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[greenyes] GAIA's comments regarding incineration as renewable energy


Dear all, below are comments from GAIA to the Green-e program, please feel
free to use any of this information in your own comments or in the future.



Regards, Monica Wilson

----------------------



Thank you very much for the opportunity to submit comments during the Second
Comment Period of the Green-e National Certification Standard process. In
response to your request for comments, we urge Green-e to continue to
exclude municipal solid waste incineration (including gasification and
combustion) from the definition of eligible renewables, as currently stated
in part III section A of the National Certification Standard.



GAIA welcomes the opportunity to provide information to Green-e and other
interested parties about municipal solid waste (MSW) combustion and
gasification. GAIA recognizes that combustion and gasification are forms of
incineration. Waste gasification frequently includes the combustion of gases
in order to generate energy. Waste gasification and the related technologies
of waste pyrolysis and plasma share other characteristics with more
traditional forms of incineration such as mass burn combustion and
refuse-derived fuel (RDF). These shared characteristics include:

* Threat to public health and the environment from air emissions
including dioxins, heavy metals, carbon dioxide, particulates and hazardous
air pollutants
* Solid residues that may contaminate ground water
* Contaminated liquid byproducts
* Economic burden to local community
* Waste of embodied energy in the discarded materials
* Encouraging continued waste generation, rather than recycling and
waste prevention which conserve energy.

Energy conservation through recycling and waste prevention

Recycling most materials saves three to five times the amount of energy as
incinerating these same materials would generate (some materials, like
aluminum and paper save much more energy). <outbind://38/#_edn1> [i] For
every ton of material destroyed by waste incineration, many more tons of raw
materials must be mined, extracted, processed, and distributed to
manufacture new products to take its place.



The U.S. Environmental Protection Agency recently studied the energy impacts
of various municipal waste disposal options and concluded that recycling
saves more energy than incineration with energy recovery. The study
determined that current recycling levels, compared to landfilling/combustion
disposal, conserve an equivalent of approximately 11.9 billion gallons of
gasoline. <outbind://38/#_edn2> [ii] Recycling should be encouraged to grow,
not face increased competition with more disposal technologies like
gasification.



A recent article in the International Journal of Life Cycle Analysis
concluded that "recycling is environmentally preferable to disposal [WTE
incineration and landfilling] by a substantial margin." Public health and
environmental benefits of recycling over incineration and landfilling
include reduced impacts on global warming, acidification, human health
effects, and human and ecological toxicity. <outbind://38/#_edn3> [iii]



Concerns about Waste Incineration

Although the volume of garbage appears to be greatly reduced by gasification
and incineration, no technology can make anything actually disappear. Mass
can neither be created nor destroyed, only changed. <outbind://38/#_edn4>
[iv] The gas, smoke, and liquid and solid wastes that leave a facility will
have the same mass as the solid materials entering the facility. Masses of
gas and particulates will go up the stack, toxic ashes and solid wastes will
need to go to landfill, and liquid wastes will also need to be managed.



Incinerators are an obsolete and unsustainable method of dealing with
municipal discards. Problems with waste incineration include releases of
hazardous pollutants, creation of toxic ash and liquid residues, high
economic costs, energy loss, and incompatibility with other waste approaches
such as waste prevention, reuse and recycling. <outbind://38/#_edn5> [v]



Mass burn waste incinerators create and release an unknown number of toxic
chemicals. Below is a list of chemicals detected in air emissions from
municipal waste incinerators. Dioxin is so hazardous that no emissions are
acceptable. The U.S. has signed the Stockholm Convention on Persistent
Organic Pollutants (POPs) which targets four incinerator byproducts
(dioxins, furans, polychlorinated biphenyls and hexachlorobenzene) for
reduction with the goal of elimination. This convention provides a mandate
for moving towards long term sustainable approaches, not more incinerators.



Concerns about Staff Recommendation for Item 1: Waste Gasification

Waste gasification can not meet the standards included in the Green-e staff
recommendation. A similar definition for waste gasification is used in a
2002 California law called AB 2770. This law also required the California
Integrated Waste Management Board (CIWMB) to study gasification and
pyrolysis and some related technologies for handling municipal solid waste.
On page six of the CIWMB's draft "Conversion Technology Report to the
Legislature," the report states:

"Air emissions from thermochemical [gasification and pyrolysis] and
biochemical systems include such things as NOx, SOx, hydrocarbons, carbon
monoxide, particulate matter (PM), heavy metals, green house gas emissions
such as methane and CO2, and dioxins/furans." <outbind://38/#_edn6> [vi]

This demonstrates that the definition of gasification given in the staff
recommendation is simply not achievable.



