Comments by The Consumers' Association Of Penang and Sahabat Alam Malaysia on the detailed EIA of proposed therma waste treatment plant for solid waste management in Kg. Bohol, Mukim Sungai Besi, Kuala Lumpur
25th September 2000

INTRODUCTION
The Detailed Environmental Impact Assessment (EIA)of the proposed Thermal Waste Treatment Plant for Solid Waste Management in Kampung Bohol, Mukim Sungai Besi, Kuala Lumpur was displayed in the Department of Environment for public comments and feedback, as required under Section 34A of the Environmental Quality Act '74 and guidelines made thereunder.

Consequently, the Consumers' Association of Penang and Sahabat Alam Malaysia took the opportunity to study the EIA and we hereby submit our comments and feedback on the same. Our comments are made with reference to the specific chapters in the EIA as stated below.

1. CHAPTER 3 - PROJECT OPTIONS
REPORT IS BIASED IN FAVOUR OF THERMAL OPTIONS AND OTHER NON-THERMAL DISPOSAL OPTIONS NOT ADDRESSED SUFFICIENTLY

Incinerator Option Already Decided By Government

The proposed project is a part of the Integrated Solid Waste Management System in Kuala Lumpur. The objective, as stated in the EIA report, is to efficiently manage solid waste disposal and treatment so as to reduce the load and landfills, which is the existing practice of solid waste treatment.

Under the options of disposal methods in Chapter 3, the EIA includes information on waste reduction, composting, refuse derived fuel, sanitary landfill and thermal waste treatment.

However, in considering the various options for waste disposal, the EIA report is biased in favour of thermal waste treatment technology, devoting a substantial part of the EIA to considering this technology as an option. It gives very scant regard to the other options and does not give much importance to waste reduction and composting or other non-thermal disposal methods.

In fact, the report states that "waste reduction is also a component of an integrated municipal waste management system and not a solution to the waste disposal problem". This statement is quite misleading and not entirely correct.

If all the various waste reduction methods like reusing, recycling, composting, etc are utilised to handle our wastes, then our volume of waste would be reduced substantially and that would mean less waste to be disposed off in the landfills. Hence, serious waste reduction efforts can indeed be a solution to the waste disposal problem.

It is quite clear from the EIA that the Federal Government had already decided on the incinerator option several years ago. According to the EIA, the Government in privatising the management of solid wastes to Alam Flora Sdn. Bhd, required the concessionaire to build and operate a thermal waste treatment plant (an incineration plant) "…as an intermediate treatment to reduce the volume of waste to be landfilled." (see Chap 1 pg. )]. However, subsequent to this decision, the EIA reveals that the Government will now undertake the construction of the incinerator.

The EIA does not however set out the rationale for arriving at the decision for such an option after a detailed consideration of all the various options. Since the decision by the Government has already been made, the incinerator option is naturally promoted at the expense of the other alternatives that exist which are more environment-friendly and much cheaper.

The Federal Government's move is clearly very short-sighted - i.e. in wanting to reduce existing volumes of waste by burning everything at a very high price. It has been argued elsewhere that the Government is obtaining very cheap loans from Japan to build this incinerator, estimated to be about RM 2 billion. The incinerator is not being built for free. The public will still have to repay the loans even if interest rates are low.

In considering the 'no-build' option, the EIA states that this option would only be recommended if this study concludes without doubt that the proposed project would have considerable adverse effects with no mitigation measures possible. In otherwords, the incinerator idea would only be abandoned if there are no mitigation measures for the adverse impacts stemming from such a plant.

Incinerator Option Compromises Other Waste Minimisation Strategies

Thermal options such as incineration technology rely upon the continued generation of waste to support the high operating costs. Pressure to pay back the high cost of building incinerators has had the effect of encouraging and perpetuating waste generation. Investment in incineration would inhibit the development of more sustainable waste minimisation practices, as well as the exploration and development of products and processes that do not use toxic chemicals in the first place.

In fact, in Chapter 3, page 7, the EIA itself states that the impacts of waste diversion programmes will have an impact on the proposed plant. It further states that "Recycling activity of "say, 10 percent, will affect the efficiency of the proposed plant. This depends on the type of waste to be recycled." Therefore, once the incinerator is in operation, future waste minimisation efforts would be seriously compromised, given the likely impact it will have on the incinerator's continued performance. In otherwords, the future of the incinerator may take predominance over other waste minimisation strategies that are important for public health and safety.

Composting Option - Not Adequately Addressed

The reference in the EIA to composting mainly emphasized the drawbacks of large scale composting plants. The report did not discuss the feasibility and advantages of home composting methods i.e. worm composting, basic composting, underground composting and closed air composting. Through home composting, some of the household organic waste (about 30% based on our waste composition) is diverted and it helps the environment by recycling valuable organic resources and improving the fertility and health of the soil in the garden and house plants.

