Pottstown Landfill Air Pollution Permits 

Public Hearing  June 24, 2003

1.  Increase NOx emissions

Problem:   NOx emissions cause health harm. 

                   This is a severe non-attainment area under the Clean Air Act’s, health based standards.    Reductions of NOx are required under the Clean Air Act. 

Requests to DEP

1.       We have a right to clean air under the PA Constitution.  We ask DEP’s air department to protect our air and our health, according to your mission statement.  To do this DEP must DENY increased NOx emissions from the Pottstown Landfill, under any and all circumstances.

2.       We have a right to clean air under the federal Clean Air Act. 

      It is DEP’s responsibility to protect that right.  Require Pottstown Landfill to reduce its NOx emissions, as required under health based standards of   the Clean Air Act.

2.  Plan Approval  PA - 46- 0033B

Problem:   Waste Management’s plan to manage Pottstown Landfill’s Eastern Expansion gas does not provide the SAFEST technology to manage this gas.  Greater Pottstown Area residents will be exposed to this air pollution over the next 20 to 50 years.   Elevated illness patterns around the Pottstown Landfill require the safest technology to protect pubic health, not the cheapest for the benefit of a multi billion world wide corporation.

Problem:  This is DE FACTO Plan Approval.  The pipeline to connect the Eastern Expansion with the original landfill in this plan approval draft has already been installed, without a Plan Approval or public comment.  This should never have happened.

·          We object to this pipeline connection and the use of flares to burn Eastern Expansion gas.

·          Safer non-burn technology should be required by DEP. DEP knows flares are not the safest technology; that burning landfill gas will produce dioxin by-products; that dioxin is one of the most toxic chemicals known to mankind; that dioxin can harm human health at parts per trillion; that dioxin stores in human fat; that most people in the U.S. are at their dioxin limit, and that people living near sources of dioxin can be 10 times more at risk than the average population.   

Problem:  The use of an additional flare has already been installed for emergency purposes.  This was in response to over six months of horrible Pottstown Landfill gas odors throughout the entire area. 

·          For reasons listed above, we also object to the continued use of this new flare to manage Eastern Expansion air pollution, installed without a plan approval or public comment.

       Problem:  Was the community subjected unnecessarily to six months of unbearable odors, increased air pollution, and short and long term health risks because of Waste Management’s irresponsible planning or because they tried to circumvent Clean Air Act requirements. Either is unacceptable!   

·         Six months of horrible odors from the Pottstown Landfill diminished the quality of life of tens of thousands of area residents, many who had frequent severe headaches, sinus infections, nausea, dizziness, burning eyes, throat, nose, lungs, skin, but many may have also suffered long term health risks. 

·         But, even worse, excessive and extended air pollution and odor violations may have lead to long term health problems, especially in our children

·          Waste Management failed to provide up-front planning to manage Eastern Expansion gas.  The Eastern Expansion, opened in 1998, and now almost full,. appears to have been producing uncontrolled gas, which got out of hand this fall. This required an emergency quick fix, without a plan approval or public comment. 

·          Waste Management has made the absurd claim that the Eastern Expansion was not part of the Pottstown Landfill.   Was this to avoid having the Eastern Expansion’s air pollution added to the rest?   How or why did the Eastern Expansion get an air pollution permit in this sever non-attainment area?  Is that because Eastern Expansion air pollution was ignored until this emergency?

·          We believe Pottstown Landfill’s Eastern Expansion air pollution should have been a violation of the Clean Air Act’s health based standards, calling for reductions of air pollution in our severe non-attainment area.

·          Now you see it, now you don’t!  The Eastern Expansion is still not included in two permits currently under review by DEP, at the same time as this permit which now does include the Eastern Expansion. Is this Waste Management magic?

·           “IF” the Eastern Expansion is considered separate from the Pottstown Landfill and is permitted to be missing from the Operating Plan and the Title V permit, then this pipeline between the Eastern Expansion and the original landfill is a clear permit violation of both of those permits.  The flares in the original landfill are not allowed to burn off-site gas.   Waste Management can not have it both ways!

Requests to DEP

1. We ask DEP to take this opportunity to require Waste Management to use the safest, modern, non-burn technology to manage Eastern Expansion gas over the next several decades. 
• Burning landfill gas is a form of incineration.
• Burning landfill gas produces dioxin.
• We can not continue to be subjected to the burning of the Eastern Expansion gas in flares. 

·          We cannot allow the production of any amount of dioxin,  for the next 20 to 50 years, from burning massive amounts of Eastern Expansion gas in flares.   What would happen to area residents, especially their children?

·          We reject the idea of transporting this hazardous gas off-site and burning it in industrial boilers.

·          We demand the safest non-burn technology to handle Eastern Expansion gas to avoid decades of dioxin contamination, from burning the gas produced from the waste already in the Eastern Expansion.

·          We reject expansion of the Eastern Expansion.  Each load of waste will produce more dangerous gas, which will harm human health no matter how it is managed.

