REPORT: Reevaluating Waste Management in Minneapolis

7/29/2019 REPORT: Reevaluating Waste Management in Minneapolis

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M i n n e s o t a P u b l i c I n t e r e s t R e s e a r c h G r o u p

Fall 13

Hennepin Energy Recovery Center [HERC]:Reevaluating Waste Management in Minneapolis

A Minnesota Public Interest Research Group Report

Authors: Emma Wright

Joshua Winters, MS

Ryan Kennedy


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2 [HERC] Reevaluating Waste Management in Minneapolis

Foreword

A special thanks for this report goes to Emma Wright for her tireless work in doing theprimary research and drafting this report. Additional thanks goes to Dakotah Johnson,

Jamison Tessneer, Joshua Winters (MS Science, Technology, and Environmental Policy), andRyan Kennedy for their thoughtful feedback and guidance in the development of this report.


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[HERC] Reevaluating Waste Management in Minneapolis 3

TableofContents

Executive Summary ................................................................................................................................................... 4

Introduction ................................................................................................................................................................. 6History of the Hennepin Energy Recovery Center ........................................................................................ 7Air Emissions ............................................................................................................................................................... 8Public Health .............................................................................................................................................................. 11Greenhouse Gas Emissions ................................................................................................................................... 16Toxic Ash Disposal ................................................................................................................................................... 19The Cost of Incineration ........................................................................................................................................ 20Environmental Assessment Worksheet Inadequacies: ............................................................................. 22A Path Forward ......................................................................................................................................................... 23Conclusion ................................................................................................................................................................... 28Recommendations ................................................................................................................................................... 28


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ExecutiveSummaryIn 1989, Minneapolis became one of the few cities in the nation to approve and build amunicipal waste incineration facility after the Clean Air Acts adoption. Covanta Energy, a

multinational corporation that operates waste incineration facilities throughout the world,operates the Hennepin Energy Recovery Center (HERC). In the context of the EnvironmentalProtection Agencys solid waste management hierarchy, only landfill disposal is less preferredthan incineration. Covanta is seeking to expand the amount of waste burned by 212 tons aday, which would bring the facility to full capacity. This report seeks to outline theconsequences and concerns related to garbage incineration at-large as well as those presentedby the proposed 20% increase in waste burned. Further, this report outlines the veryalternatives we should be pursuing as a better solution to our waste management challenges.

Key Findings:

The Hennepin Energy Recovery Center generates significant quantities of health

damaging air pollutants.1. When aggregating the health damaging air pollutants regulated by the Minnesota

Pollution Control Agency, HERC is Minneapolis top polluter by pounds of emissions.2. The amount of health damaging air pollutants emitted per megawatt generated is

higher than any coal, oil or natural gas fired plant.3. The pollutants monitored by HERC are self-reported, with permits issued based

substantially off of estimates. The emissions monitoring system used by HERC usesestimates, not actual emissions, to determine permit compliance for most emissions.

The toxins emitted are a public health concern and disproportionally effect lowerincome communities and children.

4. HERC is a significant source of many toxins in Minneapolis, including but not limited tomercury, NOx, SOx, dioxins, furans, and particulate matter.

5. The health damaging air pollutants emitted affect the lungs of childrendisproportionally, as they are still developing. There are eighteen elementary schoolswithin two miles of the HERC stack.

6. Communities within a two-mile radius of the HERC stack have rates of asthmahospitalizations that are significantly higher than those of Minneapolis as a whole.

The materials being incinerated have not been efficiently managed up the waste

stream.7. Over half (51.5%) of the materials burned at HERC are recyclables.8. Nearly an additional third (32%) of the materials are organics.9. Most of the other waste is comprised of materials with established disposal methods

other than incineration.


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Conclusions:

Based on these considerations and others found in the report, MPIRG would strongly

recommend the following:

1. The Minneapolis City Council should deny Covanta the conditional use permit toincrease waste incineration at HERC by 20%, or 212 tons of garbage per day, as thecitys comprehensive plan dictates negative health effects to Minneapolitans should beavoided in zoning decisions.

2. The City of Minneapolis should move towards curbside composting as a wastereduction strategy to remove the 32% of incinerated materials that are organics.

3. The City of Minneapolis should continue its efforts to streamline recycling to increaseparticipation rates and remove the 51.5% of incinerated materials that are recyclables.

4. Hennepin County and the City of Minneapolis need to seriously consider how HERC fitsin the current waste management scheme. The key consideration being the ratherperverse incentive that HERC creates by allowing for improperly sorted waste from

across Hennepin County to be burned. By doing so, not only does Minneapolis bear thebrunt of air pollution deposition, it also reduces the incentive that other cities have toreduce their waste through recycling and composting.

5. Failing these other policy recommendations, at the barest minimum a full EIS shouldbe required to determine the extent of negative health effects.