Other Options In Dealing With Waste Stream Based on the composition of solid waste in Malaysia (Table 1.3), the following can be done with the valuable materials that is separated from the source or salvaged from the waste stream.

These aspects have not been considered sufficiently in the EIA report.

Landfills Still Needed To Deal With Toxic Incinerator Ash

Incineration is touted as an alternative to land filling. Yet incinerator ashes - contaminated with heavy metals, unburned chemicals and entirely new chemicals formed during the burning process - are buried in landfill or dumped in the environment.

Incineration actually perpetuates the use of landfills because of the large quantities of leftover ash produced by incinerators. In Chapter 3 pg 4 it is stated that the volume of waste is reduced to 90-95% by using the incineration method. This is another bare allegation which is unsupported by any substantial evidence.

According to Dr. Paul Connett, a waste management expert from the US, incineration is only able to reduce 3 tonnes of waste to 1 tonne of ash. If the proposed incinerator is going to be dealing with 1,500 tonnes of waste per day, it would mean that after burning, we would still have 500 tonnes of ash left.

Even if we accept the EIA's estimates of 95% reduction in volume by incineration, there will still be 75 tonnes of ash generated everyday which will amount to about 2,250 tonnes a month. This is not an insignificant amount of toxic wastes!

Regrettably, the report has not sufficiently dealt with the need for specific landfills for the toxic ash generated by the proposed plant. General references are made in Chapter 8 for the disposal of the ash (and the highly risky conversion of the ash into usable materials) but there is no specific identification of suitable locations. In fact the report even suggests that the bottom ash of the plant can be disposed in either monofills or MSW landfills with double liners in a very flippant manner without rigourous scrutiny and attention.

This ash is very toxic, containing concentrated amounts of heavy metals and dioxins which, when buried, will eventually leach into the soil, potentially polluting groundwater.

Disregarding the obvious dangers of the toxic ash, it is stated in the EIA (Chapter 4, pg 9) that the melted slag would be suitable for brick making or construction material. Experiences from abroad show that using the ash from incinerators was a major mistake. Ash from a municipal waste incinerator in Newcastle, UK, was used on local allotments and paths between 1994 and 1999. All of it had to be removed recently after it was found to contain unacceptably high levels of some heavy metals and dioxins.

Technology Assessment And Lack Of Cost-Benefit Analysis

The EIA states that the important criteria for the selection of the municipal solid waste treatment technology are reliability, cost, conformance with the environmental regulations and system. However, the technology that is incorporated for selection is only thermal treatment technology. The EIA report fails to include waste reduction, composting, RDF, sanitary landfill and other methods in this assessment and comparison.

There is also no cost-benefit analysis done on the selection of the municipal waste treatment technology.

Incinerators with state-of-the-art pollution control equipment are formidably expensive. Once the authorities invests in incineration they often don't have enough money to invest in waste reduction. In this way, incineration directly competes with efforts to reduce and recycle waste.

Very few jobs are created in return for the huge economic investment in incineration. Most of the jobs are temporary, created during the building of the plant (expected 200 workers during the peak of construction). This proposed incinerator in Kampung Bohol is expected to employ less than 100 workers only.

On the other hand, community efforts into waste separation, reuse and repair, recycling and composting can create more jobs, both in the handling of the waste and in secondary industries using recovered material.

The EIA report also fails to recognise the contribution of scavengers or ragpickers in separating the waste that goes to the landfills. The impact of the thermal waste treatment technology (that diverts all the waste to the incinerator) on the lives and economy of these scavengers should have been assessed in the report.

Also, most of the money invested in the incinerator leaves the community. The huge engineering firms that build incinerators are foreign and so most of the money invested leaves the country and the community. On the other hand, money invested in the low-technology alternative stays in the community creating local jobs and stimulating other forms of community development.

Recycling saves more energy than incineration yields. For instance, if the United States burned all its municipal waste in incinerators, it would contribute less than 1% of the country's energy needs.

Two studies performed in the US in 1993 and 1994 show that if the currently marketable recyclable material, which is typically burned in a modern trash incinerator, was recycled instead, some 3-5 times as much energy would be saved. The reason: Incineration can only recover some of the calorific value contained in the trash; it cannot recover any of the energy invested in extraction, processing, fabrication and chemical synthesis involved in the manufacture of the objects and materials in the waste stream. Reuse and recycling can. In fact, a wide-ranging cost-benefit study conducted for the European Commission 1997 concluded that even landfilling was better and more energy-efficient than incineration for managing household waste.

Finally, the cost of constructing, procurement and operation of the incinerator is exorbitant. The initial stages of procurement of equipment and construction would run to more than RM1 billion. Further, the operational and maintenance costs for the next twenty years (expected life span of the incinerator plant) would be considerably high. The costs of all these would have to be paid by the public either through imposing a fee for solid waste collection/treatment or through other forms of taxes.

On the other hand, through aggressive waste minimization campaigns, composting and recycling efforts initiated by the authorities and waste managers, the public would not have to spend much but actually gain to profit from these efforts.

