Sierra Club
Pennsylvania Chapter - Lehigh Valley Group
P.O. Box 1901
Allentown, PA 18105-1901
contact: (610) 865-5147
email: l vs i er r a clu b@g ma il .c om
Allentown City Council
City Hall
435 Hamilton Street
Allentown, PA 18101
November 11, 2010
re: proposed Waste-to-Energy project by Delta Thermo Energy, Inc.
Members of City Council:
The Sierra Club is America's oldest (1892) and largest (1.5 million members) environmental
organization, with over 24,000 members in Pennsylvania. The Lehigh Valley Group of the Sierra
Club has serious concerns about the proposed Waste-to-Energy proposal for Allentown by Delta
Thermal Energy, Inc.

The project has been presented as a closed-loop system with negligible environmental
impact. If this proves to be accurate, it may be a better system for disposing of municipal
solid waste than land-filling that waste, as is presently done. However, the Sierra Club
does not believe the proposal has thus far demonstrated that its operation will, in fact,
have little environmental impact or dangers for public health.
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The proposal has five system outputs: a powder fuel, ash from combustion, smokestack
emissions, waste water flowing to the city's sewage treatment plant, and electricity. Other
than electricity generation, this proposal has not shown what toxic substances (heavy
metals, hydrofluorocarbons, and other toxins), and at what levels, will remain in each of
these system products after the proposed combustion, scrubbing, and water treatment.
The proposal has also not specified what federal or state technical standards will be used
to regulate such possible toxins and what testing regimen will be used by regulators to
insure public health is not endangered by these substances leaving the facility in effluent
solids, water, and exhaust. These issues must be addressed in order to preserve public
health and safety for both Allentown and surrounding communities.

In the absence of a DEP permit for this "experimental" project, what monitoring will be
done by DEP and the operator? What standards/limits will be used, in what frequency
will monitoring occur, what results will be made public, and what will be the result of
any “substandard” monitoring results?

A waste combustion facility's fuel requirements are potentially in conflict with existing
waste recycling programs: Will the city continue and improve its recycling efforts or will
this project reduce them due to its need for waste for fuel? DEP may ban municipal food
waste from landfills: will this project preclude or limit future composting and digestion
efforts by the city?

The three components of this proposal -- Resource Recycling System, Complete
Combustion Chamber, and Water Treatment System – to our knowledge, have never been
combined in one operating system anywhere in the world. What happens to this project if
it simply does not work as planned or does not eventually receive a non-experimental,
long-term DEP permit?

Please also see below the Sierra Club's national policy on such solid waste incineration.
The Sierra Club urges the City of Allentown to seek clear answers to these questions before
proceeding any further with this project.
Very truly yours,
Sierra Club
Pennsylvania Chapter - Lehigh Valley Group
by: ______________________________
Donald W. Miles, chairman
xc:
Hon. Ed Pawlowski, Mayor
Allentown Environmental Advisory Council
_____________________
Sierra Club national policies on solid waste:
The Sierra Club’s policy for reducing waste is based on Zero Waste: it aims to prevent waste by design rather than
manage it after the fact. Zero Waste addresses not only the quantity of waste we generate, but also its toxicity, its
contribution to climate change, and the important links between waste reduction and corporate responsibility.
Environmental management of materials and energy should first, reduce the use of materials and energy and the use
of toxic substances to a minimum (through design for the environment); second, repair and reuse, extending the
service life of materials and products; and third, recycle, conserving as much as possible of embodied value.
Elimination or reduction of wastes should have the highest priority in a waste management program. Process
substitution, waste reduction, reuse, and conversion to nonhazardous substances should be encouraged. Closed
systems of manufacture, use, and disposal should be developed. Industrial processes producing wastes that cannot be
reused, converted to nonhazardous substances, or safely incinerated should be phased out. If materials and energy
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recovery are not possible, the best technologies should be used to reduce the level of hazard as much as possible.
Waste exchanges should be encouraged .
Incineration should only be considered after all other acceptable options have been evaluated and found to be
impracticable for managing a particular waste. Regulations must be in place to require the lowest levels of emissions
and effluents that are technically feasible. Incinerator design, permitting, and operation must include sufficient
safeguards to protect human health and the environment. If the lowest feasible levels of emissions do not fully
protect human health and the environment, the facility should not be allowed to operate unless incineration is the
least hazardous option for management of an existing problem waste. Because much is still not known about the
health and environmental effects of emissions, including the products of incomplete combustion, research should be
pursued to further characterize and reduce emissions.
(a) The permitting, sighting, and operation of hazardous waste incinerators, including mobile units, must include a
public education and participation process that makes all data associated with design, waste streams, transportation,
storage, and emissions conveniently available to the public.
(b) All permits should be written to provide for changes or revocation at any time, and should be re-evaluated at
least every two years. A mobile incinerator must have a permit that is specific for each site where it operates.
(c) Incinerator sighting should minimize risks to the public from emissions and transportation, at the same time
avoiding such environmentally sensitive areas as critical wildlife habitat, parks, and wilderness areas. A facility
should include a buffer zone and operate inside a containment building where fugitive emissions are controlled.
(d) Trial burns must be conducted on each individual incinerator using waste streams as close as possible in
character to those to be burned in normal operations.
(e) All hazardous waste incinerators should be equipped with emission control systems for acid gas, toxics, and
particulates. Monitoring should address all potentially toxic emissions, including organics and metals. Monitoring
should be based on frequent or continuous sampling whenever technically feasible. Continuous emissions
monitoring should be employed that will fully characterize the operating conditions of the incinerator and should be
connected to automatic interlock systems that will not allow continued operation of the incinerator if design values
cannot be attained. Ashes, slag, and aqueous wastes should be presumed hazardous and managed appropriately.
Management of incinerator residues should be provided for in the design and permitting process.
(f) Monitoring programs should include the collection of on-site and off-site baseline data prior to facility operation
so that contamination from the facility can be distinguished from ambient or background pollution levels when
operation begins. Established quality control procedures should be used. All monitoring data should be conveniently
available to the public and the press from facility operators and regulatory authorities.
(g) Regulatory controls should require operator certification and an operations and maintenance plan. Inspection to
determine that the plan is being followed should be both announced and unannounced and should cover all shifts at
facilities. Regulations should provide for the establishment of a citizens' over-sight committee which can designate
and supervise its own inspector. This person shall be trained and employed at state or facility owner expense and
should inspect the facility on a least a weekly basis, independently of state inspections.
(h) Research on other thermal technologies, using nonhazardous chemicals for initial testing, should be encouraged.
(i) Part of the facility's cost of doing business should include the preparation of environmental and public health risk
assessments, permit fees, monitoring, closure, insurance, and post-closure contingency funds. A special tax, such as
a gross receipts tax, should be imposed on the facility to compensate the host community that bears the health risks.
This compensation should be available for improving community emergency response capabilities, additional
monitoring, health testing, health care, transportation safety, and other costs attributable to facility impacts. Marine
incineration is not acceptable because human or mechanical error or natural disaster could cause a release of toxics
that could not be contained or cleaned up. Compliance with strict safety or emissions requirements would be
difficult to assure and safer disposal options exist.
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