Ending Waste Incineration in Montgomery County, PA

The Covanta Plymouth trash incinerator is Montgomery County’s #1 Air Polluter

Mont­gomery Coun­ty recent­ly received an “F” grade from the Amer­i­can Lung Asso­ci­a­tion for smog in their 2019 State of the Air report. The Asth­ma and Aller­gy Foun­da­tion ranked the Philadel­phia metro area as the 4th worst place for asth­ma. This is, in part, due to the huge amounts of nitro­gen oxide (NOx) air pol­lu­tion released from Cov­an­ta Ply­mouth and oth­er major pol­luters in the area. In the whole 5‑county Philadel­phia area, three of the four largest NOx pol­luters are trash incin­er­a­tors: Cov­an­ta Delaware Val­ley (in Chester City), Cov­an­ta Ply­mouth, and Whee­labra­tor Falls in Bucks County.

Because of the air pol­lu­tion and health con­cerns, 41 orga­ni­za­tions, includ­ing all of the major envi­ron­men­tal orga­ni­za­tions, wrote to Philadelphia’s may­or ask­ing that they not con­tin­ue to con­tract to burn the city’s trash in Cov­an­ta Ply­mouth and oth­er incinerators.

In 2017, accord­ing to data report­ed to the state DEP on indus­tri­al sources of air pollution:

Covanta Plymouth released:

421,828	TONS of green­house gas­es (CO2 equivalents)
1,320,940	pounds of Nitro­gen Oxides (NOx)
114,420	pounds of Car­bon Monox­ide (CO)
102,800	pounds of Hydrochlo­ric Acid
70,360	pounds of Sul­fur Oxides (SOx)
16,741	pounds of Par­tic­u­late Mat­ter (PM10)
16,293	pounds of Fine Par­tic­u­late Mat­ter (PM2.5)
5,852	pounds of Ammonia
3,630	pounds of Volatile Organ­ic Com­pounds (VOCs)
5.8	pounds of Nickel
4.0	pounds of Lead
3.2	pounds of Chromium
1.4	pounds of Mercury
0.4	pounds of Arsenic
0.4	pounds of Cadmium

To put the small­er num­bers in per­spec­tive, mer­cury is one of the tox­ic pol­lu­tants for which there is no known safe lev­el of expo­sure. Lead is also known not to have any “safe” lev­el. The incin­er­a­tor report­ed releas­ing 1.4 lbs of mer­cury into the air in 2017, not count­ing that which gets into the air and water via the ash. Mer­cury is incred­i­bly tox­ic. A high­ly cit­ed Min­neso­ta study found that if approx­i­mate­ly one gram of mer­cury (the amount in a sin­gle fever ther­mome­ter) is deposit­ed to a 20-acre lake each year from the atmos­phere, this small amount, over time, can con­t­a­m­i­nate the fish in that lake to the point where they should not be eat­en. 1.4 pounds of mer­cury equals 635 grams. That means the incin­er­a­tor, in a typ­i­cal year, is releas­ing enough mer­cury suf­fi­cient to keep over 600 20-acre lakes so con­t­a­m­i­nat­ed that the fish are not safe to eat.

In terms of rank­ings, Cov­an­ta Ply­mouth is the largest air pol­luter in Mont­gomery Coun­ty, respon­si­ble for 36% of the coun­ty’s indus­tri­al air pol­lu­tion. On spe­cif­ic pol­lu­tants, it’s #1 in car­bon diox­ide (36% of the total), hydrochlo­ric acid (96%), nitro­gen oxides (55%), and sul­fur diox­ides (28%). It’s #2 in mer­cury (16%) only because a sewage sludge incin­er­a­tor in Hat­field is #1. It’s also #2 in con­dens­able par­tic­u­late matter.

What does this cost to human health? A 2017 study from the New York Uni­ver­si­ty School of Med­i­cine found that just one pol­lu­tant (fine par­tic­u­late mat­ter) from the trash incin­er­a­tor in Bal­ti­more is caus­ing $55 mil­lion in annu­al health costs to res­i­dents in sev­er­al states includ­ing Penn­syl­va­nia. Fine par­tic­u­late mat­ter (PM2.5) is asso­ci­at­ed with pre­ma­ture death, heart dis­ease, chron­ic bron­chi­tis, and oth­er res­pi­ra­to­ry dis­tress. The PM2.5 emis­sions from Cov­an­ta Ply­mouth are 43% that of the larg­er Bal­ti­more incin­er­a­tor. With­out fac­tor­ing in the largest pop­u­la­tion in the Philly area (which would increase this num­ber), this would trans­late to over $23 mil­lion in annu­al health dam­age due to just one pol­lu­tant com­ing out of Cov­an­ta Ply­mouth — and this is based on their report­ed 2017 emis­sions before they start­ed hav­ing rou­tine mal­func­tions in late 2018.

