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HomeMy WebLinkAbout1999-03-04-SWAT-rpt.pdf Ji Revision 1.0 Lexington's Solid Waste Future Report of the Lexington Solid Waste Action Team to the Lexington Board of Selectmen March 1999 March 4, 1999 To: Lexington Board of Selectmen From. Lexington Solid Waste Action Team This report provides a summary of the work, conclusions, and recommendations resulting from the efforts of the Lexington Solid Waste Action Team over the past year. Listed below are the Team members who approved transmission of this report to the Board of Selectmen. (Signed by the following members of the Lexington Solid Waste Action Team) John Andrews Katherine Fisher Rep. Jay Kaufman Laura Dickerson Kate Fricker Al Levine Eileen Entin Rosemary Green Fran Ludwig John Federochko Myla Kabat-Zinn Jill Stein, Chair Acknowledgements The Solid Waste Action Team would like to acknowledge the contributions of all members of the SWAT as well as other interested citizens, who attended meetings and contributed to the work of the group during the past year. We would also like to acknowledge the assistance provided by our ex officio member, George Woodbury director of the Lexington Department of Public Works. The SWAT also appreciates the sustained interest of the Board of Selectmen in finding improved ways to manage the Town's solid waste. The bulk of the actual writing of the report was undertaken by John Andrews with assistance from Jill Stein. This report is available on the internes at http://www.lexingtonma.org/.swatlHomePage.htm CONTENTS Acknowledgements Trash by the Numbers (table) Executive Summary 1. Introduction 1.1 A New Perspective 1.2 Assessment Principles 2. Waste Treatment Alternatives 2.1 Waste Prevention 2.2 Recycling 2.3 Landfilling 2.4 Incineration 2.4 1 Current Arrangement for Trash Incineration 2.4.2 Risks of Cost Increases for Incineration 3. Public Health Considerations 3.1 Increasing toxicity of the waste stream 3.2 New Discoveries Link Waste Practices to Health. 3.3 Health Impacts of Incineration 3.3.1 Mercury 3.3.2 Dioxin 3.3.3 Lead 3.3.4 Particulate Emissions 3.4 Health Impacts of Landfills 3.5 Health Impact of Waste Prevention 3.6 Health Impacts of Recycling 3 7 Dollar Costs of Health Impacts 3.8 The Limits of Regulatory Protection 4. Desirability Ranking of Waste Management Options 5 Citizen Involvement and Public Education 6. Policy Recommendations 7 Plans for the Coming Year References Trash by the Numbers Figures for Lexington's Solid Waste Program Number of households 11,000 Number of residents 32,000 Tons of Solid Waste (annual) 11,100 tons Tons from Residents (less schools and municipal 10,000 tons facilities) Average pounds per resident/year 625 lbs. Average pounds per household per year 1818 lbs. Recycling rate in Lexington (1998) 54% (including yard waste) 30% (excluding yard waste) Guaranteed Annual Tonnage (GAT) that Lexington 11,396 tons must buy from NESWC Tipping fee at NESWC incinerator (FY99) I $105/ton Regional tipping fee (non-NESWC) I $50-$55/ton Collection costs for mixed trash (FY99) I $670,000 Collection costs for recycling I $353,800 Annual trash tipping fees I $1,186,059 Percentage of air emissions of dioxin in U.S. due to 32% municipal waste incineration [EPA94a] Amount of human exposure to dioxin that occurs 90% through diet [EPA94] Half-life for elimination of dioxin from the human 7-11 years body [EPA94] Dioxin exposure for 1 cancer per million people 0.006 picograms/Kg/day exposed [EPA94] Percentage of trash remaining as ash after 25% incineration (by weight) ii Executive Summary The Lexington Solid Waste Action Team (SWAT)was appointed in 1998 by the Lexington Board of Selectmen to provide citizen support for Lexington's recycling efforts and to study options for improving the Town's solid waste program. This report summarizes the knowledge gathered, analyses conducted, and conclusions reached by the SWAT during the past year. The SWAT identified four fundamental methods of waste treatment: waste prevention, recycling, landfilling, and incineration. Waste prevention refers to any effort to reduce the amount of trash that is generated, thus avoiding the need for collection and disposal. Recycling refers to the reuse of waste materials, thereby treating the waste stream as an economic opportunity rather than as a burden. Landfilling buries trash in a suitable facility Incineration, currently the primary means used by Lexington for solid waste disposal,bums the solid waste, and then disposes of the ash that remains in a landfill. Due to increasing disposal costs and tightening town budgets, finding less expensive ways to manage solid waste is fast becoming a necessity for Lexington. Currently Lexington is one of 23 communities of the North East Solid Waste Committee (NESWC) who are under contract to bring a guaranteed annual tonnage to the NESWC incinerator in North Andover. The "tipping fee" charged for this tonnage is currently about$105/ton which is about twice typical market rate fee in eastern Massachusetts This will increase to approximately $200/ton in 2005. The NESWC contract will end in 2005 (barring early closure of the incinerator). The SWAT feels that Lexington must begin planning now for transition to post-NESWC programs that will realize substantial savings through waste prevention, recycling, and competitive contracting. Recent discoveries regarding the health implications of incineration and landfilling have introduced a new complexity into the evaluation of solid waste programs. Waste management in the past was based on the assumption that pollutants contained in the waste stream or generated by treatment could be rendered harmless by dispersion or by degradation in the environment. Recent studies, however, reveal that toxic chemicals in the waste stream persist in the environment and bioconcentrate in the food chain. Particular concerns surround incineration because this method of treating waste increases the mobility and bioavailability of pollutants, resulting in a significant increase in the likelihood that pollutants will impact human health. Among the pollutants of chief concern are mercury dioxin, lead, and particulates. These substances are now known to cause health damage at levels comparable to or lower than the exposures that currently prevail. For example, • Mercury exposure is a proven danger to the cognitive development of the human fetus. Current levels of environmental mercury create risks for learning, memory and attention impairments in children. Incineration is responsible for over half of the mercury released in Massachusetts. • Dioxin is a known human carcinogen, and also has adverse reproductive, developmental and immunologic impacts. Current levels of dioxin exposure are 2 to 60 times greater than is considered safe. Waste incineration is the single largest source of dioxin. • Lead has well-known neurological impacts. Waste incineration is a significant source of environmental lead, accounting for 17% of total lead emissions. • Particulates resulting from combustion have been shown to aggravate respiratory and cardiac diseases. Data show that excess deaths from heart disease, lung disease, and cancer increase in proportion to particulate exposure. iii Based on its analyses the SWAT ranked the four major solid waste program options according to six assessment criteria. cost, health impacts, environmental impacts, liability exposure, program risk and stability and convenience. A combined ranking across all categories ranks the options in the following order of preference: waste prevention, recycling, landfilling, incineration. Waste prevention avoids pollution