The EIA report should have given a thorough analysis of all these facts and not emphasize on thermal waste treatment technologies only.

Controversies Over Incinerators and Trends Abroad Ignored

Chapter 3 pg 4 indicates that it is possible to locate incinerator plants in densely populated areas as it is an environmentally acceptable form of waste treatment. Further it is stated that incineration has played a role in municipal waste management for more than 50 years in many major Japanese, European and American cities.

What the EIA report fails to clarify are the controversies revolving around the incineration technology in these countries. Many of the industrialised countries cited by incinerator salespersons as proponents of incineration technology are rapidly shutting down their incinerators. Faced with shrinking markets in pollution-conscious northern countries, incinerator companies are turning to Asia where they see a lucrative market for their outdated and poisonous technology.

About 4,600, or 17 percent, of Japan's 27,000 garbage incinerators have permanently or temporarily suspended operations due to the tightening of controls on dioxin emissions in January 1999, according to the findings of an Environment Agency survey. Operations at about 620 of the 27,000 facilities had been suspended, while about 3,980 incinerators were out of action indefinitely. [The Daily Yomiuri (Tokyo) June 29, 2000].

One of the key drivers behind current environmental policy in Japan is national concern over health risks due to widespread dioxin contamination. Japan generated 5,300 grams of dioxin in 1998, according to a Ministry of International Trade and Industry emissions inventory. The MITI report also states that municipal solid waste incinerators generated about 80 percent (4,300 grams) of Japan's 1998 dioxin emissions. Based on these figures, UNEP determined that Japan produces almost 40 percent of all airborne dioxins from identified sources worldwide. [The Japan Times, July 17, 2000]

In countries, such as the Netherlands, Germany where pollution regulations are impossibly tight, incinerators continue to incur enormous costs to clean up the pollution they cause.

Today, incinerators are being sold under a variety of guises - such as fluidised bed incinerators, thermal treatment plants or as waste-to-energy systems. Through incineration, industry has found a way to break down its bulk waste and disperse it into the environment via air, water and ash emissions.

Incinerator promoters argue that there have been developments in technology for controlling emissions to the air. New incinerators are again being proposed in some European countries. Governments charged with managing industrial waste stand at a critical juncture. They can continue to approve and promote the harmful incineration technology, or they can encourage the development and use of clean production methods that eliminate toxic processes, products and waste.

The Malaysian government should adopt the cleaner and safer technology of waste reduction, and not be fooled by the seemingly harmless incineration technology. Far from making waste disappear, incinerators actually create more toxic waste, and through this pose a significant threat to public health and the environment.

In promoting the incinerator option, the EIA has underestimated the dangers of the technology to public health and the environment. We will deal with more of this in further detail later.

Thermal Treatment System

Toxic Emissions
Most of the chlorine in the waste stream is converted into hydrogen chloride (HCl), a strong acid gas which at high temperatures will attack most metals it meets. Most of the HCl can be removed with the alkaline scrubbing devices before the flue gases leave the stack, but not necessarily before this acid has damaged some of the materials from which the incinerator is built. Furnace linings, ductwork and boiler tubes need frequent and costly attention.

At the high temperature of combustion, the nitrogen and oxygen in the air combine to form nitric oxide (NO). Because this gas is neutral, scrubbers using alkaline chemicals such as lime cannot remove it. Systems involving the injection of ammonia or urea can convert some of the nitric oxide back into nitrogen, but these high-energy reagents are expensive and the removal of nitric oxide is only about 60% effective. Any nitric oxide that is not removed is later converted by sunlight into nitrogen dioxide, which contributes to photochemical smog and acid rain.

At the temperatures of combustion many of the toxic metals such as lead, cadmium, arsenic, mercury and chromium are released. Furthermore, they are liberated in the form of tiny particles or gases, which if they escape from the stack, vastly increase the potential surface area contact between themselves and the environment. They also penetrate deep into human beings, where they are rapidly exchanged with the bloodstream. The traditional method of removing metals from emissions is via particulate control devices such as electrostatic precipitators or fabric filters. Electrostatic precipitators, although very robust, are less efficient at removing the tiniest particles of concern. The fabric filters (baghouses) are more efficient but suffer from breakage and blockage and need careful maintenance. This pollution control equipment can remove some but not all heavy metals from stack gases. But even then the metals do not disappear; they are merely transferred from the air into the ash, which is then landfilled. Subsequently, metals in the ash may leach into and contaminate soils and potentially groundwater. Presently, in some countries ash from incinerators is sometimes being used for construction purposes such as in asphalt, cement and for making paths. Even the EIA report states that the ash would be suitable for brick making and construction. This practice can have serious implications for the environment and for human health. For instance, metals can leach out of such construction materials.