Gasification and pyrolysis, and the related technology of plasma, not only
create and release hazardous air pollutants, these technologies also produce
discharges to surface and groundwater. Liquid residues are a byproduct of
the waste gasification process and may be highly toxic.
<outbind://38/#_edn7> [vii] Contaminated water is also a byproduct of air
pollution control devices such as wet scrubbers, commonly used in combustion
systems.



Although some gasification, pyrolysis and plasma vendors frequently claim to
be non-combustion processes, these companies are misleadingly referring only
to the first of their two stage process. Gasification is two-stage
incineration:

* The first stage of a gasification process is heating waste to create
gas, oil, liquid residues and solid residues.
* In the second stage of gasification, gas created during the first
stage is combusted.

During both stages, dioxins and other harmful chemicals are created. Recent
emissions monitoring of a test MSW pyrolysis facility in California showed
higher dioxin and particulates emissions than from two MSW incinerators in
the region. <outbind://38/#_edn8> [viii]



Finally, unlike the description given in the staff recommendation, none of
these technologies inherently remove recyclable materials prior to
processing. Just as with any other waste facility, a facility could choose
to remove recyclables before being treated in an incinerator or sent to a
landfill. However, such a system is different from removal being inherent in
the gasification process. Indeed, the highest calorific value is found in
organic materials such as paper and food waste (which are recyclable and
compostable) and plastic, thus placing a gasification facility in direct
competition with recycling and composting for these discarded materials. It
is a mistake to assume that a facility would separate out these materials
for recycling when it has a conflict of interest in the use of the
materials. Furthermore, "put or pay" contracts, which incinerators often
require, undermine waste prevention efforts by requiring a constant supply
of garbage.



I look forward to working with Green-e in the future. Please do not hesitate
to contact me if you have any questions about these technologies.




_____

<outbind://38/#_ednref1> [i] US EPA. Waste Management and Energy Savings:
Benefits by the Numbers. September 2005. www.epa.gov/mswclimate

<outbind://38/#_ednref2> [ii] US EPA. 2005.

<outbind://38/#_ednref3> [iii] Morris, Jeffrey. "Comparative LCAs for
Curbside Recycling Versus Either Landfilling or Incineration with Energy
Recovery." International Journal of Life Cycle Assessment 10 (4), 2005, p.
273-284.

<outbind://38/#_ednref4> [iv] Encyclopedia Britannica,
www.britannica.com/eb/article?tocld=49377

<outbind://38/#_ednref5> [v] Waste Incineration: A Dying Technology. GAIA.
2003. Available at www.no-burn.org

<outbind://38/#_ednref6> [vi] California Integrated Waste Management Board,
"Conversion Technologies Report to the Legislature," May 2005. Available at
www.ciwmb.ca.gov

<outbind://38/#_ednref7> [vii] IEA CADDET, Advanced Thermal Conversion
Technologies for Energy from Solid Waste, August 1998. Available at
www.caddet-re.org

<outbind://38/#_ednref8> [viii] South Coast Air Quality Management District
presentation to the California Integrated Waste Management Board, September
20, 2005. http://www.ciwmb.ca.gov/agendas/mtgdocs/2005/09/00019545.ppt







