Open Letter to Mayor & Chief Minister of Delhi

To

Ms Arti Mehra
Mayor of Delhi
Municipal Corporation of Delhi
Mayor's House
Town Hall
Delhi – 110006

Subject-Objections with regard to the proposed Waste to Energy plants based on non-renewable technology options for misplaced resources (garbage)

Madam,

Pursuant to the meeting of K.S. Mehra, Commissioner, Municipal Corporation of Delhi (MCD)
with the Residents Welfare Associations of Sukhdev Vihar on September 9, 2008, Delhi Campaign for Safe Environment (DCSE) to express its anguish and objection to the proposed Dioxins emitting waste to energy plant in the residential areas. Residents of the area are protesting vociferously in full media glare for several months but to no avail.

We wish to draw your attention to the initiative by the Municipal Corporation of Delhi (MCD) and Infrastructure Leasing & Financial Services Limited (ILFS) for the installation of a municipal solid waste (MSW) to energy plant in Okhla, based on incineration of Refuse Derived Fuel (RDF). We would like to state our concerns about this venture.
The proposed plant is located inside dozens of densely populated residential colonies like Harkesh Nagar and Johori Farm, when the policy of the government is to shift or relocate all existing industries whatsoever from the residential areas. Besides this the site is in proximity of hospitals like Holy Family, Fortis-EScorts and Apollo.
Inhabitants of colonies like Gaffar Manzil, Sukhdev Vihar and Hazi Colony are rightly alarmed at the prospect of a Dioxins emitting incinerator plant from coming up in their vicinity.

We understand that the MCD is installing waste to energy technologies, under the name of RDF for disposing off 2000 –3000 metric tonnes (mt) of MSW per day. While we do appreciate the outstanding effort of the MCD in showing leadership on the issue of waste in India by undertaking many unusual initiatives such as the release of the Waste Master Plan, 2020, we do think that the move to install RDF plants in Delhi is an environmentally unsustainable solution. It raises serious concerns about the health and safety of the residents, which we believe such a technology, will jeopardise.

We object to the fact that unmindful of the public protest, New Delhi Municipal Council (NDMC) had permitted Jindal Urban Infrastructure Ltd to set up this plant. This company has secured a contract from New Delhi Waste Processing Company Limited, a joint venture between the Delhi Government and Infrastructure Leasing and Financial Services Ltd. (IL&FS), to produce 16 MW power from 2, 000 Metric Tonnes of municipal waste. The raw material would be supplied to the company by the New Delhi Municipal Council (NDMC) and the Municipal Corporation of Delhi.

In fact the MCD’s Master Plan Report (2020) itself says, ... “RDF is often an option when emission standards are lax and RDF is burned in conventional boilers with no special precautions for emissions.” We are surprised that despite this observation the report then goes onto suggest RDF. We are also surprised to note that the consultants were hired by United Nations Environment Programme (UNEP), which has been central to the Stockholm Convention, and discourages the use of incineration. In fact the MCD report itself says that RDF is another form of incineration.
Besides we are also concerned that such a master plan has been drawn up with no consultation with the residents and civil society members.

RDF and Incineration
RDF is a thermal and combustion technology, mainly used to prepare waste for mass incineration. The reason for making pellets is to both get the waste in a dry combustible form besides making it ready for those types of incinerators, which can handle RDF. As such all controls which are necessary for incineration need to be in place for RDF, which is not a stand-alone technology, but only another stage for a type of incineration. All such technologies go under various names such as RDF, incineration, pyrolysis, gasification etc.

Needless to say, if mixed waste is burnt, it will create problems of very toxic compounds such as dioxins and furans, heavy metals and other pollutants. The calorific value for the waste comes from materials such as plastics and metals. Plastics, especially chlorinated plastics such as polyvinyl chloride (PVC) when combusted gives rise to these highly toxic pollutants. In fact PVC plastic combustion is banned in India by regulation both in the municipal and bio-medical waste handling rules. In the case of hazardous waste India has developed a very stringent standard, which follows the European standard for the Treatment, Storage, and Disposal Facilities (TSDFs).

Toxics are created at various stages of such thermal technologies, and not only at the end of the stack. These can be created during the process, in the stack pipes, as residues in ash, scrubber water and filters, and in fact even in air plumes which leave the stack. There are no safe ways of avoiding their production or destroying these once produced, and at best they can be trapped at extreme cost in sophisticated filters or in the ash. The ultimate release is unavoidable, and if trapped in ash or filters, these then become hazardous wastes themselves. On the other hand other methods of MSW treatment, which are non-thermal and do not create any such problems.

