Waste Strategy for England 2007 – Environment, Food and Rural Affairs Committee

Prompted by a news item on Sky which mentioned Dioxins produced by incinerators here is an article I wrote which was perhaps a tad prophetic especially concerning very small particles.

Many of the hyperlinks probably no longer work

Memorandum submitted by Dr Alan Taylor (Waste 33)

Yesterday’s Solution.

Executive Summary

Municipal Solid Waste-Energy from Waste Incinerators are an outdated technology that acts in direct opposition to the basic intent of the Stockholm Convention on Persistent Organic Pollutants because, they generate these. Alternative technologies such as plasma gasification now exist and the technology cycle for the development of these is now approaching maturity, perhaps providing a safer more local and hence lower transport burden solution. The in-situ monitoring of waste treatment and its pollution lags behind the technological need. Implementation is nearly always retrospective and stimulated by external legislation. This situation represents a commercial opportunity for the UK to provide a lead.  Should central government invest in research into, the development and commercialisation of high quality monitoring technology, then a business opportunity exists. Rather than looking to European technology providers central government could learn from the novel treatment methods currently being developed in the USA and Japan, by commissioning full scale plasma gasification plants. The lessons learned here would enable the UK to compete as a supplier in the international market place for waste management technologies rather than being a consumer.

The current climate represents an opportunity for the UK to provide a lead through, for once, legislating ahead of the EU. In the learning process of this it could create a long term commercial advantage.

Yesterday’s Solution

1.0 Background

In response to Buckinghamshire County Council’s waste strategy consultation a local campaign group was formed; the Aylesbury Chilterns Resistance to Incinerator Development (ACRID). A grouping of local individuals came together to raise local awareness of the implication of municipal solid waste-energy from waste incinerators (MSF-EfWI) and the citing of such a reactor in the beautiful Aylesbury Vale. Local people revisited the published literature on EfW and EfWI in particular. This submission is as a result of this research and addresses items 1, 2 and 9 of the Terms of Reference for the Environment, Food and Rural Affairs Committee examination of the DEFRA Waste Strategy for England document May 2007.

The author, Dr Alan Taylor is a former Senior Lecturer in Physical Chemistry at Imperial College and a founder of the high technology laser company Powerlase Ltd.

This submission is written on behalf of ACRID in his capacity as head of technology investigations for the ACRID committee and does not represent the views of either Imperial College or Powerlase ltd.

The committee’s attention is drawn to the following quotations:

The Stockholm Convention on Persistent Organic Pollutants. [1]

Article 1


“Mindful of the precautionary approach set forth in Principle 15 of the Rio Declaration on Environment and Development, the objective of this Convention is to protect human health and the environment from persistent organic pollutants.”

Baseline Scenarios for the Clean Air for Europe (CAFE) Programme.

Final Report (2005) [2]

“New Studies show that exposure to small particles (below a diameter of 2.5mm, PM2.5) is associated with substantially increased mortality, especially from cardio-vascular and cardio-pulmonary diseases. Present levels of PM2.5 in Europe are now estimated to reduce the statistical life expectancy in European population by approximately nine months, comparable to the impacts of traffic accidents. Thus, these newly identified impacts of fine particles by far exceed those identified earlier for ozone.”

2.0 Context

This document looks at one aspect of  the Waste Strategy for England, namely the use of municipal solid waste incinerators for energy recovery. Further it suggests that alternative and better technological solutions are already available and that, at last, high quality monitoring technology is becoming available and in a sane world needs to be implemented. Further, the need for the management of waste will continue and represents a commercial opportunity for the UK, should it choose to develop new technological solutions for in-situ monitoring of waste processing and waste management methodologies. As things stand the provision of large scale waste treatment plants is by non UK corporations who have a vested interest in supplying their own (out dated) solutions, thereby driving the waste management agenda in a direction that is favourable to their own commercial needs.

3.0 Background

We cannot simply keep burying our own waste and hoping it will go away, nor can we sacrifice valuable resources bolstering up the immediacy of our convenience culture; new ways of being are required.  In the limit of this, there can no longer be any waste. From a philosophical stand point any waste mitigation strategy that actively prolongs the production of waste, by assuaging the public consciousness; “Look we are reclaiming the energy from your waste so that we can all collude in its further production;” is bankrupt and at best mitigating and disingenuous.

