Environmental Impact Statement Review, Incinerator, Clarecastle, County Clare, Ireland

OVERVIEW

The Environmental Impact Statement for construction and operation of an incinerator in Clarecastle, County Clare, Ireland, was reviewed in its entirety to assess accuracy and completeness in terms of project planning, modeling, waste identification, and technical data presented.

INTRODUCTION

Nomenclature

In keeping with the nomenclature used in the Environmental Impact Statement (EIS), Polychlorinated dibenzo-para-dioxins (PCDDs) as a group are referred to as "Dioxins". Polychlorinated dibenzofurans (PCDFs) and Polychlorinated biphenyls, are referred to as "Furans" and "PCB's" respectively.

Report Organization

Comments have referenced the appropriate sections of the EIS. Where a paragraph is given for reference, for example, Section 4.4, Page 30, Paragraph 1, this indicates the first paragraph contained in that specific section.

Acronyms

EIS Environmental Impact Statement
HCl Hydrochloric acid
IPC Integrated Pollution Control
NaCl Sodium chloride
Na2SO4 Sodium sulfate
PIC Product of Incomplete Combustion
STEL Short Term Exposure Limit
TEF Toxicity Equivalent Factor
TEQ Toxicity Equivalent
TLV Threshold Limit Value
TOC Total Organic Carbon
WHO World Health Organization

NON TECHNICAL SUMMARY

Section 2.4.1, Page 8, Paragraph 1

The liquid waste as outlined in this paragraph will also contain fly ash (see page 48 of main report) absorbed from the scrubbing procedure. It could also contain other chemicals absorbed from the gases, and would need thorough testing before discharge into the Fergus Estuary.

Section 2.4.1, Page 8, Table

The current Integrated Pollution Control (IPC) license for effluent discharge is inadequate to assess the present environmental impact on the Fergus Estuary. The license contains only traditional wet chemical parameters. As the bulk of the waste generated is of an organic nature, the absence of limits for specific organic chemicals is an omission which could result in a threat to the environment and to public health.

Total Organic Carbon (TOC) in the effluent currently has an average annual value of 723 mg/L, indicating the presence of organic compounds at part per million levels. As appropriate discharge limits for organic solvents would be at far lower levels (for example, chlorinated volatile organics would be assessed at ug/L, or part per billion levels), it is essential that this effluent be adequately characterized in order to determine the baseline effect of the present effluent discharge. At a minimum, this testing should include routine analyses for chlorinated and non-chlorinated Volatile and Semivolatile organic compounds, Metals, and an initial analysis for other groups of toxic compounds, such as Dioxins and Furans.

This is relevant to the granting of the license in that the wastewater stream generated by the incinerator is going to increase the volume of effluent discharge into the Fergus Estuary by 50m3/day, as well as change the characteristics of the final effluent in adding fly ash to the effluent.

In addition, the present Sodium bromide concentration exceeds the license limit by more than 100%. Although information is presented as to the fact that this level of sodium bromide is not toxic to trout and shrimp, there is no documentation that this level is not a threat to other aquatic flora and fauna.

Section 2.4.2, Page 9, Paragraph 1

Current air emissions, which include toxic organic solvents, at 623 tonnes/year, at present, pose a threat to public health and the environment. As the plant has been operating as such for many years, a health study of the local population should be immediately undertaken to assess what effects these emissions have already had on the local population.

Section 2.4.2, Page 10, Paragraph 1

"Concentrations of dioxins will be monitored periodically..." It is necessary to state the frequency, sampling and analytical testing methodology, (including whether specific dioxin isomers are to be measured), and detection limits which are to be utilized in the monitoring. In addition, it will be necessary to determine where the samples can be analyzed, how they will be transported, and what holding times are adequate to ensure that sample degradation does not occur between sample collection and testing. In addition, furans should be analyzed and can be as they are part of the same analytical test as that for dioxin.

Section 2.5, Page 11, Paragraph 5

States that Sodium chloride (NaCl) and Sodium Sulfate (Na2SO4) are non-toxic and therefore will have no impact on estuarine fauna. This statement is incorrect in that it depends on the concentrations to which the fauna is subjected.

Section 2.9, Page 15, Paragraph 1

The EIS states "Without an incinerator..there may be no alternative other than closure eventually." This type of statement is inappropriate in an EIS as it could be interpreted as a situation in which a trade off must be made between environmental regulation and employment.