Partial list of air emissions from municipal solid waste incinerators


pentane

trichlorofluoromethane

acetonitrile

acetone

iodomethane

dichloromethane

2-methyl-2-propanol

2-methylpentane

chloroform

ethyl acetate

2,2-dimethyl-3-pentanol

cyclohexane

benzene

2-methylhexane

3-methylhexane

1,3-dimethylcyclopentane

1,2-dimethylcyclopentane

trichloroethene

heptane

methylcyclohexane

ethylcyclopentane

2-hexanone

toluene

1,2-dimethylcyclohexane

2-methylpropyl acetate

3-methyleneheptane

paraldehyde

octane

tetrachloroethylene

butanoic acid ethyl ester

butyl acetate

ethylcyclohexane

2-methyloctane

dimethyldioxane

2-furanecarboxaldehyde

chlorobenzene

methyl hexanol

trimethylcyclohexane

ethyl

benzene

formic acid

xylene

acetic acid

aliphatic carbonyl

ethylmethylcyclohexane

2-heptanone

2-butoxyethanol

nonane

isopropyl benzene

propylcyclohexane

dimethyloctane

pentanecarboxylic acid

propyl benzene

benzaldehyde

5-methyl-2-furane carboxaldehyde

1-ethyl-2-methylbenzene

1,3,5-trimethylbenzene

trimethylbenzene

benzonitrile

methylpropylcyclohexane

2-chlorophenol

1,2,4-trimethylbenzene

phenol

1,3-dichlorobenzene

1,4-dichlorobenzene

decane

hexanecarboxylic acid

1-ethyl-4-methylbenzene

2-methylisopropylbenzene

benzyl alcohol

trimethylbenzene

1-methyl-3-propylbenzene

2-ethyl-1,4-dimethylbenzene

2-methylbenzaldehyde

1-methyl-2-propylbenzene

methyl decane

4-methylbenzaldehyde

1-ethyl-3,5-dimethylbenzene

1-methyl-(1-pro-penyl)benzene

bromochlorobenzene

4-methylphenol

benzoic acid methyl ester

2-chloro-6-methylphenol

ethyldimethylbenzene

undecane

heptanecarboxylic acid

1-(chloromethyl)-4-methylbenzene

1,3-diethylbenzene

1,2,3-trichlorobenzene

4-methylbenzyl

alcohol

ethylhex anoic acid

ethyl benzaldehyde

2,4-dichlorophenol

1,2,4-trichlorobenzene

naphthalene

cyclopentasiloxanedecamethyl

methyl acetophenone

ethanol-1-(2-butoxyethoxy)

4-chlorophenol

benzothiazole

benzoic acid

octanoic acid

2-bromo-4-chlorophenol

1,2,5-trichlorobenzene

dodecane

bromochlorophenol

2,4-dichloro-6-methylphenol

dichloromethylphenol

hydroxybenzonitrile

tetrachlorobenzene

methylbenzoic acid

trichlorophenol

2-(hydroxymethyl) benzoic acid

2-ethylnaphthalene-1,2,3,4-tetrahydro 2,4,6-trichlorophenol

4-ethylacetophenone

2,3,5-trichlorophenol

4-chlorobenzoic acid

2,3,4-trichlorophenol

1,2,3,5-tetrachlorobenzene

1,1'biphenyl (2-ethenyl-naphthalene)

3,4,5-trichlorophenol

chlorobenzoic acid

2-hydroxy-3,5-dichlorobenzaldehyde

2-methylbiphenyl

2-nitrostyrene(2-nitroethenylbenzene)

decanecarboxylic acid

hydroxymethoxybenzaldehyde

hydroxychloroacetophenone

ethylbenzoic acid

2,6-dichloro-4-nitrophenol

sulphonic acid

m.w. 192

4-bromo-2,5-dichlorophenol

2-ethylbiphenyl

bromodichlorophenol

1(3H)-isobenzofuranone-5-methyl

dimethylphthalate

2,6-di-tertiary-butyl-p-benzoquinone

3,4,6-trichloro-1-methyl-phenol

2-tertiary-butyl-4-methoxyphenol

2,2'-dimethylbiphenyl

2,3'-dimethylbiphenyl

pentachlorobenzene

bibenzyl

2,4'-dimethylbiphenyl

1-methyl-2-phenylmethylbenzene

benzoic acid phenyl ester

2,3,4,6-tetrachlorophenol

tetrachlorobenzofurane

fluorene

phthalic ester

dodecanecarboxylic acid

3,3'-dimethylbiphenyl

3,4'-dimethylbiphenyl

hexadecane

benzophenone

tridecanoic acid

hexachlorobenzene

heptadecane

fluorenone

dibenzothiophene

pentachlorophenol

sulphonic acid m.w. 224

phenanthrene

tetradecanecarboxylic acid

octadecane

phthelic ester

tetradecanoic acid isopropyl ester

caffeine

12-methyltetradeca-carboxylic acid

pentadecacarboxylic acid

methylphenanthrene

nonedecane

9-hexadecene carboxylic acid

anthraquinone

dibutylphthalate

hexadecanoic acid

eicosane

methylhexadecanoic acid

fluoroanthene

pentachlorobiphenyl

heptadecanecarboxylic acid

octadecadienal

pentachlorobiphenyl

aliphatic amide

octadecanecarboxylic acid

hexadecane amide

docosane

hexachlorobiphenyl

benzylbutylphthalate

aliphatic amide

diisooctylphthalate

hexadecanoic acid hexadecyl ester

cholesterol



Source: Jay,K. and Stieglitz, L. "Identification and Quantification of
Volatile Organic Compounds in Emissions of Waste Incineration Plants,"
Chemosphere, vol. 30, no. 7, Pp 1249-1260, 1995.





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