanent employment opportunities ranging from entry level through to senior management and a viable alternative to the use of HT incinerators and co-gen plants to burn Sydney’s waste.

Figures 1 and 2 show the location of Opal’s paper mill in Matraville and its close proximity to the surrounding residents.


Some of the main issues of concern are:

  1. The Sydney basin traps and concentrates pollutants

Figure 3 shows the typical morning and afternoon seasonal wind directions over the Sydney basin. With the Blue Mountains to the west the prevalent winds move any pollution back and forth across the Sydney basin, and when the right temperature conditions occur, this can create an inversion layer trapping any pollution and allowing it to accumulate over the Greater Sydney area.

The formation of inversion layers over Sydney has always been a problem and Photos 1, 2 and 3 show pollutants trapped under typical inversion layers that formed over the Sydney basin in the 60s and 70s, and even during a minor prescribed burn off in 2018.

  • Release of Persistent Organic Pollutants (POPs) into the environment

The main source of fuel for Opal’s incinerator will be process engineered fuel or PEF, supplied by the SUEZ Group. Approximately 80 per cent of the fuel for the incinerator will be PEF produced by SUEZ and the remainder waste from Opal’s plant. Overall, the fuel stream will contain a range of plastics and other oil-based materials which, when burnt, can produce dioxins which are some of the most lethal Persistent Organic Pollutants (POPs) known.

Dioxins or polychlorinated dibenzodioxins, (PCDDs) are considered to be so toxic that in 2012 the USEPA announced that the safe limit for human consumption is 0.7 picograms Toxic Equivalence (TEQ) per kilogram of bodyweight per day. This is a tiny quantity – one picogram is 10-12 grams.

Dioxins are only one of a range of highly toxic compounds that can be emitted by high temperature incineration. Many of these compounds can bioaccumulate in the marine and land environment, i.e. they become more concentrated as they are passed from one species to the next through the food chain. They contaminate the air we breathe and the food we eat, and damage reproductive, neurological and immune systems, interfere with hormones and cause cancer.

  • Scrubbing stack emissions doesn’t work

Experience has shown that even with the most sophisticated scrubber and pollution control equipment installed, it is notoriously difficult to maintain the optimum furnace conditions to minimise the production of highly toxic pollutants such as dioxins. This is because the conditions required to form dioxins (and other pollutants) are not fully understood. Dioxins may be formed at either low or high temperature and formation reactions do not go to completion (1).

In addition, uncontrolled emissions of dioxins and other persistent organic pollutants can occur during bypass events such as start-up, shut-down and maintenance events. These transient events are not usually measured or reported to regulators yet represent a significant pollution impact for the surrounding community through contamination of the environment and food chain, e.g. eggs (2).

  • The ash and other by-products produced by HT incineration are highly toxic

The scrubber liquid, ash and dust produced by high temperature incineration are also highly hazardous to workers and the environment and require special treatment and must be disposed of as hazardous waste. These wastes would need to be disposed of in double encapsulated clay lined cells and monitored forever as they have the potential to cause serious environmental pollution if leaching occurs.

Numerous studies have been carried out on dioxins and other POPs entering the environment. For example, dioxins in incinerator ash used to make paving in residential areas in the UK have been found in free range poultry (3) and in mothers and their breast-fed infants living near a 10-year-old municipal waste incinerator (MWI) in China (4).

  • Ever increasing greenhouse gas emissions

High temperature incineration produces large amounts of carbon dioxide and nitrous oxides which create large quantities of greenhouse gases that significantly contribute to global warming. History shows that HT waste incinerator/co-gen plant operators seek ever increasing quantities of waste to convert to fuel to minimise natural gas costs causing greenhouse gas emissions to steadily increase.

Currently Orora’s boiler is gas fired and typically one kWh of natural gas used generates 0.21kg of CO2. By comparison, if mixed waste plastics are used instead of natural gas as fuel, one tonne of mixed waste plastics would generate 1.7 tonnes of CO2 – a huge increase in CO2 emissions of 272,000 tonnes per annum (5).

In addition, approximately 4,800 round trip B double truck movements (more if single skels are used) per annum would be required to transport the process engineered fuel or PEF from SUEZ’s plant in Chullora to Orora’s mill in Matraville, a 50km round trip. A typical large diesel truck would generate 0.26kg of CO2 emissions per km travelled and this would result in more than 60 tonnes of CO2 being added to greenhouse gas emissions per annum (5).

  • The collapse of the recycling industry

Experience in Europe has shown that high temperature incineration has undermined the recycling industry causing it to collapse. This is because facility operators insist on contracts that force local councils and other municipal authorities to supply minimum quantities of waste or face contractual penalties. In effect the use of high temperature incineration discourages the collection and reuse of recyclable materials resulting the recycling industry becoming unsustainable.