Unburned toxic chemicals

No incinerator process operates at 100% efficiency. Unburned chemicals are emitted in the stack gases of all waste incinerators. They also escape into the air as fugitive emissions during storage, handling and transport. While incinerators are designed to burn wastes, they also produce them in the form of ash and effluent from wet scrubbers and/or cooling processes. Incinerator ash carries many of the same pollutants that are emitted as stack gases. Studies have identified as many as 43 different semi-volatile organic chemicals in incinerator ash, and at least 16 organic chemicals in scrubber water from hazardous waste incinerators. Ash is commonly buried in landfill, while effluent is often treated before being discharged into rivers or lakes.

New pollutants - dioxins and furans

One of the most insidious aspects of incineration is the entirely new and highly toxic chemicals that can be formed during the combustion process. When fragments of partially burned waste chemicals recombine within incinerator furnaces, smokestacks, and/or pollution control devices, hundreds, even thousands, of new substances are created, many of which are more toxic than the original waste itself.

There has been very little research on the identification of the multitude of pollutants emitted from incinerators. One study identified 250 volatile organic compounds, many of which are known to be highly toxic or carcinogenic, but it is likely that many other compounds are emitted which have yet to be identified.

Among these are dioxins and furans (often referred to just as dioxins) a class of chemical compounds widely recognised to contain many highly toxic compounds including TCDD, a chemical which has been described as the most toxic chemical known to man. Dioxin is a dangerous chemical and a serious public health threat. No amount of additional exposure is safe. Every effort should be made to eliminate dioxin at its sources, rather than control it after it is produced.

As the section on options of disposal methods is completely biased towards promoting incineration technology without adequate and sufficient consideration given to the other alternatives, the EIA is fundamentally and seriously flawed. Hence, the selection of thermal waste treatment as the desired option is not based on sound, adequate and objective reasoning.

2. CHAPTER 5: EXISTING ENVIRONMENT- ANALYSIS INCOMPLETE

Meteorology
There is no data on the acidity of rain in the existing area. This data is important, as it has to be used as a base for comparison as emissions from incinerators consists of acid gases.

Wind
There are also problems related to buildings near to the stacks. Incinerator modeling experts often fail to consider that a downward wind can cause a number of problems with the plumes swirling around these buildings.

With this in mind, wind flow pattern should be taken in the specific area that the incinerator is to be located. The EIA report should not have relied on wind observations (flow and direction patterns) taken from the Sultan Abdul Aziz Shah Airport (Subang) or Petaling Jaya, which areas are a completely different lay of land.

These aspects reveal further shortcomings in the EIA.

3. CHAPTER 8: INADEQUATE CONSIDERATION OF IMPACTS FROM PROPOSED INCINERATOR

Actual design of incinerator unknown - Consideration of likely impacts inadequate
The actual design of the thermal waste treatment technology that is going to be built has not been finalized yet. Hence, the EIA report provides general information on the systems that are available and a general description of its features, possible impacts and mitigation measures.

Without knowing the exact design of the plant, how can a proper and detailed assessment of the impacts be carried out and consequently, how can appropriate mitigation measures be considered to be adequate? Thus, how would it be possible for the EIA study to conclude whether the proposed project is after all feasible -- economically, socially and environmentally?

Impacts During Operation Process :

Air Quality
No existing data on air emissions from a similar plant In dealing with concerns relating to incinerator emissions, the EIA report acknowledges that there are no existing actual data of emissions for thermal treatment plant of similar capacity as the proposed plant in Kg. Bohol using gasification technology. [ Chap. 8, pg 2]. Hence the EIA relies on air quality modelling and data from thermal treatment plants of much lower capacity such as between 20 ton/day, 110/per day and 240 ton/per day.

To simply rely on the data of the air quality-modeling works in determining the safety of the proposed incinerator is clearly inadequate and can be highly misleading. Models are essentially theoretical structures. Their predictions and projections are limited by laboratory conditions and a host of other constraints. Essentially, models are not able to take into account the real factors and problems that may arise in the actual setting.

On the other hand, to rely on data from incinerators with much, much lower capacity is also unreliable and can be misleading. Reference is made to a German plant in Karlsruhe, which has a capacity of 240 ton/day and which is still in the initial stage of operation.

Our investigations about this plant revelead the following:

"Badische Neueste Nachrichten", the Karlsruhe newspaper issue of 23.6.2000 reports that the Karlsruhe thermoselect plant is not running in full capacity but only 70% of the full capacity. Four weeks with 100% capacity were the test conditions for the plant. 240 tons of waste should be handled by thermoselect daily, but only 150 tons were reached. The city of Karlsruhe had to bring 100 tons waste daily to the city dump because thermoselect was not working properly.

The 28.3.2000 issue of the paper stated that the thermoselect plant in March 2000 worked only 1 of 4 weeks on full capacity. Originally, the plant had a chance to prove its performance until 31.3.2000. This, they could not do.

