Take Action on Covanta

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Background

In the 2023 legislative session, Beyond Toxics played a critical role working with Senator Deb Patterson to pass SB 488, a law to require the Covanta Marion Waste Incinerators (aka “Covanta”) to put a definitive limit on the amount of medical waste allowed to be burned on a yearly basis. Lawmakers passed this law because they understood the risks to the environment and human health from burning medical waste. Medical waste is responsible for higher emissions of dioxin, a known carcinogen and hormone disruptor, and heavy metals.

In Oregon, since the passage of SB 488 in 2023, Covanta may not combust more than 18,000 tons of hospital, medical or infectious waste during a single calendar year. The law requires the ODEQ to modify the facility’s air quality pollution permit to codify the limit on medical waste in regulations.

Take Action - The deadline to submit your comments is May 7th by 5:00 PM

The Oregon Department of Environmental Quality is requesting comments on a modification of Covanta’s air quality permit to implement this critical aspect of the new law. The public comment period is for written comment only. The deadline to submit your comments is May 7 by 5:00PM.

We urge you to take this opportunity to submit your comment to support Oregon’s new 18,000 ton limit on burning medical waste. In addition, you can use this opportunity to express your insistence that DEQ immediately enforce other aspects of the SB 488.

Submit written comments:

By mail: Oregon DEQ
Western Region Air Quality Permit Coordinator,
4026 Fairview Industrial Drive SE,
Salem, OR 97302

By email: wraqpermits@deq.oregon.gov

In the subject heading and the title of your written testimony, reference the type of hearing: Covanta Marion, Title V Operating Permit Modification No.1.

Address your testimony to: Zach Loboy, DEQ Western Region Air Quality Manager

Sign your name and give your address.

Please use these talking points in your written testimony.

  • I support the air quality permit modification that will require Covanta Marion, Oregon’s waste incinerator, to limit the medical waste it burns to 18,000 tons per year.

  • I also urge DEQ to require strict record keeping requirements and to expand upon the requirements in Condition 70 b. Specifically, the DEQ should require detailed tracking of the sources of medical waste as well as the characterization of that waste. Waste suppliers should label waste as either primarily body parts and fluids or primarily other material, such as plastic; and the amounts of each category should be recorded daily and reported to DEQ.

  • I do not support the part of Condition 26a which allows Covanta to combust medical waste “at the highest rate in which a compliance test has demonstrated the combustor can operate.” At no time should Covanta be allowed to combust medical waste in any excess amount than the established limits. Basing an exceedance allowance on one compliance test is not sufficient to determine the safety of increased medical waste incineration. The DEQ should never allow excess emissions and the quoted phrase should be deleted from the permit language.

  • SB 488 also requires Covanta to provide the DEQ with a written plan to install continuous emissions monitoring equipment or continuous sampling equipment for highly toxic pollutants including dioxin, furans, PCBs, lead, mercury, cadmium, total chromium, and other heavy metals. This written plan was due December 24, 2023. To date, Covanta has not complied with this requirement. The DEQ should determine that Covanta is in violation of the law and issue a citation and fine.

EXAMPLE

To: Zach Loboy, DEQ Western Region Air Quality Manager
Subject: Covanta Marion, Title V Operating Permit Modification No. 1
Date:

Thank you for the opportunity to provide my comment for the Covanta Marion, Title V Operating Permit Modification No. 1.

I appreciate that DEQ is implementing the requirements of SB 488, which set limitations on the amount of medical waste that can be burned at the Covanta Marion incinerator in Oregon. I believe it is necessary to place strict limits on the incineration of medical waste due to the air toxic emissions associated with burning this material.

Although I wish the Oregon Legislature had chosen a lower limit for annual tonnage of medical waste that can be burned, I support the air quality permit modification that will require Covanta Marion, Oregon’s waste incinerator, to limit the medical waste it burns to 18,000 tons per year.

Considering the purpose of SB 488 aimed at setting a limit on medical waste, I object to the part of Condition 26a which allows Covanta to combust medical waste “at the highest rate in which a compliance test has demonstrated the combustor can operate.” At no time should Covanta be allowed to combust medical waste in any excess amount than the established limits. The DEQ should never allow excess emissions and the quoted phrase should be deleted from the permit language.

I recommend that the DEQ strengthen the record keeping requirements in the air permit. Specifically, the DEQ should expand upon the requirements in Condition 70 b. In addition to requiring detailed tracking of the sources of medical waste, I request that the DEQ require the characterization/description of that waste.

Sincerely,

Your name here

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