DC Council: Reject the Covanta Waste Contract

Learn more about DC’s con­nec­tion to Lor­ton in this arti­cle on DC’s Waste and Envi­ron­men­tal Racism

Jump down to ver­sion with documentation

About half of the waste going through DC’s two trans­fer sta­tions goes to be burned in Cov­an­ta’s Fair­fax trash incin­er­a­tor in Lor­ton, Vir­ginia. This con­tract expires at the end of 2015. DC’s Depart­ment of Pub­lic Works (DPW) has issued a a request for pro­pos­als (RFP) for 5–11 more years of waste burn­ing, and award­ed it to Cov­an­ta. This con­tract now needs coun­cil approval with­in 45 days (before coun­cil recess­es on July 15th).

Incin­er­a­tion is the most expen­sive and pol­lut­ing way to man­age waste (or to make ener­gy). Con­tin­ued reliance on incin­er­a­tion flies in the face of the new waste law City Coun­cil passed in 2014, requir­ing the city to move toward zero waste. It’s also bad for the health and pock­et­books of DC res­i­dents, and vio­lates the Civ­il Rights Act.

RFP Too Narrow

The RFP was set up so that only one facil­i­ty could bid. It was restrict­ed to exist­ing incin­er­a­tors with­in 50 miles of DC’s trans­fer sta­tions. There are only four such facil­i­ties. The only one in a white com­mu­ni­ty (Mont­gomery Coun­ty) does not take out-of-coun­ty trash. Two of the oth­ers (Alexan­dria and Bal­ti­more) do not have room for the vol­ume of DC’s waste. The con­tract was rigged to keep waste flow­ing to Covanta’s Lor­ton incin­er­a­tor. Land­fills were not allowed to bid.

Eco­nom­ics

Incin­er­a­tion is the most expen­sive way to man­age waste. DPW Direc­tor How­land admit­ted – in a 2009 email to the May­or’s office, and in sworn tes­ti­mo­ny before city coun­cil in 2012 – that truck­ing waste to south­east­ern Vir­ginia land­fills was cheap­er than dis­pos­ing of it at the incin­er­a­tor in Lor­ton, yet DPW chose to go with incin­er­a­tion in the last con­tract because of their pro-incin­er­a­tion bias.

Social jus­tice

DC’s waste sys­tem is a prime exam­ple of envi­ron­men­tal racism – a doc­u­ment­ed nation­al trend. DC’s waste is first trans­ferred through black com­mu­ni­ties in Wards 5 and 7, then much of it is burned in Lor­ton, VA, which is the 12th most diverse com­mu­ni­ty of col­or in the coun­try. The Lor­ton Val­ley com­mu­ni­ty lives adja­cent to the giant incin­er­a­tor and two large land­fills (one is where the incinerator’s ash goes), and near­by a third land­fill and a sewage sludge incin­er­a­tor. It’s a vio­la­tion of the Civ­il Rights Act for fed­er­al­ly-fund­ed agen­cies, includ­ing the Dis­trict, to take actions that have a dis­crim­i­na­to­ry effect, as this RFP does.

Health

DC has high asth­ma rates. Accord­ing to the CDC, DC’s adult life­time asth­ma preva­lence was 16.2%, while the nation­al rate is 13.3%. The age-adjust­ed asth­ma hos­pi­tal­iza­tion rate in the Dis­trict of Colum­bia was 267.1 per 100,000 per­sons com­pared with the U.S. rate of 144 per 100,000 per­sons. With­in 20 miles of DC, Covanta’s Lor­ton incin­er­a­tor is sec­ond only to Dulles Air­port in emis­sions of nitro­gen oxides (NOx), the air pol­lu­tants that aggra­vate asth­ma. Covanta’s Alexan­dria incin­er­a­tor is also in the top five in the DC area. DC’s waste dis­pos­al should not be help­ing dri­ve DC’s high asth­ma rates. 

Oth­er health prob­lems are exac­er­bat­ed by the fact that this incin­er­a­tor is the largest emit­ter of Hydro­flu­o­ric Acid in their entire indus­try, is the largest source of mer­cury pol­lu­tion with­in 20 miles of DC, is in the top five sources of sul­fur diox­ides with­in 20 miles, and is a large source of volatile organ­ic com­pounds (VOCs).

Envi­ron­ment

Incin­er­a­tors do not avoid land­fills. They just make for small­er, more tox­ic, land­fills. The Cov­an­ta incin­er­a­tor Lor­ton dumps their tox­ic ash in an old Fair­fax Coun­ty land­fill adja­cent to the incin­er­a­tor. For every 100 tons of trash burned, 30 tons of ash remain. The rest went into the air. Land­fills are a prob­lem, but incin­er­a­tion just makes the pol­lu­tion prob­lem worse, cre­at­ing new tox­ins in the com­bus­tion process and con­cen­trat­ing what doesn’t end up in the air, into the ash sent to land­fills, where it can still leach and harm groundwater.

Trash incin­er­a­tion is dirt­i­er than coal burn­ing. To make the same amount of ener­gy as a coal pow­er plant, trash incin­er­a­tors release 28 times as much diox­in than coal, 2.5 times as much car­bon diox­ide (CO2), twice as much car­bon monox­ide, three times as much nitro­gen oxides (NOx), 6–14 times as much mer­cury, near­ly six times as much lead and 70% more sul­fur dioxides.