Covanta’s violations

Scroll to the bot­tom of these links to see their lat­est air, waste, and water vio­la­tions issued by the PA Depart­ment of Envi­ron­men­tal Protection.

Com­pa­ny-wide, Cov­an­ta is a noto­ri­ous vio­la­tor. See Cov­an­ta’s vio­la­tions through Sep­tem­ber 2006 — a 93-page doc­u­ment filed by Cov­an­ta with the Penn­syl­va­nia Depart­ment of Envi­ron­men­tal Pro­tec­tion, out­lin­ing their vio­la­tions, com­pa­ny-wide. Note on page 37 where Cov­an­ta lists being bust­ed by the state of Con­necti­cut for tam­per­ing with their con­tin­u­ous emis­sions mon­i­tor­ing sys­tem to make it seem as if their emis­sions are low­er than they real­ly are.

See Cov­an­ta’s more recent vio­la­tions (through June 2018). Cov­an­ta Ply­mouth’s vio­la­tions are on page 37.

Sim­i­lar to their Con­necti­cut vio­la­tion for tam­per­ing with their emis­sions mon­i­tors, Cov­an­ta was bust­ed in more recent years at their Tul­sa, Okla­homa incin­er­a­tor. This is from their 10K fil­ing with the Secu­ri­ties and Exchange Com­mis­sion:

Tul­sa Mat­ter. In Jan­u­ary 2016, we were informed by the Unit­ed States Attorney’s Office for the North­ern Dis­trict of Okla­homa (“US Attorney’s Office”) that our sub­sidiary, Cov­an­ta Tul­sa Renew­able Ener­gy LLC (“Cov­an­ta Tul­sa”), was the tar­get of a crim­i­nal inves­ti­ga­tion being con­duct­ed by the EPA. The inves­ti­ga­tion relat­ed to alleged impro­pri­eties in the record­ing and report­ing of emis­sions data dur­ing an Octo­ber 2013 inci­dent involv­ing one of the three munic­i­pal waste com­bus­tion units at our Tul­sa, Okla­homa facil­i­ty. In Octo­ber 2018, Cov­an­ta Tul­sa entered into a Non Pros­e­cu­tion Agree­ment (“NPA”) with the US Attorney’s Office, pur­suant to which no charges will be filed if, for a peri­od of one year, Cov­an­ta Tul­sa sat­is­fies the require­ments of the NPA, includ­ing that it com­ply with applic­a­ble laws and reg­u­la­tions. As part of the NPA, Cov­an­ta Tul­sa also made a $200,000 com­mu­ni­ty ser­vice pay­ment to the Okla­homa Depart­ment of Envi­ron­men­tal Qual­i­ty to fund air qual­i­ty and envi­ron­men­tal efforts in Oklahoma.

Where does Covanta Plymouth’s waste come from?