From the above news articles we can deduce that the gasification plant of the thermoselect type is not without flaws. However, promoters of this technology use Karlsruhe waste incinerator as an example of an efficient and good model to follow. However, this claim should be subject to further scrutiny and analysis. Hence, the EIA in alluding to such technology without disclosing the negative aspects is misleading.

The promotion of thermoselect plants were stopped in the following countries: Switzerland (1995), Poland (1996), Brazil (1996), Argentina (1996), USA (1997), Lebanon (1998), Czech Republic (1999).

These concerns have not been addressed in the EIA report.

Dioxin -- no safe dosage
The report further concluded from the air-quality modelling that the incremental increases of pollutants are within tolerable level. As mentioned earlier, this tolerable level from the model is still in theory.

It is not able to address the problems that may arise in the actual environment, one of which is admitted by the report itself namely, the high percentage of children in the area who are already susceptible to acute health problems related to air pollution.

Dioxin discharge is expected to be within the emission limit i.e. 0.1ng/Nm3. This limit is highly questionable as many experts have argued that there is no safe dosage for dioxin intake. If there is no safe dosage, we should not be assuming that there is a safe dioxin emission limit.

The "no-safe dose of dioxin" has been adopted by many experts in view of the background dioxin levels in the environment. Of particular concern is the fact that the highest doses of these potent endocrine disrupting chemicals are reaching us from our food and being delivered to the unborn foetus. Malaysia still has no information on the background levels of dioxin in the environment. Furthermore, the EIA consultants did not make any attempts to conduct studies in the locality of the proposed plant to establish the background levels of dioxin exposure. This is a major weakness of the report. Without the data on the background levels, how can we claim that additional doses can actually be harmless to the unstudied population?

According to the most recent report on dioxin by the U.S. EPA (United States Environmental Protection Agency) released in 2000, the risk of getting cancer from dioxin is today 10 times higher than reported in 1994. The EPA now considers dioxin to be carcinogenic to humans.

The EPA report also mentions that some adverse effects may already be occurring in humans at average levels of exposure. Subtle effects like impact on learning ability, thyroid and liver functions and increased susceptibility to infections have been seen in children exposed to background levels of dioxin.

By concentrating on the tolerable limit of emissions, the report also fails to adequately address the issue of dioxins as endocrine-disrupting agents which are capable of interfering with several hormonal systems, in which the hormones function in human tissues at part per trillion levels.

The EIA report on page 2 of Chapter 8 in reference to impacts on air quality refers to two technical papers contained in Appendix 8.2 and Appendix 8.3. The report states that "dioxin should not be a major problem" as a result of the construction of the thermal treatment plant. The technical papers that the report relies on do not support this statement and in fact, is contrary to the recommendations made by the papers. Dioxin is a major problem and the technical papers suggest that all efforts must be made to reduce the source of dioxin, of which incineration technology is one.

For instance, in Appendix 8.2, the technical paper by the Office of Research and Development of the US EPA in Ohio, published in 1997 recommends that environmental and public health measures must be undertaken to reduce exposure to dioxins. This conclusion is also supported by the article in Appendix 8.3.

Toxic metals - Not Specifically addressed
We also note that the report in the Air Quality section (Chapter 8) does not specifically address the problem of the release of toxic metals such as lead, cadmium, and arsenic, mercury and chromium that are liberated from the waste during combustion.

This is especially troubling considering the fact that the metals may be liberated in the form of tiny particles or even gases, which, if they escape from the stack, vastly increase the [potential surface area of contact between themselves and the environment.

Mercury - Not Sufficiently Addressed
Mercury is a particularly problematic pollutant because it is difficult to control. At the temperature of combustion it is a gas and evades simple particulate control devices. As a result, waste incineration has been a major source of mercury going into the environment. This problem is compounded further when we do not have a waste segregation system that is able to remove sources of mercury from the waste stream.

Many modern incinerators now use activated carbon to absorb the mercury. This is an expensive item and the activated carbon has to be used continuously. Several other questions that are not addressed regarding mercury removal are:

	What is the fate of the mercury captured on the activated carbon, or the fly ash residues?
	Is the spent charcoal sent for reactivation, if so where does the mercury go?
	Is the spent charcoal burned in the incinerator, in which case where does the mercury go, as it can't stay in the incinerator forever?
	How does the presence of activated carbon effect the leaching and other characteristics of ash disposed of in landfills?
	In hot climates, will mercury evaporate from the ash?

In omitting to address the above concerns, the EIA is further flawed.

Mitigation on Air Pollution -

From the above, it is clear that the EIA has not sufficiently addressed the full range of concerns and issues relating to the impacts on air quality from the proposed plant. When the full range of impacts are not adequately addressed, the mitigation measures which have been proposed would be grossly insufficient to protect public health and the environment.

The EIA states in mitigation that the proposed plant "…will be equipped with high technology equipment to facilitate the flue gas treatment". It further states that " The Malaysian Government's chosen technology, Gasification and Ash Melting System, is designed to effectively control generation of hazardous chemical compounds such as dioxin".[ Chap. 8 Pg. 5].