Cov­an­ta’s track record

Cov­an­ta has an exten­sive track record of vio­la­tions at their facil­i­ties across the coun­try. Many are for air pol­lu­tion vio­la­tions. They were even once caught and fined for tam­per­ing with their emis­sions mon­i­tors to make it seem like their emis­sions are low­er than they real­ly are.

“Waste-to-ener­gy” and “ener­gy from waste” = Incineration

Covanta’s facil­i­ties are defined and reg­u­lat­ed as trash incin­er­a­tors (“munic­i­pal waste com­bus­tors” in EPA lan­guage). The fact that they gen­er­ate small amounts of elec­tric­i­ty has no bear­ing on whether they are incin­er­a­tors. How­ev­er, the indus­try has a (well-deserved) ter­ri­ble rep­u­ta­tion, as incin­er­a­tion is one of the most unpop­u­lar tech­nolo­gies there is. For that rea­son, Cov­an­ta and oth­ers avoid the ‘i’ word and insist that they’re not incin­er­a­tors, choos­ing inac­cu­rate PR terms instead. Waste isn’t actu­al­ly turned into ener­gy, but into tox­ic ash and tox­ic air emis­sions. Three to five times more ener­gy is saved by recy­cling and com­post­ing dis­card­ed mate­ri­als than can be cre­at­ed by burn­ing them. In essence, these are “waste-OF-ener­gy” facilities.

What Should be Done: Let the Cov­an­ta con­tract die so that DPW can extend the cur­rent con­tract on a 1‑year basis, allow­ing time to prop­er­ly rebid for a short­er term con­tract allow­ing land­fills and digesters to bid, and mov­ing toward zero waste

In pass­ing the Sus­tain­able Sol­id Waste Man­age­ment Amend­ment Act of 2014, city coun­cil man­dat­ed that the Dis­trict come up with a zero waste plan, out­lin­ing steps the Dis­trict can take to achieve at least an 80% waste diver­sion rate – divert­ing waste from both incin­er­a­tors and land­fills. Rather than con­tin­ue to use both, and lock in con­tracts for 5 to 11 years, city coun­cil ought to reject the Cov­an­ta con­tract (or let it die, unin­tro­duced), extend the cur­rent Cov­an­ta con­tract on a short-term basis (no more than a year), and request that DPW issue a 1‑year RFP that is open to all bid­ders that can han­dle DC’s waste (includ­ing land­fills and digesters, not just incin­er­a­tors). This will buy some time to allow DPW to then start work­ing toward con­tracts that reflect the zero waste goal. For what­ev­er waste can­not be reduced, reused, recy­cled or com­post­ed, the “back end” con­tracts ought to require that waste be anaer­o­bi­cal­ly digest­ed before land­fill­ing, avoid­ing gassy, stinky land­fills, and help­ing the city meet its goals regard­ing cli­mate change.

There are sev­er­al land­fills that could bid. The remain­der of DC’s waste cur­rent­ly goes to land­fills in much more rur­al areas in south­east­ern Vir­ginia, affect­ing far few­er peo­ple (1,500 to 4,500 peo­ple with­in 5 miles of the land­fills, com­pared to 103,000 peo­ple liv­ing with­in five miles of the Lor­ton incinerator).

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DOCUMENTATION:

“About half of the waste going through DC’s two trans­fer sta­tions goes to be burned in Cov­an­ta’s Fair­fax trash incin­er­a­tor in Lor­ton, Virginia.”

From 2011–2013, 49% of the waste going through DC’s Fort Tot­ten and Ben­ning Road trans­fer sta­tions went to Cov­an­ta’s Fair­fax (Lor­ton) incin­er­a­tor, accord­ing to data released by DPW in a 2014 FOIA request (see items 9–12 for spread­sheet with DC’s waste flow data), from which this chart was compiled:

This is affirmed on DPW’s web­site, where they state “The major­i­ty of trash, yard waste, and asso­ci­at­ed mate­ri­als col­lect­ed res­i­den­tial­ly or com­mer­cial­ly at the agency’s trans­fer sta­tions, are dis­posed at Fair­fax County’s Ener­gy Resource Recov­ery Facil­i­ty in Lorton.”

“This con­tract expires at the end of 2015.”

The cur­rent con­tract was exe­cut­ed with Cov­an­ta Fair­fax in 2008, and was extend­ed in 2010 and 2012 . The lat­est exten­sion states on p3: “The term of this agree­ment is effec­tive upon exe­cu­tion through Decem­ber 31, 2015.” This was revealed in our 2013 FOIA to DPW.

“DC’s Depart­ment of Pub­lic Works (DPW) has issued a a request for pro­pos­als (RFP) for 5–11 more years of waste burn­ing, and award­ed it to Cov­an­ta. This con­tract now needs coun­cil approval with­in 45 days (before coun­cil recess­es on July 15th).”

Solic­i­ta­tion: Doc173543 “Waste to Ener­gy Facil­i­ty” was post­ed on the DC Office of Con­tract­ing and Pro­cure­ment site on Nov 21, 2014. It’s for waste incin­er­a­tion ser­vices for a term of 5 years, plus two 3‑year renew­al peri­ods. To get to the orig­i­nal, go to the OCP web­site , click on “elec­tron­ic oppor­tu­ni­ties” and find Doc173543 under “Pend­ing Selec­tion” (it helps to click on “ID” to sort by ID first).
The con­tract was award­ed to Cov­an­ta Fair­fax, as indi­cat­ed in the leg­is­la­tion seek­ing emer­gency coun­cil approval .