Munic­i­pal­i­ty	Con­tract is with [links to con­tracts]	$/ton (2019) [links to fees]	Up for Renew­al	Expires	Notes
Abing­ton Township
Ambler Bor­ough	Cov­an­ta 4 Recov­ery, L.P.	$58.45	12/31/2019	12/31/2022
Bryn Athyn Borough	Waste Man­age­ment	$48.90		12/31/2022	“Bor­ough of Bryn Athyn has not signed a con­tract with Cov­an­ta for waste dis­pos­al. “Bryn Athyn Bor­ough is pig­gy­back­ing on the Low­er More­land con­tracts and intends to con­tin­ue this arrange­ment into the next contract.”
Chel­tenham Township	Cov­an­ta 4Recovery, L.P.	$58.45 ($89.98 includ­ing hauling)		12/31/2019	See memo, fees and pay­ments. Orig­i­nal­ly told us: “We are in a con­sor­tium con­tract with sev­er­al town­ships. Upper Dublin Town­ship coor­di­nates the con­tracts with Cov­an­ta on all our behalfes”
Con­shohock­en Borough	Cov­an­ta	$58.50	12/31/2019	12/31/2024; 12/31/2029	In com­bined bid with West Con­shohock­en Bor­ough and Ply­mouth Town­ship. Vot­ed on Nov. 20th to con­tin­ue Cov­an­ta con­tract for anoth­er two years.
East Nor­ri­ton Township	[Does not pro­vide waste services]				Infor­ma­tion does not exist.; “The Twp does not pro­vide waste dis­pos­al services.”
Hat­boro Borough	Cov­an­ta 4Recovery, L.P.	$70.48 — $76.97 (depend­ing on haul­ing distance)	12/31/2019	12/31/2022	Bor­ough hauls to Abing­ton Trans­fer Sta­tion. See also Nov 2019 bids from Waste Man­age­ment ($88/ton), Repub­lic ($85/ton), and Mas­caro ($107+/ton), Cov­an­ta’s 2014 pro­pos­al, pay­ments, and bond­ing documents.
Hor­sham Township	[Does not pro­vide waste services]				Town­ship itself (for pub­lic build­ings and such) has con­tract with Advanced Dis­pos­al for reg­u­lar trash and Repub­lic Ser­vices for recycling.
Jenk­in­town Borough	BFI Waste Ser­vices of Penn­syl­va­nia, LLC	(Flat con­tract price regard­less of volume)		4/1/2020
Low­er Meri­on Township	Cov­an­ta 4Recovery, L.P.	$69.01		12/31/2019	Town­ship pay­ments to Covanta
Low­er More­land Township	Waste Man­age­ment	$48.90		12/31/2022	“Low­er More­land Town­ship does not have… a cur­rent con­tract with Cov­an­ta or their relat­ed com­pa­nies.”; “When the for­mer mem­bers of that waste con­sor­tium solicit­ed bid pric­ing, Low­er More­land received low­er tip­ping fee bids from Waste Man­age­ment so they have been our dis­pos­al con­trac­tor since then.”
Nar­berth Borough	Low­er Meri­on Twp trans­fer sta­tion (Cov­an­ta)	$73.15	12/31/2019	12/31/2020 (and annually)	See also 2019 Q1 and Q2 pay­ments and Cov­an­ta let­ter.
Nor­ris­town Borough	Mas­caro (trash and recycling)		3/31/2020	3/31/2022	See pro­pos­al.
Ply­mouth Township	Cov­an­ta 4Recovery (Exhib­it “B” missing.)	$58.50	12/31/2021	12/31/2024; 12/31/2029	In com­bined bid with Con­shohock­en Bor­ough and West Con­shohock­en Bor­ough. On 11/11/2019, the Town­ship vot­ed 3–1 to extend the Cov­an­ta con­tract for two years until the end of 2021. See also Agree­ment to hire Curtin & Heefer LLP law firm.
Rock­ledge Borough	Waste Man­age­ment	$45.78		12/31/2022	“When the waste con­sor­tium dis­band­ed all of those con­sor­tiums put their waste dis­pos­al out to bid and each munic­i­pal­i­ty received bids from sev­er­al com­pa­nies. Our waste dis­pos­al con­tract is cur­rent­ly with Waste Man­age­ment and we pay $45.78/ton. We are in year 5 of a 5‑year con­tract and have opt­ed to stay with them for the 3 year con­tract exten­sion — year 1: 46.70/ton; year 2: $47.63/ton; year 3: $48.58/ton. Waste Man­age­ment was the low bid­der with Cov­an­ta bid­ding: Year 1: $79.35/ton Year 2: $81.19/ton Year 3: $83.08/ton Year 4: $85.01/ton Year 5: $86.98/ton”
Roy­ers­ford Borough	Cov­an­ta Ply­mouth Renew­able Ener­gy LP			12/31/2019	See 2020 request for bids and 2014 arti­cle about cur­rent contract.
Spring­field Township	Cov­an­ta 4Recovery, L.P.	$58.45	12/31/2019	12/31/2022	See pay­ments.
Upper Dublin Township	Cov­an­ta Sus­tain­able Solu­tions, LLC; pri­or was with Cov­an­ta 4 Recov­ery, L.P.	$61.39	1/31/2020 (already extend­ed to 2022?)	1/31/2022	See also fee and ton­nage data, and old­er dis­pos­al agreement.
Upper Meri­on Township	[Does not pro­vide waste services]				Town­ship has a con­tract with Waste Man­age­ment for trash and recy­cling at the Town­ship’s facilities.
Upper More­land Township	Cov­an­ta 4Recovery, L.P.	$55.20	12/31/2019	12/31/2022	See pay­ments.
West Con­shohock­en Borough	Cov­an­ta 4Recovery	$58.50	12/31/2019	12/31/2021; 12/31/2029	In com­bined bid with Con­shohock­en Bor­ough and Ply­mouth Town­ship. On 11/12/2019, Bor­ough Coun­cil vot­ed to extend the Cov­an­ta con­tract for two years until the end of 2021. Addi­tion­al exten­sions through 2029 are possible.
Whitemarsh Town­ship	Delay­ing until 11/22, but we got the doc­u­ments through an ear­li­er requestor.	Cov­an­ta 4 Recov­ery, L.P. (dis­pos­al con­tract) & J.P. Mas­caro & Sons (haul­ing contract)	$58.45 (Cov­an­ta); $66.48 / unit (Mas­caro)	12/31/2019	Vote on 11/14/2019 to end rela­tion­ship with Cov­an­ta and pay an extra $1/week per house­hold to sign a new con­tract with Mas­caro to haul to their own trans­fer sta­tion and land­fill, avoid­ing incin­er­a­tion out of con­cern for pub­lic health. It’ll be $249/household for a 3‑year con­tract with two poten­tial 1‑year extensions.
Whit­pain Township	[Does not pro­vide waste services]				“Whit­pain allows res­i­dents to select and con­tract with the trash hauler that best meets their needs. The Town­ship does not offer trash col­lec­tion as a munic­i­pal ser­vice and we do not man­date that res­i­dents select a sin­gle Town­ship-approved hauler.”