Pelletisation causes special problems. Since pellets, to burn need plastics and paper in them, these when used in household stoves or industrial furnaces which are scattered in communities, release toxics in completely uncontrolled environments to which communities are directly exposed.

Cost concerns
Such technologies cannot be justified either from the point of view of energy generation or for safe waste abatement. For example the cost of a typical 5-mw waste-to-energy project is about Rs 40 crores, with each mw of electricity consuming about 150 tonnes of urban waste. This amounts to an investment of Rs 8 crores per mw, or twice the cost of conventional thermal power. The subsidy alone to sustain such projects, especially for demonstration projects, exceeds 50% of the project cost, an unjustifiable public investment of Rs 20 crores for 800 tonnes of urban waste disposal.

All over the developed world, almost half the investment of their cost is put in emission control systems only to reduce emissions, some of which are very deadly (as mentioned earlier), such as mercury and dioxins and furans, volatile organic compounds (VOCs), and heavy metals like lead, cadmium, mercury, that waste incinerators. For example a 2000 mt per day incinerator can cost upwards of USD 500 million in Europe, half of the cost being put into emission control.

Indian garbage has an average calorific value of about 800 cal / kg. For combustion technologies to succeed they would need about 2000 to 3000 cal / kg, other wise auxiliary fuel has to be added. This makes the process more uneconomical and polluting than it already is.

Overall environmental impacts:
The impacts of incineration or of RDF are wide. The pollutants, which are created, even if trapped (at astronomical expense), reside in filters and ash, which need special landfills for disposal. Besides in case energy recovery is attempted then it requires heat exchangers, which operate at temperatures, which maximise dioxin production. If the gases are quenched, it goes against energy recovery.
International Legislation
At the international level India is party to the Stockholm Convention, which we are on the verge of ratifying. This Convention deals with very toxic chemicals known as persistent organic pollutants (POPSs), which include dioxins and furans. These are largely the result of waste combustion or thermal treatment of municipal and medical wastes, especially involving chlorinated plastics such as PVC.

The United States’ Environmental Protection Agency (USEPA) has evaluated that that incinerator emissions are the primary source of dioxin, and major sources of mercury, lead, arsenic, particulate, and other pollutants. The ash that results from burning trash is even more toxic. These effects have been recognised worldwide

Inventories of releases of such emissions, such as dioxins, heavy metals etc. have put municipal waste incinerators to be amongst the highest sources of such pollutants worldwide. Of course these are global pollutants but have drastic short term and long-term health effects. Various conventions have stated concerns about this.

The incineration of pellets made from Refuse Derived Fuel (RDF) violates several international laws such as:
a) Kyoto Protocol: As per Annexure A of the Protocol waste incineration is a green house gas emitter.

b) Stockholm Convention on POPs: Calls for improvements in waste management with the aim of the cessation of open and other uncontrolled burning of wastes, including the burning of landfill sites. States that “ when considering proposals to construct new waste disposal facilities, consideration should be given to alternatives such as activities to minimize the generation of municipal and medical waste, including resource recovery, reuse, recycling, waste separation and promoting products that generate less waste. Under this approach, public health concerns should be carefully considered, as per Annexure C of the Convention.”

c) Recommendations of United Nations Environment Programme (UNEP)'s Global Assessment on Mercury. The Global Mercury Assessment Working Group recommended measures to address global adverse impacts of mercury at the global, regional, national and local levels. The options include measures such as reducing or eliminating the mercury emission from waste incineration because unlike other heavy metals, mercury has special properties that make it difficult to capture in many control devices.

National Legislation
In fact all recent waste policies of the Government of India, which include the Supreme Court’s High Powered Committee report of Urban waste, the Shukla Committee report of the Ministry of Urban Affairs and Employment, as well as the MSW national regulations issued by the Ministry of Environment and Forests, do not recommend the use of incineration. Further regarding Schedule IV of the Municipal Solid Waste Rules, 2000, it is our understanding that the signatories of the agreement have not sought any approval from the Delhi Pollution Control Board or Central Pollution Control Board, as is mandatory.