from initial production and is by far the least expensive means of resolving disposal problems. Recycling reduces pollution and provides an economic stimulus as well. Landfilling presents some environmental drawbacks, but is an economically attractive way for disposal of unrecyclable waste. Incineration is the least desirable waste disposal option because it is the most costly and has the greatest level of undesirable environmental and health impacts. The understanding, cooperation, and support Town residents is crucial in implementing a successful waste management program. The SWAT will continue public education and outreach efforts to further citizen understanding and support for improved solid waste programs. Efforts will be made to expand participation in the Town's recycling program and to encourage voluntary waste prevention. The SWAT recommends that the Town make a commitment to a forward looking solid waste policy that seeks to impose the least cost upon Town residents, where cost includes health costs, loss of environmental resources, and loss of real estate values, as well as immediate municipal contracting costs. Such a program will clearly employ waste prevention and recycling to the greatest extent possible, and use landfilling and incineration only for that part of the waste stream that cannot be otherwise treated. The SWAT suggests a long term goal of reducing total waste by 50 per cent and increasing recycling to 60 per cent of the remaining solid waste stream. Near-term goals (which must, of necessity be more modest) are being developed. In the coming year, the SWAT will investigate successful waste management practices in other communities, such as the unit pricing programs that have been successful in reducing the costs of solid waste management by 25% and the quantities of waste by 45% or more in towns similar to Lexington. The Solid Waste Action Team will work with the Board of Selectmen and other branches of Town government to identify and implement programs for improving Town solid waste management. iv 1. Introduction This report provides the initial findings of the Lexington Solid Waste Action Team (SWAT). The SWAT was appointed by the Lexington Board of Selectmen to advise the Board on municipal solid waste management policy options, and to evaluate these options with regard to the growing health, economic, and environmental concerns associated with waste management. The SWAT was also asked to explore avenues for regional cooperation in waste management, and to recommend programs to improve participation in local recycling efforts. This initial report provides a long-term perspective on Town solid waste policy It is intended to establish the context for more detailed recommendations that will be developed in the coming year. Additional documentation and references that support this report are being provided in an information package accompanying this report. 1 1 A New Perspective Forty years ago, solid waste disposal might have been viewed as a simple question of how to obtain the cheapest per-ton fee for hauling trash away from the Town. As will be apparent in this report, program assessment has become more complicated due to the realization that waste that is hauled away for disposal often comes back into Town in the form of food, air, or water pollution, with significant implications for human health. It is this connection between solid waste practices and health that create the need for a more careful health-cognizant scrutiny of policy options. The economics of waste disposal have also changed considerably over the past forty years. The costs of traditional "throw away" treatments have risen, and the economic benefits of recycling have been proven. The ability of proper design and policy to reduce the quantity of waste without impairing the delivery of goods and services has been proven. It is here that some really good news has emerged: When all subsidies and hidden costs are fully accounted for, the practices that best protect the environment and human health are also those that are least costly 1.2 Assessment Principles To ensure a proper perspective in assessing solid waste options, the SWAT adopted the principles listed in Table 1 1 1 Table 1.1 Assessment Principles 1)LONG-TERM VISION. We will generate a long term vision that connects to short term practicalities. Without such a long-term vision, the SWAT feels that the Town can make mistakes and lock itself into inadvisable policies that would,in the long run, prove quite costly 2)APPLYING THE GOLDEN RULE TO REGIONAL IMPACTS.We will consider impacts upon all affected people as well as strictly local impacts. This implies that we will adopt a more consistently ethical point of view with regard to the burden placed upon other communities that may be the recipients of Lexington's waste stream. While at a superficial level it might appear that the Town could gain an advantage by shifting disposal burdens onto others,the SWAT feels that the damages inflicted by such a strategy upon other communities find their way back to our own Town through many pathways,both economic and environmental. In the long run,an ethical approach that is fair to everyone should be a superior strategy, 3)FULL ACCOUNTING FOR COSTS.We will consider all costs,direct an indirect, borne by Town residents. For many disposal options,significant costs that do not appear in the Town budget are borne by Town residents. In making decisions that are in the public interest,cost accounting should include the total costs,both direct and indirect, that are imposed upon residents by local solid waste programs. 4)CONSIDERING UNCERTAINTY Where uncertainty exists,or where data is subject to different interpretations, we will attempt to consider the range of uncertainty and not merely the best or worst case. The SWAT feels that good decisions require understanding the range of consequences, and must not ignore potential consequences simply because their magnitude is difficult to determine. 2 2. Waste Treatment Alternatives There are four fundamental methods of waste treatment available to the Town: o waste prevention o recycling o landfilling o incineration No single treatment produces an optimum program. A properly designed solid waste program should combine two or more of these options in a way that minimizes cost and maximizes benefits to the community The next four subsections summarize the relative desirability of the four options in terms of their costs, risks, and advantages. 2.1 Waste Prevention Waste prevention refers to any effort to reduce the total amount of trash that is collected for further treatment. Waste prevention is the least expensive treatment alternative and the most environmentally-friendly option. Some waste prevention can be achieved through more intensive public education to convince residents of the desirability of reducing waste and teach them techniques for doing so. Another option to be analyzed, which has been successful in other towns similar to Lexington, is a unit pricing program that allows residents to pay less for trash disposal if they generate less trash. This is sometimes called a "proportional rate" or "pay-per-bag" approach. In towns that have transitioned to unit pricing, the total volume of solid waste collected has often dropped by 35% to 50% Recycling rates have also increased significantly One of the problems considered by the SWAT arises from the fact that residents that generate minimal trash (e.g. senior citizens living alone) are in effect subsidizing other taxpayers who generate larger volumes of trash. The SWAT has received reports of commercial trash being set out for municipal collection (e.g. a carpet installer whose household trash always contains quantities of old carpet, an electrician whose trash often contains large quantities of old wiring and packaging of electrical items.) Unit pricing systems tend to reduce the subsidy of commercial operations by householders. The current flat rate system also denies residents on tight budgets the ability to control their solid waste expenses through exercising individual action Because unit pricing promotes fairness, waste prevention, and cost savings, it is one of the program alternatives that the SWAT will examine more closely in the coming year. Further waste prevention efforts can be pursued through state-level initiatives such as packaging laws, producer-pays laws, incentives for promoting durables over disposables, and improvements in product life cycle design. 