Written by Robin Mann, Southeastern PA Group Volunteer
In October, 2021, the Sierra Club, along with the Clean Air Council, the Environmental Integrity Project and the Clean Air Task Force submitted written comments to the PA DEP on the proposed renewal of the Title V Permit No. 23-00004 for the Covanta Delaware Valley, L.P. waste incineration facility in Chester, Pennsylvania.
The Covanta Delaware Valley waste incinerator is an outdated facility, in terms of its pollution control technology as well as its methodology for waste management. The facility was built 30 years ago; it lacks modern pollution controls and emits more hazardous air pollutants than plants meeting currently available technology-based limits. More fundamentally, the plant's operation is profoundly at odds with widely recognized sustainability principles for waste management, aiming towards full life-cycle and closed loop materials use systems with minimal destructive disposal through burning.
Sierra Club policy embraces the goal of transitioning to “zero waste” as the necessary, comprehensive response, and adopts the internationally recognized definition of Zero Waste:
“the conservation of all resources by means of responsible production, consumption, reuse, and recovery of products, packaging, and materials without burning, and with no discharges to land, water, or air that threaten the environment or human health.”
In alignment with the Zero Waste approach, the Sierra Club opposes incineration as a form of destructive disposal that prevents substantial recovery of materials and emits greenhouse and toxic pollutants.
The Covanta Delaware Valley incinerator essentially converts one waste stream into multiple other ones that are more toxic. As the Operating Permit Renewal Review (August 2021) indicates, the facility is limited to burn Municipal Solid Waste and up to 10%, or 500 tons per day, of residual waste (including hazardous material from industrial sources). The significant volume residual waste the company accepts from non-municipal sources results in generation of more hazardous waste, in both air emissions and ash, than would be generated by a Municipal Solid Waste-only incinerator. It should also be noted that diverting what is unacceptable or unapproved and hazardous material from the waste to be incinerated (including such material as automotive batteries) relies on visible identification and removal from the tipping room floor [See Sec. E, VI. #020 Operating Permit Terms and Conditions]. Has the Department conducted any investigation into the amount of unacceptable waste that, in fact, goes unidentified and is incinerated? Is the Department requiring any additional measures by Covanta Delaware Valley to intercept unacceptable, toxic materials, beyond removal of what gets noticed? Are pollution limits potentially exceeded by what gets missed?
In addition, the plant produces approximately 30% by volume of the original waste stream as toxic fly ash and bottom ash, which must be landfilled. Under the circumstances, while the steam by-product of the incineration is used to produce electricity, it is a mischaracterization to suggest that clean electricity is generated.
Sierra Club is especially concerned about the impacts of Covanta Delaware Valley and its operations on the public health and wellbeing of the community of Chester. While we do not support the operation of municipal waste incinerators in any community, we especially oppose continued operation of this plant in the oppressively pollution burdened, Environmental Justice community of Chester. The health and quality of life of the majority Black residents of Chester are harmed by hazardous air emissions from multiple, major industrial polluters located in the city. And while all of Delaware and Philadelphia Counties are in non-attainment of the federal Clean Air Act standard for ground-level ozone, ozone pollution is of particular concern in Chester, where asthma and other cardio-pulmonary diseases are prevalent and high levels of poverty contribute to ill health.
Against this backdrop, the Department is proposing to renew the Title V permit for Covanta Delaware Valley even though Nitrous Oxide (NOx) emissions from the plant are, actually, increasing. As indicated in the Department's Operating Permit Renewal Review, emissions of NOx increased from 1,030.6 tons/yr in 2019 to 1,167.9 tons/yr in 2020. That the exceedance of ground-level pollution levels in Chester is associated with the cumulative emissions from multiple plants seems a very poor justification to simply give an individual polluting facility a pass, especially one whose emissions are on the rise.
The proposed permit also utterly fails to consider the significant, additional emissions from the heavy, round trip traffic of diesel-powered, waste-hauling trucks serving the plant. These additional emissions contribute to the overall pollution burden on the community from Covanta's operations even if the Department is choosing to ignore them.
In sum, by renewing this permit, the Department would be betraying its obligations to safeguard the health of Chester residents, both by failing to uphold its official commitment to pursuing environmental justice, and by setting aside its mandated obligation to ensure all communities are brought into attainment with air quality standards.
Finally, Sierra Club objects to the renewal of Covanta Delaware Valley's air permit as contrary to Pennsylvania's commitment to reduce its emissions of greenhouse gases, e.g., through the Pennsylvania Climate Action Plan 2021. The plant generates 87MW of electricity from steam produced by the incineration process, power that Pennsylvanians don't need. Pennsylvania exports roughly a third of the electricity generated in the state. Meanwhile, as the Department recognizes in its review, the facility is a "major stationary source for Greenhouse Gas Emissions." While represented as such in company promotional material, Covanta is not a climate solution. Its continued operation should not be justified on that basis.
We urge the Department not to renew the Title V permit for Covanta Delaware Valley, L.P.
Related article - “Trash to Steam” Equals Trash to Ill Health, June, 2021, Sue Edwards