World wide there has been great effort exerted into looking at solutions, with research in a great many countries highly active; looking at ways of improving waste management, environmental and health impacts. Anyone who expresses an opinion that all the parameters of MSW-EfWI are known, is making an assertion that is not based in fact. Quite simply the data set on the emission characteristics, process development and ecological impact, is incomplete. Further, governments do not get together to draw up legislation, specifically global legislation, unless there is a need.

Lest we forget, legislation is drawn up not to provide a safe limit for pollution, rather to lessen the impact through legislative limitation [3]. It is not a guarantee of safety, whether of not people choose to “spin” that it is; is rather, a matter of business expediency. Historically, the United Kingdom has always dragged its feet in respect to the implementation of such legislation either for incineration [3] or landfill [4], favouring short term business profitability over responsible world citizenship. Nevertheless, EU legislation is legally binding on partner states and more is on its way [5]. Retrospective implementation in order to comply with incoming and stricter air quality standards will have financial implications for those selecting out-dated technological solutions for the purposes of short term political gain. 

MSW-EfWI, a now ageing technology, always produces a spectrum of organic chemicals that are not present in the waste that is their feedstock; in addition it produces fine particulate matter. Thus these are man made or anthropogenic sources, which add to the local and global ecosystems and, damage them. MSW incinerators generically have a chequered history.

4.0 Legislative and Inter-Governmental Documentation

There are both European Union [4] and UK governmental directives [6] to reduce the usage of land fill, these are to be enforced by the introduction of land fill taxes. It is safe to say therefore there is international consensus that landfill is a bad idea. Therefore any process that adds to a landfill burden is suspect. MSW-EfWI still needs landfill.

The UK is a signatory to the Stockholm Convention on Persistent Organic Pollutants (POPs) essentially requiring it to cease production of these.

Because of the nature of the Chemistry of MSW-EfWI (discussed below) plants it is a simple fact that they produce poly-chlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/Fs), poly-aromatic hydrocarbons (PAHs), and various other volatile organic compounds (VOCs). A great many of these are known to have highly toxic effects, some of which are long term and hence difficult to detect. As long ago as 1995 the US agency for Toxic Substances and Disease Registry (ATSDR) published a detailed toxicology [7] for PAHs and in 1998 for Dioxins [8].  These documents began to establish a toxicological framework for ongoing discussions in these areas.  For comparison purposes they established a series of toxic equivalencies (TEQs) based on 2,3,7,8-tetrachloro-p-dioxin which is the most widely studied congener. It is very easy to get caught up in the detail of looking at which compound has which TEQ and in doing so forgetting that one is talking about toxic equivalency, the language is explicit. This document [8] is the basis of many subsequent discussions and in the opinion of the author could benefit form revision and updating, it extrapolates from data and makes many generalisations the US Environment Protection Agency (EPA) agrees that it is based upon assumption and yet is has become “gospel”.

Incineration produces POPs.

Within the island context of the UK, the government has drawn up, through the Department for the Environment  Food and Rural Affairs (DEFRA) a waste management strategy document [9] in deed offering a position statement that incinerators are safe [10]. A close examination of this demonstrates that it glosses over the safety implications of Municipal Solid Waste (MSW) incineration. Presumably these position statements are based on a health report by Enviros Consulting (a part of the Mc Alpine Group). It is not surprising that third parties question the impartiality of such a report, given the links to the construction industry. This extensive document [11] published in 2004 discusses many aspects and in places also notes that the quality of the available data set is poor. The Royal Society review of this document is not entirely complimentary.

The DEFRA air quality guidelines [12, 13] (more recently published July 2007) is in a number of ways in conflict with the prior waste management document. This document cross references the World Health Organisation Guidelines [14, 15] and refers to the European initiatives mentioned earlier. It extends discussions into the realms of the environmental impact of particulate emissions, acknowledging the enhanced mortality such emissions engender.

The World Health Organisation (WHO) establishes that particulate matter PM10s, PM2.5s and ultra-fines (cause disease and enhance early death, there is evidence of growth defects and reduced IQs) [14, 15].There is world wide research effort into the impact of PM2.5s covering chemical nature, source identification and distribution patterns of same. The ultra-fines contain particles that are nano-metre in scale. The whole field of nano-toxicology is emergent and under-developed [17, 18, 19] as such represents the unknown.

What is clear is that this is a matter of ongoing research, worldwide.

5.0 The availability of information and governmental strategy.

Since the advent of the World Wide Web, we live in an age where information is, in principle, more widely available.  As such governments and large corporations are ever more careful in what they publish. In effect this negates any real dialogue; DEFRA itself in its own strategy document outlines the need to “handle” public perceptions. Protest organisations, at least in Western countries are free to publish whatever they wish. This proliferation (or deliberate non-proliferation) of information has lead to a situation where there is an acceleration of bytes (some of them sound) about the “facts”, and where consciousness is manipulated to fulfil other objectives. Not all the information published on the web is well researched and factual.

There are even conferences aimed at overcoming the negative perceptions of Energy from Waste [16]. This, under the guise of true consultative approach seems a little out of place. In effect unless one has access to recent research articles via a university library the general public is left to rely upon information provided {research articles cost as much as £30 each} as and when the government chooses, a rather strange implementation of the nanny-state in overdrive.  Further the detailed technical papers published by governmental organisation are written in such a manner as to obfuscate and cause loss of “will to live” in the reader, more specifically the lay reader. Jargon is as ever the coat of the chameleon seeking to hide half truths.

6.0 What is MSW incineration and hence EfW(I)?

In their simplest form incinerators are large ovens where waste is burned in an oxygenated environment. The chemical reaction between waste and oxygen is exothermic (produces heat) that can be used to heat water to drive turbines.  The feedstock for such incinerators is very mixed (heterogeneous) in nature, with varying calorific value. The waste contains organic matter and what chemist terms organic chemicals. These organic (carbon based) materials when completely oxidised make CO2 and H2O, incomplete oxidation creates CO. Unfortunately the reaction chemistry is not quite that simple, in that as a product of combustion various ashes are produced.

These ashes still need landfill and because of the concentration of toxic materials that results from these processes this ash needs to be treated as hazardous waste, requiring separate landfill or further treatment. Incineration produces POPs that were simply not there in the first place. Amongst these POPs, the PCDD/Fs are known to be highly toxic acting inter alia as carcinogens (they cause cancer) [8] and even gene switches. Because they are large aromatic molecules they are not water soluble, they localise in fats or lipids. They are subject to bio-accumulation (they get more concentrated in living things) and bio-magnification (when animals eat others with high concentration their own chemical concentration goes up, this can include humans). They are chemically quite stable and long lived. Governmental doctrine assuages public opinion by presenting statistics comparing the very locally produced pollution to overall national averages, in so doing denying any possible affect of localised clustering.

The track record of incineration is poor, the large scale production of polychlorinated dibenzo-p-dioxins and polychlorinated dibenzo-furans (PCDD/Fs) was determined only in retrospect and reactor design has since improved to reduce flue gas emissions of same [20, 21, 22]. Some key factors have been identified and at certain temperatures the 300-450 °C these compounds are more easily made [23]. Very high temperatures are therefore needed to effectively reduce the content of these. They, POPs, are always produced. If process temperature is increased they are removed form the exhaust gases but concentrate in the resultant ashes. The presence of chlorine is needed [23] to make PCDDs, and all MSW has this and the content will depend upon the feedstock.

Because of new legislation emission limits on PM10s have been set and this has caused incinerator operators to put in place more rigorous filtering regimes. However this does not catch the PM2.5s and ultra-fines. A recent study [24] has shown that the particle size distribution depends on process temperature, with higher temperatures producing particles that range in size from a few nanometres to a few microns. The peaks in the particle distributions occur at ~40nm and ~2 microns. As a rule of thumb the smaller the particle the more likely it is that it is transported further and absorbed into our body.

These toxic chemicals and particles enter our body through three main pathways, we breathe them in, we eat or drink them and they are absorbed through our skin. The whole area of particulate emissions and their affects remains very much a hot topic [25-31], yet consensus remains that they cause morbidity and mortality.

7.0 Monitoring

The data set on true emission characteristics of MSW incinerators, Energy from Waste (EfW) incinerators being a sub set of these, are not readily available. In fact there is consensus that this is incomplete.  There has been progress in developing new on line monitoring capabilities [24, 32, 33, 34].  This is still research. In the absence of stack top monitoring and chemical assay of incinerator ashes, any quoted values are at best projections and at worst guesses. Surely, it is a simple requisite that such monitoring must be in place.

The quantification of human body burdens is limited in live beings and is only ever a snapshot at a given time, because living organisms absorb things and then after a time change them or pass them from the body.  Measurements of in vivo body burdens for humans is perhaps limited to blood sampling from live volunteers[35], the fat soluble PCDD/Fs/PAHs are found in assay, presumably from the lipids in cell membranes only. The author is not aware of any current methodology to measure particulate body burdens. Post mortem studies may yet provide an evidence base, by their very nature concentrations are static upon death and exposure histories can only (currently) be gained from indirect sources and via extrapolations.

Some indirect methods of monitoring are however proving helpful in clarifying long term exposure patterns. Researchers have recently looked at the possibility of micro-evolution due to toxic stress [36], bio-monitoring with lichens [37], genotoxicity with Tradescantia micronuclei [38] and uptake in peregrine falcon eggs [39]. Direct transferability of these to the human condition also remains somewhat of an extrapolation, though the long term natures of these bio-markers are proving insightful.

Governmental safety assurances are based on retrospective epidemiological studies from a number of localities for example [40-44] and are assumed to be directly and globally transferable.  Little acknowledgement is made of differing climatic conditions between sites and the absence of such studies in the UK, is very noteworthy.

Risk analysis[45,46] is based on average body exposures / loadings and putative emission characteristics quoted in comparison to mass burdens using the TEQ scale mentioned earlier and the whole  area is still generating research[45,46], whilst acknowledging uncertainty in the toxico-kinetic and toxico-dynamic models [47,48,49].What is safe to say is that the area is very much one of research and may lead to the development of a new area of human pathological endeavour in years to come, when the long term exposures effect in the population at large.

8.0 Technology Choice

Weber et al[50], discuss at length the concept of POP destruction technology in line with the intent of the Stockholm convention suggesting that PCB(Poly-chlorinated biphenyl) destruction facilities operating at 1100º C with residence times in excess of 2 seconds. Plasma gasification technologies operate in this domain rather than at the temperatures that synthesise POPs. They are used to treat POP rich waste from other sources.  Like all developing technologies there is a time lag between conception and inception; see for example [51, 52]

In a fast changing world it is interesting that there is so much emphasis(in the UK) on incineration, particularly so when facilities to produces fuel gases from waste are already operational around the world, for example the plasma gasification plant at Utashinai in Japan.  Secondary gas combustion is much easier to control (being of a homogeneous nature) and the high temperature processes do not create POPs; in fact such methods are used to treat incinerator waste prior to landfill. The technology cycle has now advanced. Perhaps it is time for the UK to look to the USA and Japan for guidance on how to handle waste for the future.  Arguments can be made about the volume handling of such gasification plants in comparison to MSW-EfWI, however might it not also reduce the transport burden if smaller more local facilities were built to handle local waste?

There is much development in the area of gasification (including plasmas) as evidenced by a recent conference [53], perhaps agreeing with the title of the document that incinerators are… Yesterday’s Solution. 