2.2 Recycling Recycling is the second least expensive solid waste option. It also produces clear environmental benefits. Recycling treats the waste stream as an economic opportunity rather than as a burden. Studies have shown that recycling of materials can stimulate the local economy and produce jobs [Eyring94]. 3 According to the EPA, when recycling is substituted for use of unrecycled material, it reduces energy consumption by 43%, reduces air pollution by 90%, reduces water pollution by 30-100%, and reduces emission of greenhouse gasses by 70%. [EPA98a]. Significant cost savings result from each additional ton of recycled materials that are diverted from the waste stream. Some examples of this are provided in Table 2.1. The figures in this table assume that any changes in collection costs caused by diversion of waste into recycling are negligible. This is usually true insofar as costs of collection are more dependent upon the number of stops that the collection trucks must make than upon the exact tonnage collected. However, in particular situations contracting costs may jump up or down depending upon whether the contractor's equipment can be efficiently matched to the task (e.g. whether one truck is sufficient for pick-up or a second truck must be added). The table does not reflect revenues generated or tipping fees paid for recyclables (which vary with the market for recyclables). It can be seen that under the NESWC contract, it is important to know whether the town is currently above or below the GAT threshold. If the town is above the GAT threshold, then recycling avoids paying the tipping fee for the ton recycled. If the town is below the GAT threshold, then the tipping fee must be paid anyway but cost savings arise from reselling the unused GAT tonnage on the open market. Currently Lexington is below its GAT tonnage, and will probably remain below It is assumed that on average, 80% of the market rate value of the unused GAT tonnage is recovered by the town. Table 2.1 Savings achieved by recycling an additional ton of waste CONDITIONS RESULTS Contract Above Market NESWC Income Total Conditions GAT? Rate tipping from GAT Savingper Tipping fee Resold Ton Fee avoided Recycled Yes t $100 $0 $100 NESWC 1999 NESWC 1999 No $45 t $36 $36 Yes t $180 $0 $180 NESWC 2005 Open Market t $55 t t $55 2005 t=not relevant to savings in this case The figures in Table 2.1 are only examples intended to show the general savings from recycling. However, none of these further considerations alter the fundamental conclusion that for conditions applying to Lexington, increased recycling reduces waste management costs. 4 Additional economic advantages arise for recycling after the "disposal' Unrecycled trash simply decays in a landfill, leading to long-term problems with water pollution and suppression of property values" But the reprocessing of the recycled materials produces jobs, stimulates the economy and generates a tax revenue that is returned to the local community It has been estimated that nine jobs are created for every 15,000 tons of trash that is recycled. The same amount of trash would create one job at a landfill and two at an incinerator [Eyring94a]. Currently NESWC communities recycle approximately 33% of the waste stream, although Lexington's recycling rate is 54%. The current Massachusetts Solid Waste Master Plan calls for a statewide recycling rate of 46% by the year 2000. Other states have adopted even higher recycling goals, including Rhode Island and New Jersey, whose goals are 70% and 60% respectively Fourteen towns in Massachusetts already recycle over 56% and 17 towns recycle over 50% The rate of recycling for the NESWC towns could be improved considerably if clear policies for increasing recycling were to be adopted. Many recycling programs began as voluntary efforts with minimal public commitment to education, enforcement, and staff support. The SWAT has encountered the misconception that high rates of recycling are achievable only in "enlightened" communities where the demographics make the public education effort easier. But in fact low rates of recycling appear to he more a result of insufficient commitment on the pail of government than upon any differences between the citizens of communities. If recycling is viewed as an optional, volunteer activity and if the connection between throw-away programs and higher taxes are ignored, then recycling rates can be low But when recycling is taken seriously when a sustained effort to educate the public is made, and when the town provides adequate support, then excellent recycling rates can be achieved in almost any community in Massachusetts. 2.3 Landfilline Nationwide, landfilling is the most common technique for waste disposal. It usually provides significant cost savings over incineration. Landfilling has the advantage that the rate of trash flow can be adjusted over fairly wide limits to match demand (thus avoiding the need for long- term guaranteed annual tonnages). Improperly sited and managed landfills have caused significant environmental problems in the past. However there have been recent demonstrations that some of the problems of landfilling can be significantly alleviated if proper guidelines for siting and operation are followed. All landfills emit certain greenhouse gasses (such as methane) due to decomposition of buried waste. And leachate from landfills may be sufficiently polluted to cause local water pollution problems. Because landfills have finite capacity and because opening new landfills can take time, it is important to pursue waste prevention and recycling efforts in order to relieve the pressure on landfills. 