Municipal and state governments are also vulnerable to waste incineration contracts which are lengthy (30 years) and lock in fuel feedstocks. This has the effect of diverting waste resources away from higher order waste management outcomes like reuse and recycling. The financial risk for municipalities are significant as they are required to meet their contracts whether they have the waste supply volumes or not.

The ongoing environmental and health issues associated with HT incineration has led to waste management through recovery and recycling being preferred as a more ecologically sustainable and cost-effective waste management solution and the European Commission has:

  • Legislated to discourage and decommission waste incineration in the EU (6)
  • Removed all renewable energy and industry subsidies that the industry relies upon to be viable (7) and announced that the EU taxonomy will not include waste incineration (8) in recognition of the significant environmental impacts HT incineration causes and threat it poses to the creation of a robust circular economy (9).


Clearly, the high cost of Australian produced natural gas needs to be reduced to ensure the long-term viability of industry in Australia, but what of the huge and ongoing environmental legacy that will occur if Opal’s (and other high temperature incinerator/co-gen facilities) are built?

How is NSW (and the other States) to deal with the ever-increasing quantities of plastics and other materials separated from municipal waste streams that was previously exported to other countries – particularly given the scarcity and high cost of land fill?

The solution lies in a Zero Waste City model (10) that includes the expansion of the existing waste resource recovery and recycling industry to recover and recycle a range of waste resources and support the Australian government’s pursuit of a sustainable circular economy.

Recycling of food contact grade PET and PE largely abandoned, should be encouraged and relaunched as both PET and PE drink and milk containers have been designed for easy recycling.

Various government incentives could also be provided to foster a viable, robust waste recycling industry able to provide thousands of new, permanent job opportunities ranging from entry level through to senior management.

By doing this NSW (and Australia) will benefit from:

  • Reducing the quantity of waste requiring landfill
    • Significantly reducing greenhouse gas emissions
    • Protect the long-term health of Sydney residents
    • Maintain and enhance the existing waste recovery and recycling industry and
    • Provide viable, permanent job opportunities for all Australians.

Written By Chris Hanson. The author gratefully acknowledges the assistance of National Toxics Network in obtaining the papers cited in this briefing note. National Toxics Network (NTN) is a NGO (non-government organisation) network working for pollution reduction, protection of environmental health and environmental justice. NTN is the Australian focal point for the International POPs Elimination Network (IPEN) and strives to achieve the full implementation of the Stockholm Convention on Persistent Organic Pollutants (POPs) 2001 and other relevant international and regional chemical and waste treaties.

1 Environment Australia (1999), Incineration and Dioxins: Review of Formation Processes, consultancy report prepared by Environmental and Safety Services for Environment Australia, Commonwealth Department of the Environment and Heritage, Canberra.

2 Arkenbout, Abel, Petrlik, Jindrich, 2019/08/26, Hidden emissions of UPOPs: Case study of a waste incinerator in the Netherlands

3 Petrlik J, et al. (2018); High levels of PCDD/Fs around sites with waste containing POPs demonstrates the need to review current standards, Abstracts Book of the Dioxin 2018: 38th International Symposium on Halogenated Persistent Organic Pollutants & 10th International PCB Workshop, 26-31 August 2018, Krakow, Poland

4 Peiwei Xu, et al. (2019) High intake of persistent organic pollutants generated by a municipal waste incinerator by breastfed infants, Environmental Pollution 250 (2019), 662–668

5 Veolia Winnipeg STP Process Selection Report, Appendix 7 – CO2 Emissions Factors Database

6 European Commission, 26the January 2017, The role of waste-to-energy in the circular economy, Brussels.

7 The REGI committee report excludes from the scope of the Cohesion Fund “investment in facilities for the treatment of residual waste with the exception of outermost regions and in case of state-of-the-art recycling solutions in line with the principles of the circular economy and the waste hierarchy fully respecting the targets laid down in Art 11(2) of Directive (EU) 2008/98 and provided that Member States have established their waste management plans according to Art. 29 of Directive (EU) 2018/851”

8 EU technical expert group on sustainable finance, EU Taxonomy, March 2020

9 Zero Waste Europe, September 2019, The impact of waste to energy incineration on climate policy.

10 Zaman, Atiq, Lehmann, Steffen, 2011/08/15, Challenges and Opportunities in Transforming a City into a ‘Zero Waste City’.

Figure 1 : Opal Paper Mill Location
Figure 2 : Location of Opal Paper Mill
Figure 3 : Greater Sydney area showing typical summer and winter morning and afternoon wind directions
Photo 1: 1960’s
Photo 2: 1970s
Photo 3: 2018

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: