Comments and Testimonies

January 25, 2005

CLEAN AIR COUNCIL'S ORAL TESTIMONY TO PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION'S INTENT TO ISSUE TO HARRISBURG MATERIALS ENERGY, RECYCLING, AND RECOVERY FACILITY A MINOR PERMIT MODIFICATION: SOLID WASTE PERMIT NUMBER 100758.

Good evening. My name is Toni Flora, and I am Program Manager with Clean Air Council, Harrisburg office. CAC is a state wide non-profit, member-supported organization that is dedicated to protecting everyone's right to breathe clean air. The Council has members in Dauphin County that are affected by the permitting of the Harrisburg Materials, Energy, Resource Recovery Facility (HMERRF).

I would like to thank the Department of Environmental Protection, Office of the Environmental Advocate, and the Harrisburg Materials Energy, Recycling, and Recovery Facility (commonly known as the Incinerator) for allowing members of the community to come forth tonight to express their comments and concerns regarding the permit modification. Clean Air Council recognizes that this is not a mandatory procedure according to Pennsylvania administrative law, and the Council really appreciates the opportunity to comment.

The past compliance history of the Harrisburg Incinerator is questionable at best. The citizens in the community, who are aware of the status of the incinerator, are wary of its health risks. DEP is aware that the relatively small turnout tonight is due to the defeat the citizens felt when permits were issued last year. Numerous accounts of past permit violations have been documented, and even Barlow, in its 2001 feasibility study, noted at section 1.2.3.5 on page 1-6, noted the negative influence of the incinerator's history.

I would like to say first that the Council understands that DEP is in a difficult position where they are faced with strong community opposition and the city's push to restart the incinerator. The community is strongly opposed to continued operations because of concerns to public health, and based on the past history of the incinerator.

Penalties for the permit violations in the past were not enough to deter the violations from reoccurring. In one instance in this permit, if the operations staff are not careful, they could leave the door open for more violations. Over a period of nine months in 2000 - 2001, the incinerator was found in violation 14 times for allowing waste to remain onsite for over 24 hours. Attachment P, page P-3, states that there is enough room for three days of storage that will "provide sufficient fuel for weekends and holidays when less waste is delivered." The intent is in accord with the previous permit 100758, condition number 6. However, the ability of the incinerator to store extra waste, coupled with the ability of the incinerator to receive and process 185 tons more of waste than it is allowed to burn in a day, will in all probability lead to more violations and more problems.

The CAC was pleased when the mayor placed an additional recycling drop off area on 7th and Division Streets. The Incinerator is showing an attempt to recycle. Additionally, there is minimal curb side recycling. However, these attempts are not enough. Bleached writing paper is a source of dioxin emissions. According to figure 2 of the Southcentral Region Aggregate MSW composition, paper is 34.7% of waste. 586,111 tons of paper are disposed of in this region.

In order to reduce the emissions of dioxin, it would be beneficial for the facility to require reduction of the amount of bleached paper that enters the incinerator through promotion of recycling efforts. A permit condition should be, in addition to the collection facilities on site, the Facility should make a strong push for recycling in the community. Not enough effort has been made by the government or private industry in the community to educate people about the benefits of recycling and where and what to recycle.

In other communities in other states, trash collectors do not pick up a resident's trash for the week if there are any visible recyclables in the trash. Pressure from HMERRF to their haulers could promote more recycling throughout the state, and as a result, avoid unnecessary emissions.

Another resource recovery mechanism the facility can promote is composting of foods such as fruits and vegetables, which can easily be done in one's own back yard and used as a natural fertilizer. I mention this because food is the most prevalent material in Southcentral PA, according to figure 5 in DEP's Region MSW Composition report. THA should consider promoting composting to residents to cut down on the amount of waste.

A memo that cited a Barlow report in 2000, saying it offered the option of a pre-sorting system to remove recyclable materials. This system does not appear to be employed in the permit. The method to remove recyclables and hazardous materials, or bulky waste such as large appliances, is to retrieve it from the tipping floor using a front end loader. This process seems inefficient and unpractical to remove the smaller appliances, recyclables, and non-permitted waste such as the kidney dialysis bag which was accepted, resulting in a violation around March 24, 2000. The permit should mandate a more effective way to recover recyclables from the loads received at the facility. Installation of the pre-sorting system would result in more jobs to monitor the system and ensure proper operation. Additionally, more household hazardous waste collection programs and electronic waste collection programs need to be conducted in the local communities.

Another concern for the future of the incinerator is the ash landfill. It is noted in Form 13A that the ash landfill will close no later than March 22, 2010. If the incinerator continues to operate at that point, there will be increased truck traffic to remove the ash waste to another landfill. Another issue will be the loading of the ash onto the trucks. Right now the permit calls for the landfill to be covered, and the entire facility appears to be an indoor operation. It appears as though loading the ash and driving the trucks around with the ash will create an additional concern with ash waste, as it was at one point before the retrofit.

DEP's past enforcement was not rigorous enough in the community's view. By issuing the permit, the community has expressed concern that DEP will not be there to protect the community from continuous violations by the Incinerator. IF DEP decides to issue this permit, the community expects vigorous enforcement of the permit conditions and strict compliance with the law. Clean Air Council insists DEP protect the health of the citizens of Central Pennsylvania.

I would like to thank all of you for your time.