Sacrifice Zones Are Not Acceptable
Conservation Campaigner for the Sierra Club of Canada
As Conservation Campaigner for the Sierra Club of Canada, I am concerned about the Bennett incinerator proposed for Belledune, New Brunswick.
I have been concerned about toxics issues for many years living in Sydney, Nova Scotia where incineration of PCB contaminated coal tars is being considered. Incineration of toxic waste is an unacceptable solution to dealing with toxic waste.
As well as the CO2, SO2, NOx and heavy metals that are given off when these materials are burned, dioxins and furans (extremely toxic compounds) are released into the atmosphere everywhere chlorinated wastes are incinerated .
Much of the concern about toxic waste incineration is the threat of blowouts or upsets. During power interruptions or mechanical malfunctions, the emergency vent stack on the incinerator opens, flushing the contaminants into the surrounding atmosphere .
The two licensed facilities in Canada (Swan Hills, Alberta  and St-Ambroise, Quebec ) designed to burn these wastes have both contaminated the surrounding soils and or wildlife. Both of these incinerators were supposed to completely destroy the contaminants without these emissions.
There is no incinerator anywhere in the world that has successfully burned hazardous waste. In recognition of this fact both the US and Australia  have investigated safe alternatives to incineration. Both have concluded that one of the few technologies that is effective and commercially available is a Canadian technology from PLI Eco Logic called hydrogen reduction. This reduction process is coupled with a thermal desorption technology that first concentrates the waste or removes it from its matrix. In the absence of oxygen, hydrogen reduces the toxins to methane gas and salty water. Eco Logics web page is www.eco-logic-intl.com.
Eco Logics Stationary Unit, Australia
The Sierra Club of Canada has three criteria for the safe destruction of hazardous waste: 1. It must completely destroy the waste 2. The residues must be contained 3. There must be no emissions from the process
Hydrogen reduction meets these criteria. It is a closed loop system, which means virtually zero emissions from the process.
An excellent primer on alternatives to incineration and effective community action is Learning Not to Burn, A primer for citizens on alternatives to burning hazardous waste (pdf format) by Elizabeth Crowe, Chemical Weapons Working Group / Mike Schade, Citizens Environmental Coalition, June 2002.
Incineration of waste guarantees the environment surrounding the site will be contaminated. Promises of safe, effective, well regulated burning are meaningless and only placate a community long enough to victimize them. Dr. Neil Carman, a former incinerator inspector in the state of Texas, disputes the reliability of test burns to determine the amount of toxins being released into the air. He says the hype about DRE (or destruction removal efficiency) is meaningless. According to Carman, the DRE only measures the stack emissions under ideal conditions for three 6-hour burns. What is not measured are dioxin by-products, or PCBs that end up in the fly ash, or the residual toxins which continue to accumulate in the stack after the test burn.
Incinerator permits are filled with loopholes, says Dr Carman. I havent seen an incinerator that didnt cause some kind of problem in the community. It is essential to say NO to hazardous waste burning because safe and effective alternatives exist.
You can find more information on incineration at our local Sierra Club of Canada web site www.safecleanup.com
 Growing Storm Over Bennett PCB Plan by Brit Griffin, HighGrader Magazine, Spring 2002
In early April, 34 doctors, representing nearly the entire medical community of Temiskaming, released a warning about the potential health effects of burning PCBs, dioxins and furans at the proposed incinerator.
PCBs, dioxins and furans, and heavy metals are harmful to fetuses, babies and children, leading to abortion, genetic malformations, cancers and mental and behavioral problems,
 Accident Reports Contradict EA Claims on Bennett Incinerator
Toronto At a press conference held at Queens Park today, NDP Environment Critic Marilyn Churley released a series of damning documents about the controversial Bennett incinerator. The reports, dating from October 2001 to March 2002, list a series of accidental releases at Bennetts existing incinerator in St. Ambroise, Quebec. In each incident, toxins were blown out into the surrounding environment through the opening of the emergency release stack. The reports contradict claims being made by the company in their draft EA submission to Ontarios Ministry of Environment.
Marilyn Churley was joined in this press conference by Terry Graves of Public Concern Temiskaming. He points out that under the scoped EA process, the MOE is unlikely to even look at Bennetts track record. The EA relies entirely on studies supplied by company-paid consultants.
We have documents that reveal a pattern of upsets and blow outs at the existing Bennett incinerator, says Graves. They contradict the claims being made by the Bennett EA submission. No wonder the MOE doesnt want to hold full or public hearings. If the MOE dealt with the hard evidence of Bennetts track record, theres no way the incinerator would ever be licensed in Ontario.