2. The responsibility of DEP’s air department is clear.  Your mission, Ms. Carlini, as well as your moral and ethical duty, is to protect our air and our health, regardless of the cost to this multi billion dollar corporation.  
3. Don’t permit this Plan Approval, just because it was already installed and is already operational.  Just remember, the odor air pollution emergency for which this plan went into action, was either caused by irresponsible planning by Waste Management or their crafty planning to avoid Clean Air Act requirements.  Don’t punish a community for decades, which has already been forced to suffer immeasurably for over six months.  Don’t negatively impact the lives of tens of thousands of people and their children, far into the future, to save Waste Management money.
4. What will the physical and financial costs be to our children in the future if DEP doesn’t require the safest technology to manage massive amounts of Eastern Expansion gas for decades?  
5. DEP’s air department must reject Plan Approval PA – 46- 0033B, and take this opportunity to protect our air and our health from Pottstown Landfill’s air pollution.  Value our children’s future health and quality of life.  
6. Fines for the odor violations should not go to DEP, but rather to the communities affected by Pottstown Landfill’s air pollution, to be used for them to defend themselves against Pottstown Landfill’s air pollution.

3.  Amended Operating Permit OP-46-0033

Problem – The Pottstown Landfill can not operate without causing harmful off - site air pollution.  

                    Air pollution causes many serious illnesses and even death.   It also causes serious quality of life issues. Childhood cancer statistics have been skyrocketing since the late 1980’s when Waste Management bought the Pottstown Landfill.  There are other elevated cancers around the Pottstown Landfill and many other alarming illness patterns around the Pottstown Landfill.

Problem – This Operating Permit Amendment for the Pottstown Landfill does not include the Eastern Expansion, an operational section of Pottstown Landfill since 1998.  

Problem -  We don’t know exactly what’s in Pottstown Landfill’s air pollution.  DEP doesn’t know, either.

Problem  - All monitoring, calculating, testing, and reporting of Pottstown Landfill’s

                  regulated air pollutant levels are done by Waste Management.   

a.       The honor system has failed this community, as evidenced by our shocking childhood cancer rates. 

b.       Since the inception of the company, Waste Management has a history of felonies, violations, fines, and penalties.  Some of them were for falsified testing results, hazardous waste storage, and medical waste violations.  This is the company which is on the honor system to monitor, test, calculate, and report for purposes of information in this operating permit.  How can we trust their information?

Problem -  This Operating Permit excludes our most dangerous exposure risks from Pottstown Landfill’s air pollution.

a.       Radiation and dioxin are the MOST HAZARDOUS air pollutants associated with Pottstown Landfill’s air pollution.   This operating permit does NOT include radiation or dioxin, even though they are part of Pottstown Landfill’s air pollution.  The regulatory system has failed us miserably if it ignores air pollution for which there is no safe level.

b.       Synergistic and additive exposure risks from Pottstown Landfill’s air pollution are unknown at this time.  To issue an operating permit for any more air pollution.

Problem -  This operating permit calls for the use of two flares to burn off the gas, and excludes a full time flare that is already operational.  Burning Pottstown Landfill gas in flares is not the safest way to manage Pottstown Landfill’s air pollution to protect the health of area residents.  DEP acknowledged that flares are not the safest way to manage the gas.

Problem -  Condition 8. A. 1.  This is a dangerous and unacceptable loophole to make way for future Pottstown Landfill expansions and the use of flares for the gas generated from them. 

·          Neither future expansions, nor the use of flares for the gas they would generate, are in the best interest of public health.

Problem – Condition 8. H. This contains language that would allow the start up of a pipeline delivery system to take the landfill gas to a third party.  T

·          This is a back door tactic to open the back door for transporting Pottstown Landfill’s unregulated, ever-changing, hazardous, corrosive, and explosive Pottstown Landfill gas off-site. 

·          Sending Pottstown Landfill’s hazardous gas off-site is an unacceptable tactic to to circumvent Clean Air Act, health based requirements, and also to avoid eventual hazardous liability for the health effects of this extremely hazardous gas.

·          Transferring hazardous gas is not the solution to air pollution.  The air pollution is still released in the same air pattern.  This is a tactic used by air polluters to get what they want at the expense of public safety. 

Problem – Many permit conditions contain language which is not protective of public health.  Waste Management has use language such as “whichever is less stringent.”

Requests to DEP

1.       We urge DEP to revoke Pottstown Landfill’s Operating Permit Amendment OP-46-0033.      

2.       We urge DEP to close the Pottstown Landfill immediately. 

a.      Closure is the only ethical, common sense approach to Pottstown Landfill’s air pollution.  Increasing environmentally related illnesses around the Pottstown Landfill call for prevention and precaution.

b.      Closure is imperative to prevent future unnecessary public health and safety risks to over 30,000 residents, and thousands of children who attend 29 schools and day-cars, within 3 mils of the Pottstown Landfill.

3.       We urge DEP to end the use of flares for all Pottstown Landfill gas, based on the fact that it is clearly not the safest technology to manage Pottstown Landfill’s air pollution.

4.       We urge DEP to require the safest non-burn technology for all remaining Pottstown Landfill gas over the next several decades.   This is imperative to protect the health of people around the Pottstown Landfill, especially the children.