“Incin­er­a­tion is the most expen­sive and pol­lut­ing way to man­age waste (or to make energy).”

See this doc­u­ment­ed at www.energyjusticenetwork.org/incineration .
Some high­lights…
Incin­er­a­tors are more expen­sive than land­fills. Here’s how incin­er­a­tor prices com­pare to land­fill prices across the country:

Source: Nation­al Sol­id Waste Man­age­ment Association

See fur­ther down for DC-spe­cif­ic doc­u­men­ta­tion show­ing that it’s cheap­er to use land­fills than the Cov­an­ta Fair­fax incinerator.

Incin­er­a­tion is more pol­lut­ing than coal:

“Con­tin­ued reliance on incin­er­a­tion flies in the face of the new waste law City Coun­cil passed in 2014, requir­ing the city to move toward zero waste.”

In July 2014, DC City Coun­cil passed the Sus­tain­able Sol­id Waste Man­age­ment Amend­ment Act with our sup­port. This new waste law requires that the city come up with a zero waste plan to divert 80% of the city’s waste from both incin­er­a­tors and land­fills. It clar­i­fies the city’s Sus­tain­able DC pro­gram goal of zero waste by 2032.

For the city to start mov­ing toward zero waste, incin­er­a­tors must be cut out of the ques­tion. Incin­er­a­tors are nev­er part of a zero waste sys­tem. The eco­nom­ic sav­ings of using land­fills in the inter­im are need­ed to finan­cial­ly sup­port the waste reduc­tion strate­gies. Also, address­ing the back end of the sys­tem prop­er­ly (digest­ing any remain­ing waste to sta­bi­lize it before land­fill­ing) is impor­tant to address with­in city waste con­tracts — and needs to be dri­ven through con­trac­tu­al incen­tives in the next five years, per­haps by start­ing to require a cer­tain por­tion of DC’s waste stream to be han­dled by diges­tion by years 4 and 5. A 5–11 year incin­er­a­tor con­tract wastes time that could be spent using a con­trac­tu­al process to spark the cre­ation of pri­vate diges­tion oper­a­tions to serve the Dis­trict. Cost sav­ings by using land­fills in the near-term could also be applied to devel­op­ing pub­lic diges­tion oper­a­tions for the city.

“It’s also bad for the health and pock­et­books of DC res­i­dents, and vio­lates the Civ­il Rights Act.”

Keep read­ing for details on these…

RFP Too Narrow

“The RFP was set up so that only one facil­i­ty could bid. It was restrict­ed to exist­ing incin­er­a­tors with­in 50 miles of DC’s trans­fer sta­tions. There are only four such facil­i­ties. The only one in a white com­mu­ni­ty (Mont­gomery Coun­ty) does not take out-of-coun­ty trash. Two of the oth­ers (Alexan­dria and Bal­ti­more) do not have room for the vol­ume of DC’s waste. The con­tract was rigged to keep waste flow­ing to Cov­an­ta’s Lor­ton incin­er­a­tor. Land­fills were not allowed to bid.”

The Incin­er­a­tion Request for Pro­pos­als (RFP) states on pages 8 & 10:

C.5. REQUIREMENTS
C.5.1. The Con­trac­tor shall oper­ate a licensed and per­mit­ted WTE Facil­i­ty…
C.5.1.8. The Con­trac­tor’s WTE Facil­i­ty shall have been in com­mer­cial oper­a­tion for at least 3 years and shall be locat­ed with­in a 50-mile geo­graph­ic radius (one-way haul­ing) of the Fort Tot­ten and Ben­ning Road Trans­fer Stations.

“WTE Facil­i­ty” means “waste-to-ener­gy,” which is an inac­cu­rate term for a trash incin­er­a­tor . (Trash incin­er­a­tors, even though they pro­duce some ener­gy, do not lit­er­al­ly turn trash into ener­gy, but turn it into tox­ic ash and tox­ic air emis­sions, while recov­er­ing a small frac­tion of the ener­gy that could have been con­served through recy­cling and composting.)

There are only four trash incin­er­a­tors with­in a 50 mile radius of DC’s two trans­fer stations:

State	Coun­ty	City	Own­er	Oper­a­tor	Plant Name	Size (tons/day)	Demo­graph­ics with­in 5 miles
MD	Mont­gomery	Dick­er­son	North­east MD Waste Dis­pos­al Authority	Cov­an­ta	Mont­gomery Coun­ty Resource Recov­ery Facility	1,800	78% white
MD	Bal­ti­more City	Bal­ti­more City	Whee­labra­tor	Whee­labra­tor	Whee­labra­tor Bal­ti­more (BRESCO)	2,250	68% peo­ple of color
VA	Alexan­dria City	Alexan­dria City	Cov­an­ta	Cov­an­ta	Alexandria/Arlington Resource Recov­ery Facility	975	53% peo­ple of color
VA	Fair­fax	Lor­ton	Cov­an­ta	Cov­an­ta	I-95 Energy/Resource Recov­ery Facility	3,000	54% peo­ple of col­or (72% clos­est to the plant)

Accord­ing to 2013 waste receipt data pro­vid­ed to us by the Mary­land Depart­ment of the Envi­ron­ment, Mont­gomery Coun­ty only takes waste from with­in the coun­ty (and coun­ty offi­cials con­firmed for us by phone that this is their pol­i­cy). The same data shows that the Bal­ti­more incin­er­a­tor is at 87% capac­i­ty, and that accept­ing anoth­er 200,000 tons/year of waste from DC would put them at 111% capacity.

