To city leaders, future or present, and all concerned and involved citizens, I would like to provide some information regarding the proposed gasification plant that is now being considered to mitigate the methane buildup at the landfill. I beg you to consider the possibility that there would be more risks associated with this project than we currently face with the methane situation at the landfill. The waste industry has launched a massive effort to build incineration-like technologies for hazardous waste, garbage, and medical waste. Most companies promoting these technologies claim there would be no toxic emissions. Unfortunately, this absolutely false, just as it was when they made the same claims for incineration, and they do pose a threat to the health and environment of our communities.
It is also doubtful that the project would be worth the little extra energy it might provide. We need to see the data that supports the claims that this project would provide energy for Shannon, or the University, considering that the Syngas that would be produced has only ¼ the energy rating of natural gas, our limited supply from the waste stream, and the primary obligations the city would have to three military bases. There is also evidence that these types of plants have been known to under perform when it comes to the energy they are expected to produce.
In the area of economics this project does not add up. The extreme expense and environmental risks involved with this technology have prevented it from becoming established as an energy resource in North America. The revenue that this project is projected to generate is totally theoretical and speculative, and in fact, Siemens has no waste gasification plants in operation in the world. They do not even mention waste gasification technology on their extensive web-sight. The only experience they seem to have ever had in this experimental niche of the energy market was in Germany where their waste gasification plant was closed after an entire neighborhood in the town of Furth had to be evacuated when clouds of gas leaked from the plant following an explosion, resulting in the hospitalization of personnel and locals. The incident prompted the Siemens Company to shelve its waste treatment business altogether, until now it seems.
A hand out provided at a public meeting last week declared that “Thermal Gasification Is Not Incineration;” however, the EPA's own data show that gasification units produce more dioxins, furans, nitrogen oxides, the same amount of lead, mercury and cadmium. Some of the chemicals such as carbon monoxide and sulfur dioxide, are reduced, but not eliminated.
Supporters of this resurrected technology, such as Michael Williams, Texas Railroad Commissioner who has appeared in the paper touting this technology last week, and who is a member of the National Coal Council, (an important conflict of interest) has been taking advantage of semantic tricks that have been made possible by the EPA, using terms such as “zero emissions,” and “renewable energy” when referring to gasification. Clean up for these plants always adds hefty operational expenses (which create a powerful disincentive to invest in adequate safety equipment, backup systems and procedures) and is never fail safe or complete. In addition, whatever toxins they can “remove” from the air, are still produced and must be disposed of or reintroduced into the environment somewhere. Most of the toxins that are diverted from the air will end up in the landfill but should be classified and treated as hazardous waste.
Methane is not toxic... Hydrogen sulfide and cyanide, nitrogen oxide, dioxins, furans, mercury and lead are without doubt produced by gasification and without doubt, top the official list of the most toxic, cancer causing, potentially lethal, substances known to science and man...
This hand out that our city saw as sufficient to inform the public was a 2 page excerpt taken from a 200 page report from and investigation into gasification by Alameda Power and Telecom, the public power agency of the city of Alameda, CA. Much like the scenario here in San Angelo, APT had first discussed siting the garbage plant in a low-income community, without public discussion. Residents and environmental justice groups responded by forming a three-city grassroots coalition that challenged the claims of “no emissions” and advocated for clean, renewable energy. The mayor of San Leandro, where the plant was to be located, spoke strongly against the project. After investing $500,000 to conduct the investigation into 6 different companies, they decided to REJECT a possible garbage “gasification” plant to meet Alameda’s future energy needs. If you would be interested in reading some of the public responses received by APT from the educated public in that area, they can be found at this web address: http://www.alamedapt.com/newsroom/reports/gasification_comments.pdf .
Some may argue that this is par for the course in “wacky” California, but obviously the proposal to build a gasification plant could not hold up against the scrutiny that occurred in that community, even after the initial $500,000 investment had been made. The full report reveals in that investigation into gasification, that the "Potential for Emissions of Air Toxics" was "less impressive" than all the other data on their score chart- yielding an average index of only 43 out of 100 when reviewing data from 6 different companies making proposals..."DESPITE THE FACT THAT ALL THE SUBMISSIONS MADE WERE CAPABLE OF MEETING FEDERAL, STATE, AND LOCAL SITTING AND PERMITING STANDARDS..." The report continued that, “…the team chose an aggressive approach of deducting strongly for any technology that is potentially less than completely thorough in destroying or re-creating these (hazardous) compounds…”
We should ask: who among those supporting this proposal in our community has engaged in any serious inquiry into the risks involved and where are their findings???