This system is being touted as a problem-free solution to the dioxin emissions, when there is very limited information and examples on existing gasification and ash melting system, which deal with such a large volume of waste as 1,500 tonnes/day.

The claim that the dioxin decomposition efficiency of the equipment proposed is higher than 97.5% is unsubstantiated and appears to be a bare statement. This needs further verification. The EIA report also claims that combustion control has become the principal control strategy to reduce dioxin and furan emissions. However, it admits that the measurements of dioxins and furans cannot be done on a continuous basis.

The report has flawed when it makes claims about "effective control of dioxin emissions" while ignoring that the continuos monitoring of the success of this mitigation technology has never existed anywhere in the world.

In theory, a properly designed incinerator should convert simple hydrocarbons into nothing other than carbon dioxide and water. Practical experience, however, has shown that even the best of combustion systems virtually always produce PICs (products of incomplete combustion), some of which have been found to be highly toxic. Even under the strictest of standards, "state-of-the-art" incinerators emit chemicals that have escaped combustion as well as newly-formed "products of incomplete combustion" - thousands of different chemicals of which only a small fraction have been identified.

The monitoring and measuring of incinerator performance is conducted in various ways and on various levels in different countries. Actual incinerator performance can deviate radically due to "combustion upsets" such as: equipment failure, human error and rapid changes in the waste fed to an incinerator. Only a small fraction of the total volume of waste needs to experience one of these "combustion upsets" for there to be significant deviations from the targeted destruction efficiencies.

Pollution control technologies for different pollutants are often incompatible. So scrubbers designed to filter out particulate and heavy metals, will cool the exhaust gas to the ideal range for dioxin formation. This means that decreasing the emission of one pollutant often increases the emissions of others. And no pollution control device can eliminate dioxin or heavy metal emissions completely.

This represents a major weakness of the incineration technology.

Even when the most stringent precautions are taken to minimise dioxin air emissions, it is still very difficult to maintain that emissions are low because there is no equipment available in the world to monitor dioxins and furans on a continuous basis. Instead, we have to rely on measurements made on a spot-check basis with advance notice given to the operator that they are going to be monitored on a particular day. Indeed until recently, very few incinerators in the US had been measured more than once in their whole operating lifetime. In the Netherlands, one study showed that the standard 6-hour test for dioxin emission from a modern incinerator actually underestimated dioxin emissions by a factor of 30 to 50!

The problem in Malaysia is further compounded by the fact that the DOE does not have the technology to carry out its own assessment of the emissions and has no other choice but to rely on the air monitoring data supplied by the operator of incineration plant. Furthermore the plant operator has to send samples for analysis overseas which are cost-prohibitive.

The EIA report has failed to take into account the problems related to continuous dioxin emission monitoring from incineration plants.

Furthermore, the mitigation section on air-quality also ignores the admission the report makes in Chapter 4, page 12 that the dioxin-furan precursors, aromatic structures on particulate carbons, aromatic chlorides and aromatic hydroxides are generally more resistant to thermal destruction and can recombine to form dioxins and furans in the presence of fly ash in the temperature range 200-450 degree centrigades during post-combustion process.

In the light of the above, the EIA report adopts a very over-generalized and simplistic in approach in dealing with the mitigation measures. The mitigation measures proposed are therefore unacceptable to adequately protect the public and the environment.

Solid Residuals - Callous Approach
It is stated in the EIA report that bottom ash in Netherlands is being used for dike making and in US is used for road base construction. Bottom and fly ash is mixed with hydrated lime and Portland cement to make building blocks.

We should not be making the same mistake that these countries had made. Incinerator operators would of course say that the ash produced at these plants is inert. Opponents to incineration say that the ash is far from inert and contains extremely dangerous levels of heavy metals which can leach out into the surrounding soils posing a threat to the water table and food produce.

Despite mountains of scientific evidence on the high metal content of incinerator ash, industrialists have repeatedly claimed it can be used as a hard core for road building or even in 'breeze block' type building materials.

The ash from the municipal incinerator in the Byker area of Newcastle's East End has been used on the pathways of local allotment parks and school playing fields. About 2,000 tonnes of the ash has been spread over allotments, pathways and bridle paths over the last six years. Ash from the Christon Road Allotment site in South Gosforth that was tested revealed dangerously high levels of arsenic, mercury and lead.

Mitigation on Fly Ash Disposal
The EIA states that treatment of fly ash can be carried out using technologies such as melting solidification, cement solidification, chemical treatment and stabilization by acid and other solvents. However, the report fails to elaborate the specific technology that is going to be used.

The report recommends that the fly ash from the melting furnace shall be treated and converted to reusable product. This approach is ignores the toxicity of the fly ash.

Then the report recommends that the remaining fly ash from the bag filters be disposed off to designated landfills. The justification for incinerator technology was premised on the assumption that we are running out of land space for landfills for ordinary solid waste. Here ironically the EIA calls for the creation of a designated landfill for toxic waste. However there is no reference to any proposed location for the disposal of the toxic fly ash from this incinerator.