Accord­ing to 2013 waste receipt data pro­vid­ed to us by the Vir­ginia Depart­ment of Envi­ron­men­tal Qual­i­ty, the Alexan­dria incin­er­a­tor is at 99% capac­i­ty. Adding anoth­er 200,000 tons/year of waste from DC would put them at 155% capac­i­ty. Cov­an­ta’s Fair­fax incin­er­a­tor, how­ev­er, was at 91% capac­i­ty and that includ­ed over 215,000 tons of DC waste. Con­tin­u­ing to send DC waste there would not increase their capac­i­ty, and thus this one incin­er­a­tor was the only one in a posi­tion to big on the RFP.

Eco­nom­ics

“Incin­er­a­tion is the most expen­sive way to man­age waste. DPW Direc­tor How­land admit­ted – in a 2009 email to the May­or’s office, and in sworn tes­ti­mo­ny before city coun­cil in 2012 – that truck­ing waste to south­east­ern Vir­ginia land­fills was cheap­er than dis­pos­ing of it at the incin­er­a­tor in Lor­ton, yet DPW chose to go with incin­er­a­tion in the last con­tract because of their pro-incin­er­a­tion bias.”

The incin­er­a­tor indus­try’s trade asso­ci­a­tion pres­i­dent tes­ti­fied before DC City Coun­cil in March 2013 and admit­ted that incin­er­a­tion is more expen­sive than land­fills . Oth­er indus­try-wide data shows the same.

Among DC’s options, DPW Direc­tor William How­land, answer­ing ques­tions from Trans­porta­tion and Envi­ron­ment Com­mit­tee Chair, Mary Cheh, in hear­ing on 9/28/2012:

“We nego­ti­at­ed the price with Fair­fax and you just need­ed to give us the haul­ing costs from DC to Fair­fax. There were 9 ven­dors in 2004 that bid, and 5 ven­dors that bid in 2009. All 14 bids, it was cheap­er to take it to a land­fill, which typ­i­cal­ly was as far away as Rich­mond, than it was to take it to Fair­fax County.”

In a 2009 email to the May­or’s office, How­land wrote:

Five years ago, DPW issued a solic­i­ta­tion for waste dis­pos­al. In the solic­i­ta­tion DPW asked for the ven­dors for pric­ing on two dif­fer­ent sce­nar­ios. We asked them to give us a price for dis­pos­al if the ven­dors dis­posed of the trash at any facil­i­ty of their choosing.

We also asked for a price to trans­port it to Fair­fax Coun­ty to their waste to ener­gy facil­i­ty. The price for dis­pos­al was fixed at the same cost for all of the ven­dors so the only thing we need­ed to know is what the trans­port cost would be to Fairfax.

We had three bid­ders and all three com­pa­nies bid a low­er cost to haul trash to a land­fill much fur­ther away than it would be to haul it to Fair­fax with a set dis­pos­al fee.

See full quotes and cita­tions here .

We’re not sure why How­land claims to have had 3 bid­ders in 2004 when email­ing the May­or’s office, and 9 bid­ders in the same 2004 process when tes­ti­fy­ing before City Coun­cil. Nonethe­less, he’s con­sis­tent­ly stat­ing that it’s cheap­er to haul waste to more rur­al land­fills in Vir­ginia than to incin­er­ate in Lorton.

Bias: Out­go­ing DPW Direc­tor How­land, and DPW Sol­id Waste Man­age­ment Deputy Admin­is­tra­tor Hal­lie Clemm have a rather reli­gious belief that incin­er­a­tion is prefer­able to land­fill­ing — in oppo­si­tion to the con­sen­sus among envi­ron­men­tal orga­ni­za­tions, and all avail­able data. This has been revealed in numer­ous com­mu­ni­ca­tions, includ­ing tes­ti­mo­ny before city coun­cil, state­ments in pub­lic meet­ings on DPW’s Waste Life-cycle Study, and doc­u­ments revealed in FOIA requests. Their state­ments jus­ti­fy­ing their beliefs are eas­i­ly con­tra­dict­ed by indus­try and EPA data, and some are based on bla­tant mis­rep­re­sen­ta­tions of data pre­sent­ed by pro-incin­er­a­tion con­sult­ing out­fits. For the lat­ter, see points 15–19 in our 2014 FOIA .

One of many oth­er exam­ples is when How­land tes­ti­fied before City Coun­cil in 2012, telling Chair­per­son Cheh how great the pol­lu­tion from the Cov­an­ta Fair­fax incin­er­a­tor is:

How­land: “Despite what some of the oth­er speak­ers have said, I am a lit­tle bit excit­ed about waste-to-ener­gy and I would like to explore it.…” (at 3:22:53)

Cheh: “I don’t know how mod­ern the Vir­ginia facil­i­ty is, and it may be a bad rap that con­tin­ues from the past, but what is the sense of burn­ing trash and the envi­ron­men­tal impacts?”