2.4 Incineration Currently, incineration is the primary means used by Lexington for solid waste disposal. For this reason, it will he discussed in somewhat more detail in this report. A full explanation of how the Town became committed to the use of incineration is beyond the scope of this report, but certain facts that are relevant to future program planning will be detailed here. 5 Municipal waste incineration is accomplished by transporting waste to a central facility where, after separation of certain non-combustible components, the waste is burned under controlled conditions. Heat from the combustion process is used to power generators that produce electricity which can be sold to partially defray the costs of operating the facility Three- quarters of the weight of the trash burned is exhausted up the smokestacks, while one-fourth of the weight remains in the form of ash. The ash must be deposited in a suitable landfill. Incineration is the least desirable waste disposal option because it is the most costly form of disposal and has the greatest level of undesirable environmental impacts. Because of the large capital investment and the need of the facility to be provided with a steady volume of trash, incineration cannot be flexibly adjusted to meet the needs of the communities. Long term contracts are normally required, and communities become vulnerable to failure of a single large facility that might be caused by mechanical, economic, or legal problems. Incinerators ingest a contaminated fuel (mixed municipal solid waste containing mercury, lead, sulfur, and chlorine-based products) and disperse a significant amount of these contaminants into the downwind environment. In addition, incineration produces new pollutants during the combustion process (such as dioxin, particulates, and NOx). Some of these pollutants are among the most toxic materials known, and appear to have no threshold below which they are harmless. Pollution controls are clearly helpful in reducing emissions, but do not reduce emissions to insignificant levels. These residual smokestack emissions continue to cause adverse exposures to respiratory and food chain pollutants. In addition, air emission controls generally result in toxic materials being captured in fly ash (the ash that is removed from the smokestack exhaust). This leads to a further disposal problem when the ash is taken to landfills. Pollution controls are technically demanding with regard to design, maintenance, and operation. They can readily be frustrated by intentional or unintentional lapses in operational performance. Continuous monitoring is not available for some key toxics (such as dioxin), resulting in periodic testing being conducted at times that are known to the incinerator operators. Even where satisfactory control is theoretically possible, concerns remain due to the demonstrated ability of incinerator owners to evade monitoring, obtain unjustified waivers or exemptions, and influence government officials responsible for oversight. [Note: The company operating the MRI incinerator (Waste Management Incorporated) has a lengthy record nationwide of environmental violations, felony convictions, and lapses in operational performance. Documentation is available in the SWAT information package.] 2.4 1 Current Arrangement for Trash Incineration - NESWC Lexington is a member of the North East Solid Waste Committee (NESWC ), a public-private waste-management partnership planned and developed by the Commonwealth in the late 1970's. NESWC consists of 23 communities that signed a contract to send municipal trash to Mass Refusetech Incorporated (MRI). MRI is a private corporation that owns and operates the NESWC incinerator in North Andover. MRI is owned by Wheelabrator, which is a subsidiary of Waste Management Incorporated (WMI), a nationwide waste management company The NESWC towns include: Acton, Andover, Arlington, Bedford, Belmont, Boxborough, Burlington, Carlisle, Dracut, Hamilton, Lexington, Lincoln, Manchester-by-the-Sea, North 6 Andover, North Reading,Peabody, Tewksbury Watertown, Wenham,Westford,West Newbury, Wilmington, and Winchester. Currently, the direct costs for disposal at the MRI facility in North Andover is approximately $100 per ton under the NESWC contract which compares with a regional market disposal cost of approximately$45/ton. The NESWC rate is expected to grow to about$205/ton by 2005 due to the cost of the pollution control retrofit and the final payment of the construction bonds. By contract , Lexington must pay the MRI tipping fee for 11,396 tons of trash (the guaranteed annual tonnage, GAT). The Town can sell any GAT tonnage it does not use, but because market price is less than the MRI rate, the full cost of the MRI tipping fee cannot be recovered. An obvious question is why the MRI incinerator must charge NESWC towns almost twice the regional market rate for trash disposal. Such excess rates are quite characteristic of incinerator operations across the country In general, municipal trash incinerators can operate only with substantial taxpayer subsidy in the form of above-market-rate tipping fees, guaranteed tonnages, direct capital investments of public funds, subsidies for electricity generated, etc. When Lexington joined NESWC, highly inaccurate costs projections were provided to the towns, and this led to the NESWC communities signing a contract that was extremely unfavorable to the interests of the communities. This contract expires in 2005. At that point, the communities will have made over$200M in capital investment in the facility, which will then belong entirely to Wheelabrator (Waste Management Incorporated). At this point, it may be possible for the incinerator to operate competitively on the open market until the next increment of capital is required (to repair the facility or meet new pollution control standards). The full implications of this, and the alternatives, such as closure of MRI or early termination of the NESWC contract, will not be addressed in this report. 2.4.2 Risks of Cost Increases for Incineration Because of the complex operational issues and capital investment requirements associated with operation of an incinerator there are several financial risks that the Town is exposed to when incineration is employed as a disposal option. Among them are: o Requirements for additional pollution control devices. At the current time the threshold of harm for some of the incinerator pollutants, such as dioxin and mercury, are steadily decreasing as additional health research is completed. The EPA is scheduled to release a new risk assessment of dioxin in the near future, and it is expected that the report will document increased dioxin risks. Partly as a result of recent international mercury reduction goals, the state DEP has also stated its expectation that state-level controls on mercury will be tightened in the future. If current trends continue, the pollution control devices now being proposed may no longer be adequate and additional expensive retrofitting or pre-incineration separation programs will he required. o Rules for disposal of incinerator ash could he tightened, increasing ash disposal costs by a factor of three. Incinerator operators avoided the normal requirements for disposal of toxic ash by obtaining an agreement from EPA that they would be allowed to mix the toxic fly ash with the less toxic bottom ash before the ash would be tested. Whereas toxic ash disposal might cost $200/ton, the mixing allows the ash to he disposed of as non-toxic ash at$39/ton. The mixing did not reduce the total amount of toxic materials in the product. This rule is being challenged in 7 lawsuits filed against EPA and the possibility of a change in disposal regulations represents a financial risk. o Electricity deregulation is expected to reduce electrical rates. This would limit potential revenues from the waste-to-energy component of an incinerator, and might increase the effective cost of incineration. [Note: Under the current NESWC contract,electricity revenues for the facility are not tied to wholesale electricity prices. However, such prices should have an impact on revenues realized after the expiration of the current contract.] o Class action lawsuits filed by citizen groups could expose the NESWC communities to significant liabilities. Legal actions are already underway against one incinerator, without yet finding success. However, the situation seems to be evolving in a manner similar to the class action lawsuits against tobacco companies. Should citizen groups find an effective legal approach to suing for damages, the potential liability could be very large. An additional comment is in order with regard to the legal liability produced by the incinerator. In similar cases, large settlements have often