Section 2.12, Page 16, Paragraph 1

"..if wastes..are not incinerated at the correct temperature, toxic chemicals such as dioxins are discharged to the atmosphere." This statement is somewhat misleading as even when incinerators are operated at the correct temperature, toxic chemicals such as dioxins and furans are discharged to the atmosphere. This is outlined in Paragraph 3.

Section 2.12, Page 16, Paragraph 3

3 ug/hour dioxin, 72 ug/day, or alternately 0.1 ng/m3 cannot be deemed a safe level of dioxin. As more studies relating to dioxin exposure are conducted it is being found that there is no level at which specific dioxin isomers are not considered a risk to public health and the environment. In addition, the EIS does not address the formation, levels, or testing of other products of incomplete combustion (PICs), including Furans and PCBs. These are also emitted from the type of incinerator proposed and their effects on the environment and public health are not included in the EIS.

Section 2.15, Page 19, Paragraph 2

The salmon catch statistics should be added as an addendum presently in order to determine whether effluent is affecting the catch. This is significant as there are salmon netting operations in the local area.

MAIN REPORT

Section 3.1, Page 16 1st paragraph

"Non-toxic" solid wastes are landfilled in double lined cells, and leach; the leachate is treated in the effluent plant. Are the contents of the waste in the landfill entirely characterized by a Toxicity Characteristic Leaching Procedure (including metals, semivolatile organics, volatile organics, pesticides, dioxins, furans, and herbicides)? This is the only way to validly demonstrate that a leachate is not hazardous, unless the totals analysis on the solid waste for all of these parameters has been undertaken and shown to be under limits. These parameters are not tested under the IPC license, so leachate from the landfill could contain some of the toxic compounds detected by these procedures. Is this also the landfill that will be used for the fly ash and bottom ash? Leachate from the fly ash and bottom ash could contain hazardous compounds; and should be characterized.

Section 4.4, Page 30, Paragraph 1

The manufacturer of the incinerator is not named, and has not been chosen as of submission of the EIS. Therefore, the relevant design and specific ability of the manufacturer to design and build an incinerator within the operational, environmental and safety guidelines of the EIS cannot be determined. It is essential that the manufacturer and design proposal be included in the plan to assess the experience and ability of the manufacturer to design and build an incinerator which meets the safety guidelines as proposed in the plan and as outlined by the EPA.

Section 4.4, Page 32, Paragraph 5

Particulates will be contained in the scrubber effluent liquid waste. The particulates are absorbed from the scrubbing process, and are actually the fly ash (reference Page 48). The incinerator effluent will be diverted to the final stage of existing effluent treatment process (the effluent holding lagoon), and mixed with the existing treated effluent. It is not clear in the EIS whether the testing on the effluent (carried out under the IPC license) will be conducted before or after the mixing of the two effluent streams. The effluent stream from the incinerator will contain 110 kg/day of particulates (or fly ash) which will be released into the Fergus Estuary. Fly ash is known to contain dioxins, furans, and other products of incomplete combustion; and is considered an extremely toxic material.

Section 4.4, Page 32, Paragraph 6

The levels of HCl emissions conflict with the design parameters on page 34:

Page 33: below 10 mg/m3 daily average and 60 mg/m3 hourly average.
Page 34: daily average of 10 mg/Nm3 and 60 mg/Nm3 hourly average.

Section 4.4, Page 33, Table

The expected dioxin value is given in Toxicity Equivalents (TEQ) as 0.1 ng/Nm3. Total dioxin discharge emissions according to the EIS will be 72 ug/day. Inhalation is an exposure route, and the ground level air concentration needs to be estimated in pg/m3, and modeled as to human exposure using appropriate breathing rates.

There is conflicting information regarding dioxin toxicity (given that many reports conclude there is no safe level), however, for comparison purposes, even conservative estimates estimate that exposure should be kept below 60 pg/day (based on TEQ and a person's size of 60 kg). In relation to planned emissions:

Planned Dioxin Emissions = 72 ug/day = 72,000,000 pg total dioxin/day
Exposure limit = 60 pg/day (TEQ) for a 60 kg person

Most human exposure to dioxin can be attributed to food. The food which is thought to be the major contributors are dairy products (including breast milk), meat, and fish.

Given the level of milk production, cattle farming, sheep farming, and fishing in the area, the level of dioxin emitted and dispersed into the area needs to be better detailed in the EIS.