 Appendix 1 References

1) http://www.pops.int/documents/convtext/convtext_en.pdf

2) http://ec.europa.eu/environment/air/cafe/general/pdf/cafe_lot1.pdf

3) http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32000L0076:EN:HTML

4) http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31999L0031:EN:HTML

5) http://europa.eu/rapid/pressReleasesAction.do?reference=IP/06/1447&format=HTML&aged=0&language=EN&guiLanguage=en

6) http://www.defra.gov.uk/environment/waste/topics/landfill-dir/pdf/landfilldir.pdf

7) http://www.atsdr.cdc.gov/toxprofiles/tp69.pdf

8) http://www.atsdr.cdc.gov/toxprofiles/tp104.pdf

9) http://www.defra.gov.uk/environment/waste/strategy/strategy07/pdf/waste07-strategy.pdf

10) http://www.hpa.org.uk/chemicals/ippc/incineration_posn_statement.pdf

11) http://www.defra.gov.uk/environment/waste/research/health/pdf/health-report.pdf

12) http://www.defra.gov.uk/environment/airquality/strategy/pdf/air-qualitystrategy-vol1.pdf


14) http://whqlibdoc.who.int/hq/2006/WHO_SDE_PHE_OEH_06.02_eng.pdf

15) http://www.euro.who.int/Document/E90038.pdf

16) http://www.energywaste.co.uk/Workshop.asp?m_pid=9889&m_nid=9923

17)  Ji et al., Inhalation Toxicology, 19, ( 2007), 745-751.

18)  Warheit et al…, Inhalation Toxicology, 19, (2007), 631-643.

19) Handy et al., Health, Risk and Society, 9, (2007) 125-144.

20) Liuzzo et al., Waste Management, 27, (2007) 106-116.

21) Geysen et al., Journal of Hazardous Materials, B126, (2006), 27-38.

22) Streibel et al., Chemosphere, 67, (2007) S155-S163

23) Takasuga et al., Arch. Environ. Contam. Toxicol. , 53, (2007), 8-21.

24)  Maguhn et al., Environ. Sci. Technol., 37, (2003), 4671-4770.

25) Grahame et al., Inhalation Toxicology, 19, ( 2007), 457-481.

26) Grahame et al., Inhalation Toxicology, 19, (2007), 727-744

27) Freitas et al., Nuclear Instruments and Methods in Physical Research B, 219-220, ( 2004) 153-156.

28) Schlesinger, Inhalation Toxicology, 19, (2007), 811-832.

29) Pongkiatul et al., Atmospheric Research, 85, ( 2007), 3-17.

30) Aboh et al. , X-ray Spectrometry, 36, ( 2007) 104-110.

31) Reff et al.,  Atmospheric Environment, 41, (2007), 4584-4598

32) Clarkson et al.,  Anal. Bioanal. Chem. 377, (2003) 39-47

33) Deguchi et al., Measure..Sci.Technol., 13, (2002), R103-R115.

34)  Binnig et al., Aerosol Science, 38, (2007), 325-332.

35) Reis et al., Chemosphere, 67, (2007) S224-S230.

36) Medina et al., Chemosphere, 67, (2007), 2105-2114

37) Augusto et al., Int. J. Environ. Health  210, ( 2007) 433-438.

38) Misik et al. , Environmental Pollution, 145, (2007), 459-466.

39) Malish et al.,  Chemosphere, 67, (2007), S1-S15.

40) Morselli et al.  Waste Management, 27, (2007), S85-S91

41) Abad et al., Chemosphere, 67, (2007), 1709-1714.

42) Grosso et al., Chemosphere, 67, (2007), S118-S124

43) Yu et al., Atmospheric Environment, 40, (2006), 96-108.

44) Schuhmacher et al., Environment International, 32, ( 2006), 397-404.

45) Paustenbach et al., Regulatory Toxicology and Pharmacology, 44, ( 2006), 249-261.

46) Nieuwenhuijsen et al., Environment International, 32, (2006), 996-1009.

47) Heinzl et al.  , Chemosphere 67, (2007) S365-S374.

48) Kerger et al., Chemosphere 67, (2007), S272-S278.

49) Charnley et al, Food and Chemical Toxicology, 44, ( 2006), 601-615.

50) Weber, Chemoshpere, 67, (2007) S109-S117.

51) Camacho, World Patent WO 97/08494

52) Raymond,  Canadian Patent CA 2339 457

53) http://www.gasification.org/

Leave a Reply

Please log in using one of these methods to post your comment:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s