This is yet another major omission of the EIA report.

The same issue arises in relation to the disposal of bottom ash from the plant. The report recommends that the bottom ash be disposed either in a monofill or an MSW landfill with a double liner. The ambiguity in the suggestion of the right location to dispose this toxic material is indeed a serious weakness.

Fugitive emissions
Some waste is accidentally released when chemicals are removed from storage containers at the incinerator site, moved to transportation vehicles, or being shipped to and moved about within the incineration facility. According to the US EPA: "Fugitive emissions and accidental spills may release as much or more toxic material to the environment than direct emissions from incomplete waste incineration..." There is also the risk of catastrophic waste releases in fires and explosions.

This aspect has not been sufficiently dealt with in the EIA.

4. CHAPTER 9: EFFECTS ON HUMAN HEALTH AND ENVIRONMENTAL SAFETY NOT SUFFICIENTLY APPRECIATED.

This chapter does not adequately incorporate information on the health impacts that would arise from the air emissions and ash from the incinerator plant. There is no full appreciation of the full range of effects that pollutants like dioxins can cause to the environment and public health, in the light of recent studies and reports such as the most recent EPA Report (2000) mentioned above.

Further, other studies have also shown the following impacts of incinerators on human health and the environment.

The EIA states that the major health risks from the proposed plants are mostly air pollutants from the high temperature combustion of municipal waste. The EIA also identifies dioxin as a major air-quality concern. It does state that the effects of dioxin are closely linked to the dose, exposure, frequency and duration. The EIA states that there are a limited number of epidemiological studies, which show the dose-response relationships of air pollutants.

This deficiency could have been somewhat been addressed by taking into account various studies that link incineration to adverse impacts on the environment and the human health. (See also the section under No Safe Dose mentioned above. Following are four recent studies that provide the basis for concluding that dioxin causes cancer and other health effects in humans. (Waste incinerators are one of the major sources of dioxin emissions.)

	The first is a study conducted by the National Institute for Occupational Safety and Health, US. In this study, 5,172 workers at twelve plants in the United States, all of which produced chemicals contaminated with dioxin were tracked for over twenty years. Men exposed for over one year had a 50% increase in stomach cancer, lung cancer, non-Hodgkin's lymphoma, Hodgkin's disease, and cancer of soft and connective tissues (soft tissue sarcoma). The relative risk for these cancers was 1.46, with a 95% range of 1.2 to 1.8. The largest relative risk was 9.2 (95% range 1.9 and 27.0) for connective and soft tissue cancers. This is more than nine times the expected cancer rate. The excess lung cancers could not be explained by excess cigarette smoking, as other smoking-related deaths did not increase.
	The second critical study is a study of German workers. This study examined 1,583 workers employed in a BASF plant that produced herbicides contaminated with dioxin. These workers were found to have an increased risk for all cancers, which increased the duration and intensity of exposure. Exposure levels were determined by measuring the dioxin in the worker's fat tissue. The least exposed workers, who were exposed for fewer than twenty years had a relative risk for all cancers of 1.1 (confidence range 0.8 to 1.4). The highest exposed workers, who were exposed for over twenty years, had a relative risk of 2.6 (confidence range 1.2 to 4.9). Lung cancers were elevated in these workers. A modest number of female workers was included in the study. However only 7% of the women worked in high exposure departments. There was an increased incidence of breast cancer among the female workers. [Zober,A., Messerer,P., and Huber,P. (1990) "Thirty-four-year mortality follow-up of BASF employees exposed to 2,3,7,8-TCDD after the 1953 accident." International Archives of Occupational and Environmental Health 62:139-57.]
	Another German study examined 247 workers who were employed at a chemical manufacturing facility that produced 2,4,5-trichlorophenol contaminated with dioxin. This study found that workers with the highest exposure, as measured by an employment tenure of twenty years or more, had twice as much chance of getting cancer as people who didn't work in the plant. The relative risk for lung cancer was elevated. The study also showed the highest cancer risks for the people with the highest exposures. [Manz,A., Berger,J., Dwyer,J.H., Flesch-Janys,D., Nagel,S., and Waltsgott,H. (1991) "Cancer mortality among workers in a chemical plant contaminated with dioxin." Lancet 338:959-64]
	The most recent EPA report from the US that we have mentioned above which concludes that cancer incidences from dioxin exposures have been underestimated by the factor of 10.

Other studies have also pointed out the following information:

	The British Journal of Cancer reported that people living within 4.6 miles of municipal waste incinerators have an increased likelihood of developing cancers.
	Increased cancer rates, respiratory ailments, reproductive abnormalities and other health effects have been noted among people living near some waste-burning facilities, according to scientific studies, surveys by community groups and local physicians
	Cancer, birth defects, reproductive dysfunction, neurological damage and other health effects are also known to occur at very low exposures to many of the metals, organochlorines and other pollutants released by waste-burning facilities.
	Many pollutants released in incinerator air emissions have been shown to accumulate in and on food crops, especially crops where the edible portion is exposed such as leafy vegetables. While thorough washing of produce may remove a portion of pollutants on crop surfaces, a significant amount (typically from 15% to 50%) will remain.