How­land: “That facil­i­ty was opened in 1991. At the time I was work­ing for Fair­fax Coun­ty. It was a state-of-the-art — they had extra scrub­bers on their smoke­stacks. It’s rel­a­tive­ly benign emis­sions that’s com­ing out of there. The inter­est­ing thing is they were rel­a­tive­ly expen­sive homes that were next to that facil­i­ty when it opened.”
(at 3:32:58)

-Sept 28, 2012 Waste Hearing

In fact, the facil­i­ty began oper­a­tion in March 1990, and did not have “extra scrub­bers.” The facil­i­ty has four pol­lu­tion con­trol devices, which is typ­i­cal for incin­er­a­tors around the coun­try, though 13 of the 80-some incin­er­a­tors in the U.S. have five or six devices. At the time it was built, there were at least 30 oth­er facil­i­ties with four or more devices, some oper­at­ing for well over a decade. There was noth­ing “extra” about it. Today, Cov­an­ta runs nine oth­er incin­er­a­tors with more air pol­lu­tion con­trol devices than their Fair­fax facil­i­ty. with more air pol­lu­tion con­trol devices than their Fair­fax facil­i­ty. (see the 3rd chart here )

EPA data for 2011 (lat­est avail­able; just released in March 2015) shows that these “rel­a­tive­ly benign emis­sions” make the incin­er­a­tor one of the largest pol­luters in the region, includ­ing the largest mer­cury pol­luter and sec­ond largest nitro­gen oxide (NOx) pol­luter with­in 20 miles of the Dis­trict. While they’re the 4th largest incin­er­a­tor in the U.S., their hydro­flu­o­ric acid emis­sions are the high­est in the indus­try, and their nitro­gen oxide pol­lu­tion is sec­ond high­est in the indus­try. See below for more on their envi­ron­men­tal rankings.

How­land was also wrong about the “rel­a­tive­ly expen­sive homes” being “next to the facil­i­ty.” The diverse Lor­ton Val­ley neigh­bor­hood that exists adja­cent to the facil­i­ty did­n’t exist until around 2005. At the time the incin­er­a­tor was built, DC’s pris­ons were locat­ed very close by, near the incin­er­a­tor and two land­fills. The pris­ons were closed in 2001, and the locked up peo­ple of col­or were placed by a com­mu­ni­ty of col­or that is not rel­a­tive­ly afflu­ent com­pared to the rest of Fair­fax Coun­ty. See the demo­graph­ics maps and his­to­ry spelled our in our arti­cle on DC’s Waste and Envi­ron­men­tal Racism .

Social jus­tice

“DC’s waste sys­tem is a prime exam­ple of envi­ron­men­tal racism – a doc­u­ment­ed nation­al trend. DC’s waste is first trans­ferred through black com­mu­ni­ties in Wards 5 and 7, then much of it is burned in Lor­ton, VA, which is the 12th most diverse com­mu­ni­ty of col­or in the coun­try. The Lor­ton Val­ley com­mu­ni­ty lives adja­cent to the giant incin­er­a­tor and two large land­fills (one is where the incinerator’s ash goes), and near­by a third land­fill and a sewage sludge incin­er­a­tor. It’s a vio­la­tion of the Civ­il Rights Act for fed­er­al­ly-fund­ed agen­cies, includ­ing the Dis­trict, to take actions that have a dis­crim­i­na­to­ry effect, as this RFP does.”

This is near­ly all doc­u­ment­ed in the DC’s Waste and Envi­ron­men­tal Racism article.

DC, as a fed­er­al­ly-fund­ed enti­ty, has an oblig­a­tion under Title VI of the Civ­il Rights Act to not take actions that have a dis­crim­i­na­to­ry effect on racial minor­i­ty groups. The RFP clear­ly did that by only allow­ing DC’s waste to be burned in one of three com­mu­ni­ties of col­or. This leaves the Dis­trict vul­ner­a­ble to legal com­plaints that could be filed with the U.S. Envi­ron­men­tal Pro­tec­tion Agen­cy’s Office of Civ­il Rights.

Health

“DC has high asth­ma rates. Accord­ing to the CDC, DC’s adult life­time asth­ma preva­lence was 16.2%, while the nation­al rate is 13.3%. The age-adjust­ed asth­ma hos­pi­tal­iza­tion rate in the Dis­trict of Colum­bia was 267.1 per 100,000 per­sons com­pared with the U.S. rate of 144 per 100,000 per­sons. With­in 20 miles of DC, Cov­an­ta’s Lor­ton incin­er­a­tor is sec­ond only to Dulles Air­port in emis­sions of nitro­gen oxides (NOx), the air pol­lu­tants that aggra­vate asth­ma. Cov­an­ta’s Alexan­dria incin­er­a­tor is also in the top five in the DC area. DC’s waste dis­pos­al should not be help­ing dri­ve DC’s high asth­ma rates.”

See CDC fact­sheet on asth­ma in DC (first chart on each page).

Nitro­gen oxides are one of the main pol­lu­tants strong­ly asso­ci­at­ed with aggra­vat­ing asth­ma as are sev­er­al oth­er pol­lu­tants asso­ci­at­ed with Cov­an­ta’s facil­i­ty (acid gas­es, air pol­lu­tion in gen­er­al, ammo­nia, diesel exhaust, par­tic­u­late air pol­lu­tion and sul­fur dioxides). 

Emis­sions data is from EPA’s EPA’s Nation­al Emis­sions Inven­to­ry , which comes out every three years (2011 data just came out in March 2015). The same rank­ings exist­ed in 2008 , except #3 and 4 were switched.

