If you live in NSW this will affect you! We need as many residents as possible to make a submission objecting to the draft NSW Energy from Waste policy.
Why? Because it’s a numbers game and we need as many NSW residents as possible to make a submission – politicians will only take notice when they receive numerous objections – so please don’t just think that just a few groups making submissions is enough!
If the current policy is adopted waste incinerator operators could legally discharge more than 7 kg/hr of dust 24/7 over surrounding homes (see below)!
But you need to get your submissions in by 5pm, this Friday 7 May!
If you have any questions please email No More Incinerators at firstname.lastname@example.org.
It’s important to note that if this policy is adopted there will be no effective controls placed on any incinerator operating – so it’s really important that as many people as possible make a submission.
You do not need to be an “expert” to make a submission, just copy the text from the sample below and add your own words to describe how you think you’ll be affected. You can view the draft policy here: https://yoursay.epa.nsw.gov.au/energy-waste-policy-statement
It’s best if you email your submission directly to the NSW EPA at: email@example.com, directly to the office of Matt Kean, Minister for Energy and the Environment at: www.nsw.gov.au/your-government/ministers/minister-for-energy-and-environment/ and to your local member rather than using the EPA’s 3 set questions.
But if you want to fill in the survey on the EPA’s website it looks like this:
Q1) Are the proposed changes to the NSW Energy from Waste Policy Statement sufficiently clear?
Q2) Are the proposed changes to the NSW Energy from Waste Policy Statement capable of being implemented?
Q3) Do you have any other comments on the implementation of the proposed changes to the NSW Energy from Waste Policy Statement?
Answer: YES, SEE MY SUBMISSION EMAILED TO: firstname.lastname@example.org
Are you taking this survey as an individual or an organisation?
Answer: Individual (if you select “group” you’ll get a block to write the group’s name in)
Type a preferred contact email here
Tick the box if you would you like your feedback to be withheld from publication
It’s best if you allow your submission to be published so others can see that they’re not the only ones concerned!
Once you’ve completed the “survey” you’ll get an option to register for updates.
OBJECTION TO THE DRAFT NSW ENERGY FROM WASTE POLICY STATEMENT
If this draft policy statement is adopted waste incinerator operators will have few meaningful controls placed over their operations. Particularly in the following areas:
- Dust emission limits
The Best Available Technology (BAT) Reference Document for Waste Incineration (EUR 29971 EN; doi:10.2760/761437), published in 2019, limits the discharge of particulates to <2-5 mg/m3 (see BAT 25, Table 5.3). Yet the draft policy appears to set a 20 mg/m3 limit for particulates, which is twice the outdated EU IED (2010/75/EU) daily average emission limit of 10 mg/m3 for particulates.
In addition it does not set limits on the concentrations of sub 2.5 micron and sub 1 micron dust particles which can cause serious health impacts, from being discharged through the stack.
a) The draft policy should set a strict limit of less than 2-5 mg/m3 for the total concentration of any particulates discharged from the stack
An average or steady state discharge limit of 20 mg/m3 particulates will be a disaster for any resident living nearby as a typical incinerator will discharge:
0.020 grams x 100 m3/sec (assuming an average stack discharge rate of 100 m3/sec)
= 0.020 g x (100 x 3600)m3/hr
= 0.020 g x 360,000 m3/hr
= 7,200 g/hr or over 7 kg of dust discharged/hour, 24 hrs/day, 365 days/year!
This is only an “average” value but would still cause an unacceptable impact on surrounding residents and the environment.
Note that for larger incinerators with higher stack flow rates significantly higher quantities of particulates would be discharged causing an even greater impact on residents and the environment.
b) The draft policy sets no limits on the concentrations of particulates less than 2.5 microns and 1 micron in size
Strict limits need to be set for the maximum concentrations of these particles that can be discharged.
Numerous studies are now linking ultrafine and nanoparticles with illnesses caused by breathing in these particles which carry a wide range of toxic heavy metals, persistent organic pollutants and acid gases which when breathed in can enter the blood stream. While the concentrations of these pollutants are relatively low after filtration, exposure to them 24/7 will create a “chronic” exposure pathway affecting the long-term health of residents.
- No requirement to establish social licence
The draft policy does not mandate the requirement for a proponent to obtain a social licence from the community to carry out their proposal and this should be included as a statutory requirement.
Obtaining a social licence from the surrounding community is critical to ensure that the community:
- Has been consulted
- Has had meaningful input into the proposal, and
- Agrees with any significant change to their living environment.
- No requirements for the immobilisation and testing of toxic ash and other spent reagents prior to disposal
Waste incinerators generate large amounts of highly toxic ash and other materials such as spent activated carbon which, despite what the waste to energy industry says can’t be remediated and must be disposed of as hazardous waste. Currently any attempt at immobilising pollutants focuses only on heavy metal contamination and nothing is done to immobilise persistent organic pollutants such as dioxins and dioxin like compounds.
In addition, if undoped activated carbon is used to filter mercury from the discharge stream any mercury collected will not be retained and will leach out of the spent activated carbon. To effectively filter and adsorb mercury from the discharge stream activated carbon doped with sulphur is required so that mercury sulphide is formed and is retained.
Irrespective of which immobilisation technique is proposed before any ash or spent reagents are disposed of, each batch needs to be tested using the US EPA TCLP (Toxicity Characteristic Leaching Procedure) test to correctly classify the waste and/or prove effective immobilisation.
There are no requirements included in the draft policy specifying how the immobilisation of heavy or bottom and fly or baghouse ash or spent activated carbon or other reagents should be carried out.
Given the hazardous nature of the waste ash and other reagents this is essential to prevent toxic pollutants leaching into the environment prior to, and after disposal.
No requirements are included in the draft policy to ensure that each waste stream is treated separately and then tested and classified by TCLP testing prior to landfilling.
There are no requirements included in the draft policy specifying what testing is required to prove that toxic heavy metals and particularly any persistent organic pollutants have been effectively immobilised prior to disposal.
The US EPA’s TCLP (Toxicity Characteristic Leaching Procedure) leaching test for solid waste should be specified as the minimum test standard and TCLP testing should be carried out on every batch of ash and spent reagents before it leaves site by a NATA registered laboratory.
TCLP testing is essential to prove that the heavy metals and persistent organic pollutants present have been effectively immobilised prior to disposal.
- No requirements to continuously analyse and monitor for critical pollutants
Currently proponents are only required to measure a very limited number of pollutants being emitted in stack gases under steady state plant conditions. Testing on modern waste incinerators currently operating in Europe has shown that this performance measure is deeply flawed as the highest concentrations of pollutants are emitted during start up, shut down or stack bypass events.
Given that in Europe persistent organic pollutants are now being found in the environment, food chain and people from waste incinerators (refer Hidden Emissions-Zero Waste Europe-Arkenbout).
the draft policy also needs to specify that continuous emissions monitoring is carried out for a range of heavy metals and persistent organic pollutants using a certified AMESA (Adsorption MEthod for SAmpling) continuous sampler in addition to the other pollutants currently required to be continuously measured.
I look forward to the NSW EPA correcting these serious errors.