The main route of exposure to dioxins in humans is through food intake. Once in the body they are only excreted very slowly and build up in fatty tissues. Studies suggest that people in the U.S. and some European countries now carry dioxins and furans that are at or near those levels which are suspected to cause health effects in humans.

In addition, the EIA refers to methods used to characterise health risks [ chapter 9, pg 3] - viz. The Direct Method ( referring to available local and foreign epidemiological studies ) and the Indirect Method ( referring to mathemetical modelling). In relation to the former method, as we have already pointed out above, the EIA has not made references to all the studies and information that we have stated. The failure of not taking into account the above studies and information has underestimated the environmental and health risks associated with incineration.

Further, it is impossible to talk about "health risk characterization" when there is virtually no information available on background levels of the concerned pollutant in the affected population.

Moreover, in addressing the problem of cancers in the population in the area, the EIA has failed to document and assess the cancer incidences in the population who live in the vicinity of the proposed plant. This is a major weakness in the EIA report, given the fact that dioxins are well known human carcinogens.

Such baseline data is important to assess the risks the population is already subjected too.

The EIA in reference to chronic health risks including cancers, relies on mathematical calculations based on inhalation rates for various sub-populations and types of daily activities recommended by the U.S.EPA in 1997. No reference is made to the EPA report released this year. In fact, reliance is placed on the EPA's previous Reference Dose (RfD).

It is our understanding that following the latest EPA Report, the agency is no longer recommending the derivation of a Reference Dose for dioxin and related compounds because setting a RfD is likely to be 100 to 1000 times below current background intakes and body burdens. Hence, calculations which are not based on the latest findings are unreliable to suggest acceptable levels of exposure. In any event, we are not convinced that there are threshold levels for dioxin levels.

In the circumstances, the mitigation measures proposed are inadequate. This is furhter compounded by the fact that there can be no continuous monitoring for dioxin exposures. As has been pointed out earlier, even in the most stringent monitoring procedures, dioxin emissions cannot be measured accurately.

6. CHAPTER 13: ENVIRONMENTAL MONITORING PROGRAMME GROSSLY INADEQUATE

The report recommends continuous monitoring of pollutants and noise from the plant. As has been stressed several times, no continuous monitoring of dioxin is possible. Even when the most stringent precautions are taken to minimize dioxin air emissions, it is still very difficult to convince the public that the emissions are low because there is no equipment available for monitoring of dioxins and furans on a continuous basis.

7. OTHER ISSUES

Air pollution control systems -Electrostatic precipitator The electrostatic precipitator, an air pollution control device which removes dust particles from stack gasses operates at the temperature range perfect for dioxin formation. Ironically, solid waste incinerators with electrostatic precipitators for air pollution control are the greatest individual source of dioxin emissions.

Waste Characteristics: Composition and Calorific Value

Municipal waste in Malaysia which has high moisture content is not ideal for economical incineration. Current industry norms recommend an energy value of 1,800 Kcal.kg-1. Even after 10% dewatering the energy values of waste samples from PJ, KL and Shah Alam reported by the supporting study for this EIA are 1,344, 1,290 and 1,154 Kcal.kg-1 respectively. This is too low and thus would require supplementary fuel - an additional running cost, to maintain the burn.

In the light of the data above, it is unlikely that the incinerator will be able to generate significant electricity as the report propagates.

Environmental Standard

At present, there is no specific standard on the emission of municipal solid waste thermal treatment plant. There are no standards for dioxin and furan emission limits under the Environmental Quality (Clean Air) Regulations 1978. The DOE does follow the guideline of 0.1ng/Nm3.

Besides these inadequacies, there is no laboratory in Malaysia that has the facilities to test dioxin level in samples. Currently medical waste incinerator operators send the samples overseas and testing for each sample is costly amounting to RM10, 000.

Hence, these issues are serious concerns in relation to monitoring and enforcement of conditions relating to the proposed plant.

8. CONCLUSION

Given the above comments, it is our view that the EIA report is flawed in many aspects, misleading on several counts, incomplete and grossly inadequate in assessing all the adverse impacts that the proposed incinerator plant is likely to cause. Consequently, the mitigation measures proposed are gravely deficient and not protective of the environment and human health.

In the circumstances, CAP and SAM urge the Department of Environment to reject this EIA. We further urge the Ministry of Housing and Local Government not to proceed with the proposed incinerator, but instead undertake comprehensive efforts in adopting cheaper and more sustainable waste management strategies.

S.M.Mohd. Idris
President of Consumers' Association of Penang
and Sahabat Alam Malaysia.