The top nitro­gen oxide (NOx) emit­ters with­in 20 miles of DC are:

Pol­lu­tion Source	NOx Emis­sions (tons)
	2011	2008
1) Dulles Airport	1,895	2,079
2) Cov­an­ta Fair­fax trash incinerator	1,613	1,689
3) DCA — Nation­al Airport	1,311	1,232
4) Transcon­ti­nen­tal Gas Pipeline in Howard County	1,270	1,271
5) Cov­an­ta Alexandria/Arlington trash incinerator	471	577

If we includ­ed a look at pol­luters between 20 and 30 miles from DC, there are four coal pow­er plants that are all worse than Dulles Air­port, though two are slat­ed to close in 2017. Two oth­er trash incin­er­a­tors (in Mont­gomery Coun­ty, MD and in Bal­ti­more), BWI Air­port, and the now-closed coal plant in Alexan­dria were also high pol­luters in 2011, not as bad as Cov­an­ta’s Fair­fax incin­er­a­tor, but worse than Cov­an­ta’s small­er incin­er­a­tor in Alexan­dria. Clear­ly, trash incin­er­a­tors are among the worst pol­luters out there, in line with air­ports and coal pow­er plants, though coal plants are gen­er­al­ly on their way out.

In the entire trash incin­er­a­tor indus­try in the U.S. (87 facil­i­ties), Cov­an­ta Fair­fax’s NOx emis­sions are sec­ond only to the incin­er­a­tor in Detroit (which Cov­an­ta ran for a time), which is the 2nd largest incin­er­a­tor in the nation and oper­ates with­out any NOx emis­sions con­trols. Cov­an­ta Fair­fax’s NOx emis­sions are even high­er than the largest trash incin­er­a­tor in the nation, which Cov­an­ta runs in Chester, PA with­out any NOx pol­lu­tion con­trols. The Cov­an­ta Fair­fax incin­er­a­tor in Lor­ton is the 4th largest in the nation and has pol­lu­tion con­trols to remove NOx. These emis­sions rank­ings are the same in EPA’s Nation­al Emis­sions Inven­to­ries in both 2008 and 2011.

Too dirty for New Jer­sey?? In fact, Cov­an­ta Fair­fax has NOx emis­sions so high that the Board of Pub­lic Util­i­ties in Cov­an­ta’s home state of New Jer­sey barred this spe­cif­ic incin­er­a­tor from being able to sell renew­able ener­gy cred­its into NJ’s renew­able ener­gy pro­gram, because it does­n’t com­ply with NJ stan­dards (for NOx pol­lu­tion and for ash test­ing), even though trash incin­er­a­tors in NJ, PA and MD are eligible.

“Oth­er health prob­lems are exac­er­bat­ed by the fact that this incin­er­a­tor is the largest emit­ter of Hydro­flu­o­ric Acid in their entire indus­try, is the largest source of mer­cury pol­lu­tion with­in 20 miles of DC, is in the top five sources of sul­fur diox­ides with­in 20 miles, and is a large source of volatile organ­ic com­pounds (VOCs).”

Hydro­flu­o­ric Acid (hydro­gen flu­o­ride): Accord­ing to EPA, “[c]hronic inhala­tion expo­sure of humans to hydro­gen flu­o­ride has result­ed in irri­ta­tion and con­ges­tion of the nose, throat, and bronchi at low lev­els.” ( source ).

Cov­an­ta did­n’t report their Hydro­flu­o­ric Acid (HF) emis­sions to EPA’s 2011 Nation­al Emis­sions Inven­to­ry, but report­ed it in 2008. Their 2008 HF emis­sions were 60% high­er than the high­est HF-emit­ting incin­er­a­tor in 2011, so they’d also be #1 in 2011.

Loca­tion	Incin­er­a­tor	2008 Hydro­flu­o­ric Acid Emis­sions (lbs)
Lor­ton, VA	Cov­an­ta Fair­fax Inc	5,084
Bal­ti­more, MD	Whee­labra­tor Bal­ti­more, LP (BRESCO)	4,399
Long Beach, CA	Long Beach City, SERRF Project	3,178
Portsmouth, VA	SPSA Refuse Derived Fuel Plant	2,539
East North­port, NY	Hunt­ing­ton Resource Recov­ery Facility	2,179
Ft. Laud­erdale, FL	Whee­labra­tor South Broward, Inc.	1,899

Mer­cury: One of the most tox­ic met­als, inhal­ing mer­cury vapor can harm the ner­vous, diges­tive and immune sys­tems, lungs and kid­neys, and can con­tribute to neu­ro­log­i­cal and behav­ioral disorders.

Accord­ing to EPA’s Nation­al Emis­sions Inven­to­ry, Cov­an­ta is the largest source of mer­cury pol­lu­tion with­in 20 miles of DC, by far, account­ing for more than three times all oth­er sources combined:

Pol­lu­tion Source	2011 Mer­cury Emis­sions (lbs)
1) Cov­an­ta Fair­fax trash incinerator	18.11
2) Naval Sup­port Facil­i­ty, Indi­an Head	2.27
3) Cov­an­ta Alexandria/Arlington trash incinerator	1.46
[remain­ing 40-some sources combined]	2.28

[No mer­cury data is avail­able for any facil­i­ties in the 2008 database.]