Section 4.5, Page 33, Paragraph 1

The performance monitoring suggested in the EIS is incomplete in terms of compound list of parameters, specific compounds to be reported, detection limits, frequency of monitoring, sampling and analytical testing procedures, and media tested. Five waste streams, constituting five separate media, will be coming from the incineration process. Those are:

Gaseous Emissions
Particulate Emissions
Liquid Effluent
Solid Waste (fly ash and bottom ash)
Leachate from landfill

A specific list of compounds with associated detection limits should be established for each waste stream; each taking into account the likelihood of compounds which will be detected in that media. For example, in the gaseous emission, Dioxins and Furans should be tested at the pg/m3 level, and the results for each specific isomer and TEQ result should be presented. Another example would be to test the solid waste using the appropriate TCLP methodology, associated compound lists, and detection limits, to determine whether the fly ash and bottom ash are appropriate to landfill.

Section 5.6, Page 48, Paragraph 3

Will the estimated additional level of sulfate from the sodium sulfate exceed the present IPC license for Sulfate, given the level of sulfate in the effluent at present? The IPC at present does not require testing for Chloride, however, it would be advisable to include Chloride and Bromide levels in the effluent guidelines.

Section 5.6, Page 49, Paragraph 1

"The scrubber waste will have no impact on ground-water quality...." This statement is somewhat misleading, as although the scrubber waste may not have an effect on the groundwater (assuming that the groundwater and the Fergus Estuary water are exclusive), it will have an effect on the Fergus Estuary, as 50 m3 is expected to be discharged into the Fergus Estuary, including 110 kg per day of fly ash (estimated final concentration of 275 mg fly ash/L in final effluent).

Table 6.6, Page 63, Analytical Results

Where ND (Not Detected) is listed, the detection limit of the analysis should also be listed. There are -'s listed for various compounds and sampling months (example Aug '94 dichloromethane). What does this indicate? Results for methyl chloride Aug '94 and methanol Sept '94 are left blank. Are there results for these compounds?

Table 6.7 through 6.11, Pages 64-69, Analytical Results

Same omissions as above.

Table 6.13 - 6.14, Page 70-71, Analytical results

There are significant differences in the results of the modeled concentrations between Forbairt and Weston (Contained in Appendix 6 and Table 6.14) For example: the ethyl acetate modeled concentration, Forbairt result is 0.0004 mg/m3; Weston result 0.765 mg/m3). In addition to analytical differences which are quite significant, Weston includes results for the compounds xylene and n-hexane, which are not included in Forbairt's Table 6.13, and are listed as not detected in Forbairt's analytical results.

There are also different reference limits applied for the compounds. The Weston report uses the World Health Organization (WHO), STEL/100 (Short Term Exposure Limit) guidelines. The Forbairt report uses the TLV/100.

At a minimum, it is essential that it be made clear which guidelines are appropriate, which compounds are appropriate, and why the reports differ in terms of compounds detected and analytical results.

Table 6.16-6.19, Pages 74-77, Analytical results

There is no note as to what the * in the concentration indicates. Does the * mean that the compound was not analyzed for, or was not detected?

In addition, in several places a concentration of 0.00 is listed. Analytical results cannot be expressed as 0.00. If, for example, 2,3,7,8-TCDF in sample 1 (page 74) was not detected, it must be listed as <0.0023 ng/g. Multiplying the detection limit by the TEF of 0.100, the resulting TEQ is 0.00023, not 0.0000 as is reported. However, it may be that the 2,3,7,8-TCDF was detected, and was incorrectly "rounded" to 0.00. This type of error (analytical results of 0.00) is found throughout the tables. This error is noted in all tables.

In addition, the detection limit for 2,3,7,8-TCDF is listed as 0.0000 for Sample 2. The capability does not exist to detect TCDF to zero, so this must also be in error.

These results should be corrected as they are not represented in an analytically sound manner, and the TEQ's are underestimated.

Section 6.4.1, Page 82, Paragraph 1

The predicted ground level concentration of dioxin[s] is 0.00003 ng/m3. No prediction is made as to the TEQ. This section should include the following additional information:

1. An estimate of the corresponding TEQ.
2. The inhalation exposure that this level results in, in TEQ (i.e. in pg, the total exposure to a person based on modeled breathing rates and body weight).
3. This should be compared to an established exposure limit, in general, these should be in pg TEQ.

Table 8.1, Page 95, Waste Types

Methane, Xylene, n-hexane, and heptane are listed as gaseous emissions, however, they are not included as wastes generated.

Section 8.2, Page 97, Paragraph 1

The nature of the present on-site contamination should be documented in this section. As the contaminated water from the boreholes is being pumped and treated in the wastewater plant, then presumably discharged into the Fergus Estuary, the effluent should be tested for these contaminants to test the efficacy of the current treatment process.