The proposed plant is not in line with national legislations and guidelines such as:

a) MSW Rules, 2000 because according to the MSW Rules it is illegal to incinerate chlorinated plastics (like PVC) and wastes chemically treated with any chlorinated disinfectant. The reason to ban incineration of chlorinated products is to stop formation and emission of dioxins, one of the most toxic substances known to human beings.

b) Recommendations of the Supreme Court constituted committee on waste management. The Burman Committee recommended that composting should be carried out in each municipality. Local bodies are cautioned not to adopt expensive technologies of power generation, fuel pelletisation, incineration, etc until they are proven under Indian conditions.

c) Delhi High Court order because the court had directed the Comptroller and Auditor General of India (CAG) to conduct an inquiry into the failure of the Timarpur plant. The high court order came in response to a public interest litigation (PIL) filed in 2000 by B L Wadhera.

d) MCD’s own Feasibility Study and Master Plan for Optimal Waste Treatment and Disposal for the Entire State of Delhi of March 2004 because it says, “Incineration of RDF is considered waste incineration.” (Page 25, Appendix D, Technology Catalogue). It also says the costs of RDF are often high for societies with low calorific value because energy is used to dry the waste before it becomes feasible to burn it.

e) ‘White Paper on Pollution in Delhi with an Action Plan’ prepared by Union Ministry of Environment and Forests. It says, “The experience of the incineration plant at Timarpur, Delhi and the briquette plant at Bombay support the fact that thermal treatment of municipal solid waste is not feasible, in situations where the waste has a low calorific value. A critical analysis of biological treatment as an option was undertaken for processing of municipal solid waste in Delhi and it has been recommended that composting will be a viable option. Considering the large quantities of waste requiring to be processed, a mechanical composting plant will be needed.”

Health Impacts and Concerns
Based on the appraisal of all the sources of pollutants, the pathways of exposure and the receptors, it has been found that the technology, which is being, suggested increases pollution in air, water and land leading to food chain contamination and disease hazards. There is overwhelming scientific evidence that incineration is a cause of ill-health:
a) Although communities living in the immediate vicinity of incinerators are most at risk from the emissions, explosions etc., the contamination is not restricted to a specific locality.
b) Test have shown areas as far as 1,000 miles are impacted directly by the chemical particulates, metals, dioxin, products of incomplete combustion etc., from it. Every resident of Delhi in particular would be exposed to the toxins emitted by incinerators via the food chain through fish, milk and other dairy produce.
c) Persistent Organic Pollutants (POPs) have recognised long term toxic effects, which transfer from one generation to another, through mother’s breast milk, and at extremely low and minute exposures. These are global pollutants.
d) What is of grave concern to civil society groups, doctors and scientists is that the womb offers little protection to the unborn child as many of these chemicals can pass through the placental wall and interfere with hormone behaviour during foetal development.
e) Even breast fed infants would be affected as its by-products also contaminate their mother’s milk. By installing such a technology the citizenry stand at great risk of such contamination and health effects.

Concerns about recycling
The installation of these technologies, which combust or thermally change materials which are otherwise being recycled, goes against the whole ethos of recycling. Hundreds of thousands of people seek their livelihood through recycling in India. Approaches to waste management should lead to socially acceptable solutions and helping already marginalized sectors.

Alternatives
Also from our understanding, RDF or incineration is completely inappropriate for Indian urban waste, which is largely biodegradable in nature, but also that they ext5ract a very high cost for the energy which they claim to generate. The cost, which is largely subsidised by various schemes, does not however include the environmental and health costs caused by their toxic releases, and which are externalised. These technologies also use valuable resources which can be recycled, such as plastics and metals, and which support a massive recycling sector in the country. On the other hand Indian municipal waste is fit for composting and biomethanation treatment processes.

In fact we feel that such high cost routes must be avoided and instead only appropriate methods such as bio-methanation, composting and proper recycling propagated. Incentives and subsidies should be offered in areas of `cold’ technologies alone, which are suited to our country economically, socially and also to our wastes.

Therefore, adopting alternative cleaner methods of waste disposal is deemed sane and sustainable. The need for low-cost solutions presents significant difficulties, but it is not an impossible task. The ideal resource management strategy for MSW is to avoid its generation in the first place. This implies changing production and consumption patterns to eliminate the use of disposable, non-reusable, non-returnable products and packaging.

The alternative waste disposal methods include:
i. Waste reduction
ii. Waste segregation
iii. Reuse and extended use
iv. Recycling
v. Biomethanation technology
vi. Composting
vii.Vermicomposting

We urgently urge you to discard any proposal, which does not adopt any of the above-mentioned methods to dispose of Delhi's municipal wastes. Suryapet, Andhra Pradesh has adopted it. It can set a precedent for the whole country. We would be happy to provide you information or clarification on this issue.

Thanking you

Yours faithfully

Cc/
Sheila Dikshit, Chief Minister, Government of NCT of Delhi
Rajerdra Kumar, Secretary (Power), Government of NCT of Delhi
& Chairman and Managing Director, Delhi Transco Limited