Sul­fur diox­ide (SO2) is a major air pol­lu­tant. EPA warns that SO2 caus­es “an array of adverse res­pi­ra­to­ry effects includ­ing bron­chocon­stric­tion and increased asth­ma symp­toms,” and that “[t]hese effects are par­tic­u­lar­ly impor­tant for asth­mat­ics at ele­vat­ed ven­ti­la­tion rates (e.g., while exer­cis­ing or play­ing.)” They go on to say that “[s]tudies also show a con­nec­tion between short-term expo­sure and increased vis­its to emer­gency depart­ments and hos­pi­tal admis­sions for res­pi­ra­to­ry ill­ness­es, par­tic­u­lar­ly in at-risk pop­u­la­tions includ­ing chil­dren, the elder­ly, and asthmatics.”

Accord­ing to same EPA’s Nation­al Emis­sions Inven­to­ry data, Cov­an­ta is the fourth largest source of sul­fur diox­ide pol­lu­tion with­in 20 miles of DC, both in 2008 and 2011:

Pol­lu­tion Source	SO2 Emis­sions (tons)
	2011	2008
Naval Sup­port Facil­i­ty, Indi­an Head	510	16
Dulles Air­port	193	173
DCA — Nation­al Airport	159	126
Cov­an­ta Fair­fax trash incinerator	90	92
U.S. Capi­tol Pow­er Plant	46	241

The Indi­an Head Navy base jumped up to be the largest SO2 source in 2011 while the Capi­tol Pow­er Plant fell from first place to 5th between 2008 and 2011, most like­ly due to reduced coal burn­ing, but the Cov­an­ta Fair­fax incin­er­a­tor remains the 4th largest source.

EPA’s Nation­al Emis­sions Inven­to­ry data shows that they’re a large source of oth­er tox­ic pol­lu­tants, includ­ing lead and volatile organ­ic com­pounds (VOCs):

Pol­lu­tant	Emis­sions (lbs)
	2011	2008
Lead	58	89
Par­tic­u­late Mat­ter (PM10)	6,892	46,264
Volatile Organ­ic Com­pounds (VOCs)	23,764	8,026

Envi­ron­ment

“Incin­er­a­tors do not avoid land­fills. They just make for small­er, more tox­ic, land­fills. The Cov­an­ta incin­er­a­tor Lor­ton dumps their tox­ic ash in an old Fair­fax Coun­ty land­fill adja­cent to the incin­er­a­tor. For every 100 tons of trash burned, 30 tons of ash remain. The rest went into the air. Land­fills are a prob­lem, but incin­er­a­tion just makes the pol­lu­tion prob­lem worse, cre­at­ing new tox­ins in the com­bus­tion process and con­cen­trat­ing what doesn’t end up in the air, into the ash sent to land­fills, where it can still leach and harm groundwater.”

Incin­er­a­tors are 7 times more air pol­lut­ing than land­fills over­all, and hun­dreds of times worse on mer­cury. They’re 30 times worse on nitro­gen oxide pol­lu­tion, 20 times worse on hydrochlo­ric acid emis­sions and 13 times worse on sul­fur diox­ides. On volatile organ­ic com­pounds (VOCs), land­fills are worse. On par­tic­u­late mat­ter (PM), they’re more com­pa­ra­ble, but incin­er­a­tors are worse on 4 out of 5 types of PM, and are pret­ty close on the 5th type. This is based on the lat­est EPA Nation­al Emis­sions Inven­to­ry data (for 2008 and 2011) for Vir­ginia, Mary­land, Penn­syl­va­nia and Michigan.

Even if you account for the pol­lu­tion from truck­ing waste fur­ther, to more rur­al land­fills in south­east­ern Vir­ginia, incin­er­a­tion releas­es 2.7 to 3.5 times as much pol­lu­tion per ton of waste as land­fill­ing (with the extra truck­ing) does. These land­fills are 42 to 121 extra trav­el miles away, past Lor­ton (one-way): King George Land­fill (42 miles); King & Queen Land­fill (113 miles); Mid­dle Penin­su­la Land­fill (121 miles). DPW loves to obsess of over truck­ing impacts — to the point of pre­fer­ring to not even have peo­ple sep­a­rate recy­clables from trash, as if the sep­a­rate recy­cling truck trips are worse than not recy­cling at all. How­ev­er, they lose this argu­ment, as the exhaust from incin­er­a­tors far out­weighs the emis­sions from extra truck­ing miles.

Trash incin­er­a­tion is dirt­i­er than coal burn­ing. To make the same amount of ener­gy as a coal pow­er plant, trash incin­er­a­tors release 28 times as much diox­in than coal, 2.5 times as much car­bon diox­ide (CO2), twice as much car­bon monox­ide, three times as much nitro­gen oxides (NOx), 6–14 times as much mer­cury, near­ly six times as much lead and 70% more sul­fur diox­ides. See doc­u­men­ta­tion here.

“Cov­an­ta’s track record

Cov­an­ta has an exten­sive track record of vio­la­tions at their facil­i­ties across the coun­try. Many are for air pol­lu­tion vio­la­tions. They were even once caught and fined for tam­per­ing with their emis­sions mon­i­tors to make it seem like their emis­sions are low­er than they real­ly are.”

See the 93 pages of Cov­an­ta’s vio­la­tions around the U.S. through Sept 13th, 2006 . The 3rd vio­la­tion on page 37 shows where they were once caught fraud­u­lent­ly adjust­ing their emis­sions monitors.