Incineration is more expensive.

This is true gen­er­al­ly, and is admit­ted by three waste indus­try asso­ci­a­tions.

In East­ern Mont­gomery Coun­ty, based on the con­tract data sup­plied so far (above), the aver­age incin­er­a­tor con­tract in 2019 is $63.02/ton. The aver­age land­fill con­tract is $47.86/ton. In the map below, incin­er­a­tor con­tracts are in dark­er grey with red prices. Land­fills are lighter grey with brown prices. Every land­fill price is under $50/ton while every incin­er­a­tor price is over that.

Incinerators are worse than landfills, even for the climate

Trash incin­er­a­tion is the most expen­sive and pol­lut­ing way to man­age waste or to make ener­gy. It’s dirt­i­er than coal burn­ing and worse than direct­ly using land­fills. The data backs up the unan­i­mous opin­ion of the envi­ron­men­tal com­mu­ni­ty in oppos­ing incin­er­a­tion and rec­og­niz­ing that it’s worse than land­fills. Incin­er­a­tion doesn’t avoid land­fill­ing. It puts over 70% of the waste into the air as air pol­lu­tion (all that escapes air pol­lu­tion con­trols), and the 30% that remains (includ­ing the por­tion caught in pol­lu­tion con­trols) con­sists of tox­ic ash that is shipped to land­fills in Chester and Berks Coun­ties. Please see this fact­sheet explain­ing why incin­er­a­tion (and ash land­fill­ing) is worse than direct use of land­fills. Land­fills are not good and no one is advo­cat­ing for them, but we need to be hon­est about the fact that incin­er­a­tion only makes land­fills more tox­ic, and pol­lutes the air far worse.

There are alternatives

Penn­syl­va­nia has plen­ty of land­fill capac­i­ty – Penn­syl­va­nia has a glut of land­fill space. With 43 land­fills and six trash incin­er­a­tors, Penn­syl­va­nia has too much waste dis­pos­al capac­i­ty, which is why the state has been the #1 importer of trash for the past three decades since this was first doc­u­ment­ed. Penn­syl­va­nia has been import­ing trash from Cana­da down through Puer­to Rico, and every state in-between. There are 13 active land­fills with­in two coun­ties’ dis­tance, with a glut of land­fill capac­i­ty avail­able. They are:

Bucks Coun­ty: Fair­less Land­fill
Chester Coun­ty: SECCRA Land­fill
Northamp­ton Coun­ty: IESI PA Beth­le­hem Land­fill, Chrin Broth­ers San­i­tary Land­fill, and Grand Cen­tral San­i­tary Land­fill
Berks Coun­ty: Con­esto­ga Land­fill, Rolling Hills Land­fill, Pio­neer Cross­ing Land­fill, West­ern Berks Land­fill
Lan­cast­er Coun­ty: Lan­ches­ter Land­fill, LCSWMA Frey Farm Land­fill
Schuylkill Coun­ty: Com­mon­wealth Envi­ron­men­tal Sys­tems
Lebanon Coun­ty: Greater Lebanon Refuse Author­i­ty Landfill

The two bold­faced land­fills are where trash is trucked in the form of ash from the Cov­an­ta Ply­mouth incinerator.

Truck­ing dis­tance is not an issue – East­ern Mont­gomery munci­pal­i­ties don’t need to truck waste direct­ly to these land­fills in the area. Munic­i­pal­i­ties can con­tract with haulers to use any of the three trans­fer sta­tions in the Ply­mouth Meet­ing area, and con­tracts can ensure that waste will not go to any incin­er­a­tors, per­mit­ting only direct land­fill use.