resulted from the plaintiffs demonstrating that the operators ignored good practice or violated emission standards. Thus anything less than exemplary character and performance on the part of the operator exposes the communities to sharply enhanced legal risk. The SWAT has troubling concerns in this regard with the performance of Waste Management Incorporated. In addition to suspected irregularities in pollution reporting and monitoring, noted in the Inspector General report [IG97a] and the EPA's 1997 Notice of Violations, MRI has been operating for over 12 years without a site permit from the North Andover Board of Health. These irregularities create legal vulnerability for MRI and NESWC in the event of a lawsuit. o Mechanical failure, chemical contamination, radioactive contamination, explosion, or natural disaster could require the sudden infusion of substantial capital investment in order to keep the incinerator running. In addition, while repairs were underway, the communities would face a disposal crisis that could in itself be costly (According to the prevalent interpretation of the NESWC contract, the NESWC communities would have to pay for the entire cost of any clean-up and repair, and. would have to continue to pay for the GAT tonnage even though no disposal service was being provided.) o Recent data raises new concerns regarding the safety of landfill disposal of incinerator ash. Lawsuits or increased regulation in this area could result in significant additional costs. It should be noted that liability can extend for decades after the initial date of disposal. o Inability to adapt to changing economic or market conditions is a general penalty that is imposed by trash incineration. Because of the large capital investment costs involved, it is often necessary to enter into inflexible multi-year agreements (up to 20 years in duration) in order to secure the necessary capital for the incinerator Sole-source commitment to a single operator is required, preventing competitive contracting. Such agreements might be considered imprudent since they prevent taking advantage of new technologies and changing market conditions. R 3. Public Health Considerations This section explains some of the public health concerns that can enter into the determination of the preferred solid waste alternatives. 3.1 Increasing toxicity of the waste stream In the past 50 years the waste stream itself has become increasingly toxic as consumer products have incorporated greater quantities of chemicals with known dangers to human health, (metals, chlorinated organics, solvents, and polyaromatic hydrocarbons) as well as thousands of new synthetics whose health effects are completely untested. While the waste stream has increased in toxicity, it has also increased in volume, due to population growth and increased per capita waste production. In the US per capita waste production has increased by 60% since 1960, while the total volume of waste has increased 135% [EPA97a] 3.2 New Discoveries Link Waste Practices to Health Concerns Waste management in the past was based on the assumption that pollutants contained in the waste stream or generated by treatment could be rendered harmless by dispersion or by degradation in the environment. The ability of an incinerator with a tall smokestack to disperse any toxins in the waste widely over the landscape was viewed as a positive feature ("The solution to pollution is dilution"). Studies in the past two decades however reveal that some dangerous chemicals in the waste stream (such as mercury and dioxin) persist in the environment and bioconcentrate in the food chain. Thus, achieving low concentrations in the initial dispersal does not prevent the substances from eventually appearing in significant concentrations in food sources, particularly fish, meat, and dairy foods [EPA94c, EPA97b, ATSDR98b]. Some of these chemicals also persist for years in human tissues, and are hyperconcentrated in the maternal nourishment of the fetus and breast feeding infant [Patandin99a, Birnbaum99a, ATSDR98b]. Even small toxic exposures at critical times in fetal and infant development can create serious lifelong health consequences including cancer, learning disabilities, behavior problems, reproductive disorders, and immune disease [Schettler96]. The pervasive nature of the toxics of most concern, together with the long period of time that may elapse between initial exposure and the appearance of harm, can make traditional pollution control approaches ineffective. Many people can be injured before any conclusive link can be proven between emissions of a particular facility and the resulting injuries. And once the link is proven, and emissions are reduced, it can take many years for the levels of toxins in human tissues to fall to safe levels. Authorities including the World Health Organization and EPA recommend exposure limits for dioxin that are much smaller than current actual exposures. Reducing such exposures to acceptable levels will require a broad strategy for reducing emissions, and because waste incineration is a major source of dioxin [EPA98b] incineration must receive special attention. 3.3 Health Impacts of Incineration Incineration increases the mobility and bioavailability of pollutants, resulting in a significant increase in the likelihood that the toxics will impact human health. While improvements in 9 incinerator emissions controls can reduce the quantity of pollutants entering the atmosphere,it is not clear that such reductions are sufficient to overcome the persistence and bioaccumulation of the most dangerous toxics. Furthermore, many potentially harmful chemicals in the waste stream are not monitored at all. Pollution controls must usually be customized for each particular pollutant and are typically not pursued at all until after pollutants have been identified and proven harmful by the documentation of damage to human beings or the environment. Therefore, potentially harmful substances continue to be discharged into the atmosphere despite "state of the art" pollution controls. In short, current pollution control practices provide some after-the-fact damage control, but are inherently incapable of protecting public health in a preemptive manner. Another failure of pollution control practice arises from the fact that pollution controls do not necessarily reduce the total amount of toxins being produced. For example, retrofit to the North Andover incinerator to meet air pollution regulations will merely result in pollutants being shifted from smokestack exhaust to the fly ash. The potential for future contamination of groundwater and land near ash disposal sites is thereby increased 3.3.1 Mercury Within the state of Massachusetts, incineration has been the source of over half the mercury released, according to the Department of Environmental Protection [DEP96a]. The MRI Incinerator itself is responsible for 20% of these emissions. Mercury exposure is a proven danger to the cognitive development of the human fetus, and current levels of environmental mercury create risks for learning, memory and attention impairments in children. Mercury released to the environment is bioconcentrated in fish by a factor of 100,000. When contaminated fish are eaten, the mercury accumulates in fatty tissues. During pregnancy it is passed on to the fetus where it is toxic to the developing brain. The level at which mercury causes harm has been continuously lowered with evolving research in the past three decades. Recent studies suggest no threshold level below which mercury exposure is totally safe. Since mercury is an element, mercury pollution is permanent and