“Waste-to-ener­gy” and “ener­gy from waste” = Incineration

“Cov­an­ta’s facil­i­ties are defined and reg­u­lat­ed as trash incin­er­a­tors (“munic­i­pal waste com­bus­tors” in EPA lan­guage). The fact that they gen­er­ate small amounts of elec­tric­i­ty has no bear­ing on whether they are incin­er­a­tors. How­ev­er, the indus­try has a (well-deserved) ter­ri­ble rep­u­ta­tion, as incin­er­a­tion is one of the most unpop­u­lar tech­nolo­gies there is. For that rea­son, Cov­an­ta and oth­ers avoid the ‘i’ word and insist that they’re not incin­er­a­tors, choos­ing inac­cu­rate PR terms instead. Waste isn’t actu­al­ly turned into ener­gy, but into tox­ic ash and tox­ic air emis­sions. Three to five times more ener­gy is saved by recy­cling and com­post­ing dis­card­ed mate­ri­als than can be cre­at­ed by burn­ing them. In essence, these are “waste-OF-ener­gy” facilities.”

See Incin­er­a­tors are NOT “waste-to-ener­gy” facil­i­ties for a good overview on the topic.

The 3–5 times fig­ure is from p. 282 in the only study we know of on the top­ic: Jef­frey Mor­ris, “Recy­cling Ver­sus Incin­er­a­tion: An Ener­gy Con­ser­va­tion Analy­sis,” Jour­nal of Haz­ardous Mate­ri­als, Vol 47, Issues 1–3, pp. 277–293 (1996). http://www.sciencedirect.com/science/article/pii/0304389495001166

“What Should be Done: Let the Cov­an­ta con­tract die so that DPW can extend the cur­rent con­tract on a 1‑year basis, allow­ing time to prop­er­ly rebid for a short­er term con­tract allow­ing land­fills and digesters to bid, and mov­ing toward zero waste

“In pass­ing the Sus­tain­able Sol­id Waste Man­age­ment Amend­ment Act of 2014, city coun­cil man­dat­ed that the Dis­trict come up with a zero waste plan, out­lin­ing steps the Dis­trict can take to achieve at least an 80% waste diver­sion rate – divert­ing waste from both incin­er­a­tors and land­fills. Rather than con­tin­ue to use both, and lock in con­tracts for 5 to 11 years, city coun­cil ought to reject the Cov­an­ta con­tract (or let it die, unin­tro­duced), extend the cur­rent Cov­an­ta con­tract on a short-term basis (no more than a year), and request that DPW issue a 1‑year RFP that is open to all bid­ders that can han­dle DC’s waste (includ­ing land­fills and digesters, not just incin­er­a­tors). This will buy some time to allow DPW to then start work­ing toward con­tracts that reflect the zero waste goal. For what­ev­er waste can­not be reduced, reused, recy­cled or com­post­ed, the “back end” con­tracts ought to require that waste be anaer­o­bi­cal­ly digest­ed before land­fill­ing, avoid­ing gassy, stinky land­fills, and help­ing the city meet its goals regard­ing cli­mate change.”

DPW is search­ing for a new direc­tor who will hope­ful­ly take the agen­cy’s sol­id waste and recy­cling efforts in a more pro­gres­sive direc­tion , since DC’s recy­cling rate lags behind many oth­er cities . DDOE is also hir­ing new staff to address DC’s waste and waste reduc­tion efforts. The Sus­tain­able Sol­id Waste Man­age­ment Amend­ment Act of 2014 passed by coun­cil last sum­mer calls for a zero waste plan to be informed by an Inter­a­gency Waste Reduc­tion Work­ing Group that has yet to be formed, and which would include these new DDOE staff. Please don’t tie the hands of the new head of DPW, new DDOE staff and the work­ing group by lock­ing in a 5–11 year con­tract for the most expen­sive and pol­lu­tion option.

To address the back end of the waste sys­tem prop­er­ly, one must fol­low the back end of the zero waste hier­ar­chy with anaer­o­bic diges­tion to sta­bi­lize resid­u­als before land­fill­ing, which could be done more cheap­ly than incin­er­a­tion, and with the weigh reduc­tion pri­or to haul­ing (not to men­tion renew­able ener­gy cred­it sales), can prob­a­bly be done cheap­er than direct land­fill­ing as well. See the report: What is the best dis­pos­al option for the “Left­overs” on the way to Zero Waste? Also, see the back end of the detailed zero waste hier­ar­chy.

“There are sev­er­al land­fills that could bid. The remain­der of DC’s waste cur­rent­ly goes to land­fills in much more rur­al areas in south­east­ern Vir­ginia, affect­ing far few­er peo­ple (1,500 to 4,500 peo­ple with­in 5 miles of the land­fills, com­pared to 103,000 peo­ple liv­ing with­in five miles of the Lor­ton incinerator).”

Here are the pop­u­la­tions around the Cov­an­ta Fair­fax incin­er­a­tor vs. the south­east­ern VA land­fills that also take DC waste:

The real­i­ty of it is that the incin­er­a­tor releas­es far more pol­lu­tion (7 times more than land­fills) at a much high­er alti­tude (note the tall stack in the pic­ture), spread­ing that greater amount of pol­lu­tion across many more peo­ple, not just those with­in 5 miles, but over the entire DC Metro region, affect­ing mil­lions of peo­ple (there are 2.4 mil­lion peo­ple with­in 25 miles of the incinerator).