Con­cern about emis­sions from truck­ing to land­fills does not jus­ti­fy burn­ing trash clos­er to home. A life cycle analy­sis of waste dis­pos­al options for Wash­ing­ton, DC found that incin­er­a­tion is far more pol­lut­ing than land­fill­ing, even if hav­ing to truck waste five times as far to land­fills 130 miles away. Truck­ing emis­sions are insignif­i­cant com­pared to the extreme amount of pol­lu­tion emit­ted by incineration.

There are three com­pa­nies with trans­fer sta­tions in the area which don’t rely on incin­er­a­tion. A “land­fill only” con­tract could be entered with any of these com­pa­nies that pri­mar­i­ly do not use incineration.

Waste Man­age­ment — Nor­ris­town
310 W Wash­ing­ton St, Nor­ris­town, PA 19401 (3 mi)
855–389-8047
www.wm.com

Repub­lic Ser­vices Riv­er Road Trans­fer Sta­tion
400 Riv­er Rd, Con­shohock­en, PA 19428 (4 mi)
610–275-6767
www.republicservices.com/customer-support/facilities#transfer-stations

J.P Mas­caro & Son’s
DeKalb Pike, Bridge­port, PA 19405 (4 mi)
610–272-7100
www.jpmascaro.com/our-facilities/bridgeport-transfer.aspx

Waste and recy­cling con­tracts should…

It’s impor­tant that waste con­tracts avoid incin­er­a­tion and pro­tect the munic­i­pal­i­ty from unnec­es­sary costs. New Requests for Pro­pos­als for waste col­lec­tion or recy­cling should:

• Solic­it bids from at least the three local trans­fer sta­tions list­ed above.
• Do not allow “put or pay” claus­es that have any sort of guar­an­teed min­i­mum amount of waste. Because incin­er­a­tors require a cer­tain amount of waste to stay in oper­a­tions (unlike land­fills), their con­tracts often con­tain a min­i­mum amount of waste that must be pro­vid­ed, or the munic­i­pal­i­ty must pay any­way. These “put or pay” claus­es in incin­er­a­tor con­tracts have bank­rupt­ed towns and cities. Cur­rent­ly, Bal­ti­more Coun­ty, MD is being sued for $32 mil­lion for not pro­vid­ing enough trash to the Whee­labra­tor Bal­ti­more incin­er­a­tor. In 2015, Wash­ing­ton, DC signed a 5–11 year con­tract with Cov­an­ta that has no min­i­mum required amount of waste. “Put or pay” claus­es dis­cour­age waste reduc­tion, recy­cling, and com­post­ing because the munic­i­pal­i­ty is penal­ized by hav­ing to pay any­way if they fall below the min­i­mum amount of waste promised. Sim­i­lar­ly, don’t sign con­tracts with flat costs that are not in dol­lars per ton.
• Ensure that any waste facil­i­ties must fol­low the law. Fail­ure to fol­low all fed­er­al, state, and local envi­ron­men­tal laws and reg­u­la­tions should be grounds for breach of contract.
• Pro­hib­it incin­er­a­tion. This should be spelled out to pro­hib­it use of any munic­i­pal waste com­bus­tor (trash incin­er­a­tor), or any refuse-derived fuel (a.k.a. Spec­Fu­el, or Processed Engi­neered Fuel) that involves mar­ket­ing waste or recy­clables as fuel to be burned in cement kilns or oth­er boil­ers. Waste Man­age­ment does this at The Forge — their plant in North­east Philly — with trash and also with the con­t­a­m­i­na­tion and unmar­ketable mate­r­i­al in recy­cling bins. Mas­caro does this with the plas­tics they col­lect and bring to their plant in Berks Coun­ty. Ide­al­ly, a con­tract should also avoid any exper­i­men­tal types of incin­er­a­tion (pyrol­y­sis, gasi­fi­ca­tion, plas­ma arc), oth­er failed exper­i­men­tal process­es like trash-to-bio­fu­els schemes, which are cost­ly and tech­ni­cal­ly fail. No com­mer­cial facil­i­ties exist in the region, but com­pa­nies keep trying.
• There are many ways in which munic­i­pal­i­ties can work to reduce waste and save mon­ey. These can be worked into waste and recy­cling con­tracts as well. Munic­i­pal­i­ties are encour­aged to reach out to us about how to incor­po­rate these “Zero Waste” poli­cies that save mon­ey, pro­mote pub­lic health and the envi­ron­ment, and cre­ate jobs while reduc­ing waste. Con­tact Mike Ewall, Esq. at 215–436-9511 or mike at energyjustice.net.