cumulative. Mercury levels in tuna have reached levels that make the consumption of more than 1/2 pound per week unsafe for women of childbearing age. Half of all fish eaters, and 20% of all young children consume more than the advised safe limit for mercury (EPA97h). The fish in half the lakes and rivers in Massachusetts now contain enough mercury to make them unsafe. The release of only one gram of mercury (0.002 pounds) is enough to cause the fish in a 20 acre lake to he unsafe for consumption by women of reproductive age(Gilkeson, Minn. Dept. of Pollution Control). Even if the proposed retrofit achieves its most optimistic predictions, the MRI incinerator will continue to produce 25,900 grams (57 pounds) of mercury per year. If even a small fraction of these emissions (approximately 3% ) falls into Massachusetts waters, the fish in the remaining relatively clean lakes and rivers may become contaminated during the lifetime of the facility 3.3.2 Dioxin "Dioxin" is a general term given to a family of manmade compounds that are produced primarily by combustion of materials containing chlorine and carbon. Dioxin is a known human carcinogen, but its most troublesome impacts are reproductive, developmental and immunologic 10 effects that have been observed in many species, including man. Evidence suggests that dioxin is affecting human health at its current background levels. The exposure of breast-feeding infants, which is also an indicator of fetal exposure, currently exceeds recommended safe levels by a factor of 60. This early dose of early dioxin is disturbingly close to the dioxin dose that causes behavior and learning problems in laboratory animals. For example, behavior and learning impairments have been observed in monkeys at levels that are only twice that to which nursing infants in the NESWC communities are currently being exposed [ATSDR98a]. In both human and animal studies, dioxin demonstrates toxicity to the male reproductive system. Some authorities have proposed that high background exposures to dioxin over the past few decades may contribute to adverse global trends in male reproductive health, including a 50% decline in sperm count, a doubling of male genital birth defects, a declining male birth rate, and a tripling of the testicular cancer rate (Davis). Municipal waste incineration is the major source of environmental dioxin, accounting for a full 32% of known air emissions and 86% of landfilled dioxin [EPA94a]. While dioxin emissions of incinerators is small in terms of total weight, the emissions are significant in toxicity For example, the total, cumulative dioxin exposure a person can tolerate over an entire life time is referred to as a lifetime allowable-dose. .After the proposed retrofit of the MRI incinerator, the facility will continue to release over 1.5 million lifetime allowable-doses of dioxin each year. Nearly 10 million lifetime allowable-doses of dioxin will be added each year to MRI's ash landfill in Peabody It is important to note that dioxin is primarily generated by the waste combustion process itself, meaning that if the same waste stream was sent to a landfill, the resulting dioxin emissions would be relatively minor. Municipal waste incineration is the single largest source of dioxin (EPA1998B). While the amount of dioxin emitted from any one incinerator is small in terms of weight. it is significant in toxicity For example, even after the proposed retrofit of the MRI incinerator, the facility will continue to release over 1.5 million lifetime allowable doses of dioxin each year. (where a lifetime allowable dose is defined as the total cumulative dioxin exposure that EPA considers acceptable over an entire lifetime). Nearly 10 million lifetime allowable doses of dioxin will be added each year to MRI's ash landfill in Peabody It is important to note that dioxin is primarily generated by the waste combustion process itself, and is not present in significant amounts in the municipal waste stream prior to incineration. For this reason, municipal landfills do not contain significant amounts of dioxin with the notable exception of landfills that accept incinerator ash [EPA94c]. 3.3.3 Lead Waste incineration has been a significant source of environmental lead, accounting for 17% of total lead emissions [EPA96b]. Lead, like mercury, is a persistent pollutant. Lead emissions to the air from the MRI incinerator are expected to decline with new emissions controls, although reductions in air emissions will translate into increases in lead content of ash. Removing lead- containing items from the waste stream can reduce lead exposures due to waste disposal. However such separation increases the costs of waste disposal. 11 3.3.4 Particulate Emissions Municipal incinerators emit a variety of pollutants shown to aggravate respiratory disease, (such as asthma and bronchitis) and promote cardiac disease. Increasing levels of some of these pollutants, notably particulate matter, are correlated in a linear fashion with disease and death from heart and lung disease, and cancer [Dockery93a]. The current Clean Air Act standards and incinerator standards represent a politically feasible level of control. They do not represent a "safe level of pollution since data indicates that there is no level of exposure below which harm does not occur. Since pediatric asthma rates in Lawrence are over twice the state average, waste management options that minimize the emission of respiratory irritants in that area should be sought. In this regard,it should be noted that the options of waste prevention, recycling, and landfilling produce little or no particulate emissions. 3 4 Health Imnacts of Landfills The health risks of landfills arise from the potential for secondary water, land and air pollution in the vicinity of the landfills. Hazardous waste landfills have been associated with a variety of problems, (increased risk of birth defects, miscarriage and nervous system disorders). The health impact of municipal waste landfills are almost certainly less, but have not yet been fully characterized. It should be noted that landfills have not been a significant national source of mercury or dioxin releases (EPA). 3.5 Health Impacts of Waste Prevention Waste prevention- which results in less trash for disposal- is expected to have no significant health impact. In addition, waste prevention reduces the pollution associated with the original production of the materials. Hence, waste prevention is the most desirable waste management option from the perspective of health and environmental impacts. 3.6 Health Imnacts of Recycling Since recycled materials have already been refined and processed, recycling is generally cleaner and less energy intensive than initial production. When evaluated in a complete lifecycle impact analysis, recycling produces far less air and water pollution than incineration or landfilling. It therefore results in fewer secondary health impacts than any option other than waste prevention. 3.7 Dollar Costs of Health Impacts Beyond the classic health concerns of pain and suffering and lost human potential, there are significant dollar costs associated with health damage. Among these are: o Direct health costs. In environmental cost/benefit analyses, the cost typically ascribed to an induced cancer is $2M (including lost personal income and health expenses). The costs of neurological deficits, including the costs of special education for learning and behavioral disabilities, is also substantial but difficult to quantify 12 o Lower real estate values. There is a well-known negative impact upon property values of proximity to a trash incinerator or landfill. This effect could become more pronounced as health damages become better known. While these effects are expected to be minor within Lexington itself, they may be substantial in communities that receive Lexington's waste. 