Reply from Kansas Sierra Club Regarding Local Concerns About The Recent Goodland Energy Center Announcement...

I looked at the draft permit you mailed to me and I have these comments:

The permit allows the burning of up to 30% by weight of MSW. It does not mention any provisions for source separation of MSW which means everything but the kitchen sink will be fair game for burning including all kinds of plastics which contain chlorine compounds and heavy metal colorants especially cadmium, industrial and consumer electrical devices containing heavy metals, such as mercury and lead, old batteries, and treated wood containing arsenic and chromium. This is attested to by the fact that the new permits lists a limit for hydrochloric acid and the old one doesn't. That because the burning of chlorinated organic materials such as PVC plastic generates HCL as well as highly toxic volatile chlorinated hydrocarbons such as dioxins and furans and PCB's.

The pollution controls are not capable of removing a significant amount of mercury. The controls could remove maybe 98% of the dioxins & furans if operated properly, but there is no means required in the permit to assure that this is the case. The formation of dioxins and furans is sensitive to having a suitably high combustion temperature at all times. Also the temperature of operation of the dry scrubber must be low enough to ensure that the volatile organics and heavy metals (except mercury) condense onto particles that can be filtered out by the fabric filter. The permit specifies no temperature of combustion or even best combustion practices. No testing or monitoring for dioxin and furans, mercury or other toxic heavy metals is required.

The permit limits MSW to 30% of the fuel but says nothing about the other 70%. For example a pile of wet MSW could be injected into the burner with 70% wet agricultural waste which which could lower combustion temperatures and allow the formation of unusually large amounts of dioxins. In contrast trash and medical waste incinerators are required to maintain certain high temperatures and may involve two stage burners or after burners for this purpose.

Although not included in the info you sent I estimate very roughly that the facility would be allowed to burn 80-100 tons of MSW per day. You might check that against what the city generates to see if this is a money making scheme.

If the system's pollution controls are working properly it means that the burning of MSW will cause the ash residues to be more toxic because they will contain much higher levels of heavy metals and toxic organics. It's unlikely that the ash landfill is designed for this because the rules for coal ash disposal in Kansas are relatively weak.

Dioxins and furans can be taken up by grazing animals or otherwise contaminate pastures and hayfields. In the absence of rainfall and lakes in the Goodland area, the mercury will contaminate water bodies hundreds of miles downwind.

I think you should insist that MSW be removed from the permit as an allowable fuel.

The conventional pollutants from burning the other proposed materials will probably not materially increase the health risks compared to burning coal. It is untrue that this plan would be carbon neutral. Tires are made from fossil fuels not tree rubber. However, to the extent that only wood products and biowastes are burned it would reduce greenhouse gases compared to burning only coal.

Best regards, Craig Volland, QEP, Chair of the Air Quality Committee, Kansas Sierra Club