Bennett has claimed in its EA submission that if there were any accidental releases of toxins through emergency stack, the stack would not be left open for more than a minute. Documents, however, show a series of accidents where toxins were being released for anywhere from two to 14 minutes. The causes of these incidents ranged from human error to mechanical breakdowns.
Graves says even one blow out, let alone a series of blow outs, as suggested by these reports, poses serious health concerns.
The Bennett incinerator is going to be built near two grade schools and a day care, says Graves. It will be burning extremely dangerous toxins such as dioxin. There is no safe level for exposure to these toxins.
Public Concern Temiskaming is calling on the MOE to undertake a full and independent audit of Bennetts existing incinerator at St. Ambroise. In addition, they want the Province to force the company to disclose any and all accident reports and upset incidents that have occurred at the plant over the last five years.
 Wild Game and Fish Health Advisory (Swan Hills Area)
As a result of an air emissions release containing PCBs, dioxins and furans at the Swan Hills Waste Treatment Centre on October 16, 1996, a wild game and fish public health advisory has been issued for the consumption of game and fish taken from the Swan Hills area. While no immediate public health threat exists for those who eat wild game or fish from the area, it is recommended that consumption of these foods be limited (and in some cases avoided) as regular consumption over an extended period of time could be harmful.
 Invasion of the Process Snatchers. Will Tory EA sink farmers over toxic incinerator plan? By Brit Griffin, HighGrader Magazine, Summer 2002
In one six-month period last winter (2001), the St. Ambroise incinerator suffered at least seven upsets. And unlike Bennetts claim of being able to limit the occurrences to a maximum of 60 seconds, the upsets ranged in duration from three minutes to a whopping 14 minutes. These accident reports completely contradict the claims being made in the Bennett EA submission, says Terry Graves of Public Concern Temiskaming. No wonder the MOE doesnt want to hold full hearings. If the MOE dealt with the hard evidence of Bennetts track record, theres no way this incinerator would be licensed in Ontario. Graves charges that the MOE is actively prejudicing the process by intervening to limit the use of the accident reports in any serious scrutiny of Bennetts EA claims.
. Excerpt from Impediments in the Establishment of Scheduled Waste Treatment Facilities in Australia
In Australia, proposals to implement high temperature incineration facilities have failed at the community consultation step, even in cases where the regulatory bodies had agreed that the proposal was consistent with their normal approval requirements for industrial facilities, and would not pose an unacceptable risk. This has extended to facilities which have been proposed in extremely remote areas. This has led to an effective outlawing of the incineration of scheduled wastes in Australia .
Community consultation has been less of a concern with regard to the non-incineration scheduled waste treatment processes (such as Eco Logic and BCD). This appears to be a result of several factors: the facilities pose a lesser risk because they are smaller and the process is more contained; the key stakeholders have not formed a strong policy position against these processes; and the companies involved have learnt to negotiate their way through the consultation process.
While a detailed discussion of approaches to the management of community consultation processes is beyond the scope of this report, based on experience with the implementation of scheduled waste treatment facilities, some of the factors affecting the success of such programs would appear to include:
- consultation with the national environmental groups (and other interested parties) in order to obtain an in principle acceptance of the proposed technology (minimizing the extent to which process considerations are confused with site-specific considerations);
- selection of an appropriate location for treatment facilities, which will be supported by the relevant authorities.
- established, regular communication with the local community on relevant issues (e.g. ongoing community/industry consultation groups);
- allocation of sufficient time to the community consultation process, rather than attempting to compress the consultation process.
CMPS&F [environmental consulting firm] concludes that community consultation is a critical aspect of the establishment of scheduled waste treatment facilities in Australia. With non-high temperature incineration processes, it appears that community consultation will not result in insurmountable obstacles and, in itself, is not sufficient to preclude investment by companies that propose to install a treatment facility. In the case of high temperature incineration, community opinion is likely to continue to preclude the establishment of a facility.
From: CMPS&F Environment Australia . 1997. Appropriate Technologies for the Treatment of Hazardous Wastes. Section 20.4
Il nest pas acceptable de sacrifier des zones
Lincinération de déchets toxiques nest pas une façon acceptable de soccuper des déchets dangereux.
Il nexiste aucun incinérateur au monde qui a réussi avec succès à se défaire de déchets dangereux. Il est assuré que lincinération de déchets contaminera lenvironnement dans la région de lincinérateur.
Le Club Sierra du Canada a établit trois critères pour la destruction sécuritaire des déchets dangereux:
1. La destruction doit détruire complètement les déchets;
2. Les résidus doivent être confinés;
3. Le processus doit se faire sans émissions.
Le processus de réduction à lhydrogène rencontre ces critères. Cest un processus en circuit fermé, ce qui virtuellement entraîne aucune émission. Effectivement, il existe des alternatives à lincinération!
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