3.8 The Limits of Regulatory Protection The ability of the current regulatory regime to protect human health and the environment is limited by several factors, including political pressures exerted by corporate interests upon legislators and regulators, limited scientific knowledge, imperfect laws, and the general ineffectiveness of the regulatory process. The consequences of these limitations will be briefly discussed in this section. Pollutants have been increasingly recognized as dangerous as our knowledge base increases. For most pollutants, the threshold exposure known to cause harm has decreased over time. Thus current guidelines for safe emissions must be viewed as temporary standards and are generally not adequate for long term policy decisions. A single study showing health effects at lower levels than previously known can turn a "safe" facility into the source of a newly recognized public health catastrophe. Indeed this is exactly what has occurred in the last 12 years with respect to mercury and dioxin emissions from the MRI incinerator. MRI emission controls that were certified as safe and "state of the art' have been found to be the source of serious environmental contamination and health impacts. Injuries to public health are virtually guaranteed by a regulatory regime that acts only to alleviate the most recently proven level of harm. A regime that was designed to fully protect public health would instead ask for proof that exposure was safe, and would relax standards only as such proof was provided by facility operators. In recent health assessments of the effects of trash incineration in the Merrimack Valley, the Massachusetts DEP has failed to address the more serious dietary exposure issues, concentrating instead upon respiratory exposures. The draft DEP report determined that the incinerator was probably in exceedance of standards with respect to hydrochloric acid (HCL), and additional pollution controls (prior to those that will occur as a result of the retrofit) were suggested. However the DEP analysis was restricted to the question of whether current air quality standards are met in the vicinity of the incinerator. This approach failed to address health risks from incinerator pollutants that contaminate food sources. Such exposures exceed air exposures by orders of magnitude. According to EPA estimates, over 97% of human dioxin exposure occurs through food contamination [EPA94c]. Similarly, mercury exposure due to ingestion of contaminate food exceed inhalation exposure by a ratio of 80:1 [WHO90a]. Due to the concentration of persistent pollutants in fetal nourishment and breast milk, the preponderance of food-based exposures is even greater during the earliest, critical stages of human development. Hence, serious questions have been raised regarding the relevance of the Massachusetts DEP's efforts to assess the health consequences of pollution in the Merrimack Valley 13 4. Desirability Ranking of Waste Management Options Table 4.1 provides a ranking (1=best, 4=worst) of the four major solid waste program options according to six assessment criteria: cost, health impact,environmental impacts, liability exposure, program risk and stability, and convenience. 'Liability exposure" refers to the potential that the Town could be held liable for partial payment of damages to persons filing suit over health or environmental damages. "Program risk and Stability' refers to the risk that the program will face escalating costs or operational failures that would endanger the continuation of the program. "Convenience" refers to the perceived convenience of the program from the point of view of the individual. In terms of"liability exposure", as noted earlier, incineration generates exposure due to landfilling of the combined fly and bottom ash. This liability is assessed to the incineration process in addition to liability due to air emissions. This assessment provides an interesting conclusion: If one formulates a combined ranking across all categories, the desirability rankings clearly follow the following order: waste prevention, recycling, landfilling, incineration. The primary deviation from this order occurs in the "convenience category since recycling requires individuals to spend additional time separating and sorting items to be placed in the trash container It should be noted that the Massachusetts DEP is considering proposals to require communities to separate mercury and lead-containing items from the trash stream prior to incineration, and this could decrease the level of convenience associated with this option. Table 4 1 Ranking of Desirability of Solid Waste Program Options (1 = most desirable, 4 =least desirable) ASSESMENT WASTE RECYCLING LANDFILLING INCINERATION CRITERIA PREVENTION Cost 1 2 3 4 Health Impacts j 1 I 2 3 4 Environmental 1 2 3 4 Impacts Economic 2 1 3 4 Benefits Liability 1 2 3 4 Exposure Program Risk 1 2 3 4 and Stability Convenience I 3 I 4 I 1 I 2 Figure 4.1 provides a depiction of the mass flow for Lexington's solid waste stream under the incineration-based option currently in effect. All percentages refer to percent of weight of the original waste stream. In tracking the waste, we use the weight rather than the volume because compression of trash should not be viewed as a treatment. For the current program, about 30% of the stream is recycled and 70% is sent to the MRI incinerator. At the incinerator, the trash is burned and 3/4 of the weight is exhausted into the atmosphere. One-fourth of the weight remains as toxic fly ash and less-toxic bottom ash. The ash is mixed (to avoid requirements for toxic waste disposal of the fly ash), and the ash is sent to a landfill. The pollution consequences arise 14 from the 52.5% of the trash that is exhausted into the atmosphere and the leachate from the 17.5% of the trash that is landfilled. ORIGINAL FINAL WASTE WASTE STREAM STREAM PROCESSED AIRBORNE STATE POLLUTION Mercury •Dioxin eb RECYCLED Lead •Particulates GENERATED 30% WASTE • RELEASED INTO ATMOSPHERE INCINERATED 0,1 52.5% ASH ASH LANDFILL 100% 70% 17.5% 17.5% Figure 4.1 Incineration option Figure 4.2 provides the mass flow for the future solid waste program that is recommended as an ultimate goal by the SWAT Here the initial waste steam is reduced by 50% through waste prevention efforts. Of the waste that is then collected sixty percent is recycled, resulting in only 20% of the original stream remaining for disposal. This stream is then deposited in suitable landfills. The only source of pollution is the leachate associated with this non-toxic landfill. The generation of dioxins and other toxics by incineration is completely eliminated. 15 ORIGINAL FINAL WASTE WASTE PROCESSED STREAM STREAM STATE (avoided pollution prom initial packaging 3090 production) WASTE PREVENTION disposables and non-durables 30% 50% RECYCLED GAS EMISSIONS GENERATED 30% " T`" e other 40% 30%7F WASTE / LANDFILL LEACHATE 100% 50% 20% Figure 4.2 Least-cost ecological option These two figures provide a clear picture of the long-term changes that the SWAT feels are desirable in Lexington's solid waste program. It should be noted that this desirable end state cannot be achieved in a single leap, and joint efforts at the regional, state, and national levels will be required to supplement purely local actions. It is important to scrutinize near-term decisions to make sure that they do not create impediments to long-term progress. In this regard, it should be noted that commitment to support of an incineration industry appears to be inconsistent with realizing the full benefits of recycling and waste prevention. Similar drawbacks could accompany any broad expansion of landfilling capacity prior to fully implementing recycling and waste prevention measures. 