City manager Harold Dominguez claimed at the public meeting that he had been to Japan and had witnessed how this alleged “cutting edge” technology is being implemented with great success. But, according to the Zero Waste Program Declaration of the Kamikatsu-cho, Katsuura, Tokushima Prefecture, September 2003, the people of Japan are pressuring the government to move away from these technologies, which have bogged down progression toward what they now understand is necessary –a zero waste management plan with a focus on recycling and consumer and manufacturer responsibility. “The tendency to build and become dependent on facilities such as incinerators is contributing to such major problems as environmental pollution, growing anxiety among residents and an enormous burden on regional government budgets. These expensive waste disposal facilities only encourage increased waste output and do not contribute to waste reduction.”
Some are claiming that burning trash is the solution to reducing the methane building up in the landfill. But as the space opens up, the city plans to charge other towns to bring their trash to the San Angelo landfill! This scenario will never result in the reduction of methane or waste. Once the investment is made there will actually be an incentive to perpetuate the accumulation of garbage and methane to continue to produce the gas.
If we look at the trends in waste management of some of the most progressive areas of the world, such as Japan, New Zealand, Australia, Canada, the EU and some states in America like California, Washington and Colorado, we can conclude that this $100 million dollar investment will be obsolete in about 20 years – just about the time the city expects to pay off the debt and start making their money. Many in these areas also conclude that gasification is not a Green Technology but an incineration “make-over,” which is just as hazardous, and counter-productive to real solutions.
If San Angelo wants to look towards measures for our future and be ahead of the curve, first and foremost, we all need to change our mentality about trash, start producing less waste, and recycle everything we can. This is the most efficient, effective, sustainable, clean, safe, and potentially lucrative, way of dealing with the very serious issue of waste management that our society faces today. If we understand that recycling is a fundamental part of any waste management program, but don't think West Texas is intellectually ready to implement big changes in this direction, then we need to educate.
We need our leaders to recognize how far behind a gasification plant could leave us in the decades to come. This project will put us years behind where we already stand on recycling, not to mention the ramifications of the hazardous waste build up in our community. We do not need to create more problems that will cost us again, in many ways, in the long run. We need leaders to promote “developments” with health, safety, quality of life, economic responsibility, and foresight in mind. All the theoretical cash generating projects should be secondary to this principle.
Here is one of the exclusions, passed by EPA in 2002 that that makes it possible for the industry to claim that this gasification is a “Green,” nonpolluting technology:
The EPA is proposing revisions to the RCRA hazardous waste program to allow a conditional exclusion from the definition of solid waste. This exclusion would be for hazardous oil-bearing secondary materials generated by the petroleum refinery industry when these materials are processed in a gasification system to produce synthesis gas fuel and other non-fuel chemical by-products.
Other loopholes are inherent the air emission standards themselves. In addition, the few records available regarding the testing of emissions on these plants have been done while the facilities were operating with controlled and reduced inputs, and often data collection begins subsequent to the initial start up period when most of the toxins are released.
While it has been said that the residual waste products we will be left with will be “inert” and disposed of in the landfill, this is also a conclusion drawn with the utilization of semantic and logistical tricks. The following is an except taken from a report by the Blue Ridge Environmental Defense League on the impacts of waste gasification on the environment and public health:
A national controversy about ash toxicity erupted in 1995 when then-EPA Administrator Carol Browner allowed incinerator operators to mix bottom ash and fly ash together prior to toxicity testing. Fly ash raises the pH of the ash, reducing the reliability of the tests. But citizens who gathered samples of ash from incinerators which had passed the EPA’s tests found very high levels of toxic metals. Gasification units produce both bottom ash and fly ash. The toxicity of gasification combustor ash would be no different than incinerator ash because the source, municipal solid waste, is the same.
Other countries treat bi-products produced from waste gasification as a concentrated hazardous waste, and are recognizing gasification as incineration, an old technology that has already wreaked havoc the world over…
Honest leaders with primary concerns for the health and well being of all should look very critically into EVERY angle of everything they do in the name of the public good. We cannot always rely on the biased “experts” to supply us with the information we need. Especially when looking at extremely costly and risky endeavors that require huge investments of money, time, and intellectual capital. A lot could be done with $100 million. We need to make sure the investment will take us as far as we can go.
Thanks for your careful deliberation on this important matter,
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