5 Citizen Involvement and Public Education Understanding and support from Town residents is important to achieving an effective and sustainable waste management program. Citizens must be willing to participate in the Town recycling program and to make personal decisions, as consumers and homeowners, that will reduce the volume of solid waste. Consumers must insist that the businesses they patronize assist in eliminating wasteful practices, and citizens must understand and support Town solid waste policies. The SWAT is optimistic that the required level of support for better waste management policies. can be obtained. High levels of public support have been achieved in other New England communities similar to Lexington. The key to such support is a broad public understanding of the economic, health and environmental costs of waste. In the coming year, SWAT will promote public education on waste, and specifically on reducing, recycling, and toxics reduction. This effort will involve the following items: 16 1) Public-education resources. The SWAT will maintain: a SWAT web site (http://www.lexingtonma.org/swat/HomePage.htm) and a bimonthly email newsletter. The SWAT will develop simplified recycling instructions,frequently-asked question brochures, and a summary of the health,economic, and environmental benefits of reducing/recycling. Articles will be prepared for the Lexington Minuteman newspaper. 2) Community Outreach. Contacts will include schools, businesses, and religious organizations in Lexington to encourage them to develop their own recycling plans for their organizations. A public meeting on solid waste management will be organized. Coverage of solid waste issues will be sought on Lexington Cable. 3) Local Networking. The SWAT will work with other interested citizen groups including the Lexington League of Women Voters, Citizens for Lexington Conservation, Neighborhood Associations, and the Senior Center 4) Regional Networking. The SWAT will work with regional and statewide groups that are concerned with issues related to waste disposal, including recycling committees, neighboring town officials, and DEP planners. 6. Policy Recommendations The SWAT makes the following recommendations regarding Town solid waste policy 1) The overall long-range commitment of the Town should be to implement a solid waste policy that imposes the least cost upon Town residents, where costs include health costs, real estate values, and environmental impacts in addition to immediate municipal contracting costs. 2) Lexington should seek future contractual arrangements in which the Town can receive the maximum cost savings for any increase in trash recycled and any decrease in the total waste produced. (The Town should avoid provisions that would interfere with this objective, such as long-term commitments to guaranteed annual tonnages of unrecycled waste.) 3) Lexington should pursue the greatest feasible use of waste prevention and recycling because they are the most effective ways to achieve cost savings and environmental benefits. Promotion of these objectives requires not only good public policy but educational efforts to bring about changes in personal behavior with regard to waste production and participation in recycling programs. The Town of Lexington and the Town s legislative leaders should pursue regional, state, and federal initiatives that would support waste prevention, recycling, and the detoxification of the waste stream. 4) The Town of Lexington should promulgate preferred-purchasing guidelines for town purchases that support 'buy recycled' and 'buy nontoxic practices. Businesses and educational institutions should be encouraged to adopt similar guidelines. 5) Lexington should encourage the establishment and expansion of businesses associated with the recycling of municipal solid waste. This provides an economic stimulus while increasing the strength and stability of the market for our recycled materials. 17 7) Lexington should support legislative proposals to assist the NESWC communities in transitioning to a more desirable solid waste disposal program. However, Lexington should not support state funding that constitutes a taxpayer subsidy for continued operation of problematic facilities or continuation of uneconomic, ill-conceived programs. 8) In order to be prepared to take advantage of opportunities that will arise in the future, Lexington should develop a solid waste strategy that looks ahead at least ten years. The groundwork for improved solid waste programs, in terms of public education and employee training, should be prepared in advance to avoid a delay between the time savings become possible and the time they are actually achieved. An important transition date that is rapidly approaching is in 2005 when the current NESWC contract expires. 7 Plans for the Coming Year In the coming year the SWAT will focus upon several topics, including the following: o Strengthening Lexington s recycling and hazardous waste disposal programs. The SWAT will continue to develop programs to promote increased participation in the Town's recycling program and the regional hazardous waste disposal program. The SWAT will work with representatives from schools, business, and religious communities to develop specific programs to promote these goals. o Regional efforts to further sustainable solid waste programs. SWAT will work with the Lexington DPW other Massachusetts communities, and area legislators to promote local, state, and federal incentives that will encourage the purchase of recycled materials, a reduction in the use of toxic materials, and reductions in unnecessary packaging and other sources of avoidable waste. o Program Analysis. The SWAT will work with the Town DPW and the Board of Selectmen to analyze the costs and advantages of the various solid waste disposal options that are available to the Town. The evolving health and environmental consequences of the options will be assessed. The SWAT will examine innovative programs adopted by other communities, such as unit pricing (pay-per-bag) programs, advanced trash collection technology regional resource recovery centers, etc. The SWAT will investigate trash collection strategies that would allow residents to pay less for trash disposal if they generate less trash. o NESWC. The SWAT will continue to evaluate opportunities for reducing the economic burden of the NESWC contract and for reducing the health and environmental impacts of the NESWC incinerator. Issues that arise here include stricter emission control standards, waste stream segregation proposals, proposals for new state assistance to NESWC communities, and proposals for closure of the North Andover facility The SWAT will also study the implications of the expiration of the current NESWC contract in 2005 18 References ATSDR98a Agency for Toxic Substances and Disease Registry, 'Toxicological Profile for Dioxin' U.S.Dept.of Health and Human Services,Atlanta,Georgia, 1998 ATSDR98b Agency for Toxic Substances and Disease Registry, 'Toxicological Profile for Mercury' U.S.Dept.of Health and Human Services,Atlanta,Georgia, 1998 Birnbaum99a Birnbaum,Linda, 'Dietary Exposure to PCBs and Dioxins in Children Environmental Health Perspectives,Vol. 107(1),January 1999 Denison Denison,Richard A. 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