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Introduction

Waste brought to HERC is trucked in by waste haulers from the Minneapolis community andother areas within Hennepin County, where it is processed and burned. The Minneapolis

waste incineration facility is what the industry considers a waste-to-energy facility because itgenerates electricity; as waste is burned the heat turns water into steam, which then powers agenerator. But the waste also produces three main by-products: air emissions, toxic ash, andferrous recycled metals. Because the exact content of each load of waste is unknown, it isnearly impossible to know the chemical composition of the ash and air emissions.1

The Environmental Protection Agency and the Minnesota Pollution Control Agency haveadopted a waste hierarchy as follows for the order of the best waste management optionspossible:2

Waste reduction and reuse Recycling Composting Resource recovery, including waste-to-energy or waste composting Landfilling with methane recovery Landfilling without methane recoveryIncineration is one of the bottom-tiered methods of waste management. Despite that, Covantais seeking to expand the amount of waste burned by 212 tons a day, which would bring thefacility to full capacity. Incineration may be above land filling on the waste hierarchy, but itdoesnt follow that it should be the waste disposal method of choice. That waste could bereduced, reused, recycled or composted. These very alternatives were expected to beincreased when the HERC facility was first built, as a temporary waste-management solution

to supplement new recycling and waste reduction efforts.

By focusing on burning and landfilling alone, there is a false choice. Better than a landfill isnot good enough for the communities subjected to the pollution from HERC; responsiblewaste management plans for Minneapolis have always treated HERC as a temporary solutionwhile recycling and composting capacity became more available. Nearly a quarter-centuryafter HERCs boilers came online, it is more critical than ever to reevaluate our wastemanagement strategies to divert recyclables and compostables from incineration.

In the following report, the Minnesota Public Interest Research Group will examine the historyof HERC, the air emissions produced, the cost to Minneapolis, and alternative means of waste

disposal.

1Combs, Susan. "Municipal Waste Combustion." Http://www.window.state.tx.us/. Web. 09 Nov. 2011.

.2Hennepin County Environmental Services. "The Hennepin Energy Recovery Center: A Waste-to-Energy

Facility." Http://hennepin.us/. Hennepin County, Minnesota, 2009. Web. 15 Nov. 2011. .


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HistoryoftheHennepinEnergyRecoveryCenter1985 An Environmental Impact Statement (EIS) completed for HERC

1989HERC constructed, gains approval of needed air permits and begins operating3

2001 Covanta Energy fined $22,000 for excess hydrochloric acid emissions4

2002Covanta Energy fined $15,000 for excessive mercury emissions from HERC5

2003 MPCA issues a Letter of Warning6

2003 HERCs Air Quality Permit Expires and has NOT been reissued7

2004 Covanta fined $4,200 because operators lack required certification 8

2009 Covanta verbally admits they would have to reduce dioxins to comply with new permit

expectations9

2009The Minneapolis Planning Commission rejects a Conditional Use Permit (CUP)

application from Covanta and Hennepin County in June, in part because of insufficient

environmental review. The Commission, in denying the CUP, states "increasing thecapacity of the garbage burner, in all probability could be detrimental to public health,

safety, community and general welfare.10

2009Six state legislators send a seven-page letter to the members of the Minneapolis City

Council opposing the expansion of HERC11

2011The PCA cites 27 areas in which Covanta's documents "do not contain all of the

information that is needed in order to continue to process the HERC Environmental

Assessment Worksheet and air emission permit modification application."12

2013Covanta continues to require extensions to complete the Environmental Assessment

Worksheet

3Hennepin County Environmental Services.

4MPCA Enforcement Files

5"Citizen's Petitions for an EAW for HERC Expansion." Letter to Craig Affeldt, Supervisor Environmental Review Unit.

08 Sept. 2009. Pca.state.mn.us. Minnesota Pollution Control Agency, 11 Sept. 2009. Web. 20 Nov. 2011.6

Ibid7

Ibid8Ibid

9Minneapolis Planning Commission Minutes. June 23, 2009.

10Ibid.

11State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia

Torres Ray , and D. Scott Dibble. "Hennepin County Recovery Center's Conditional Use Permit Proposal." Letter to

Minneapolis City Council Members. 16 July 2009. MS. Minnesota House of Representatives, St. Paul, Minnesota.12

Frank Hornstien, State Representative. "Request for an Environmental Impact Statement on the Hennepin Energy

Recovery Center." Letter to Mike Opat, Chair, Hennepin County Board of Commissioners. 14 Apr. 2011. Minnesota

House of Representatives, St. Paul, Minnesota.


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Air Emissions

Despite requisite filters and precautions for a facility of its age and design, HERC produces asignificant amount of pollution, ranking as one of the top point-source polluters inMinneapolis. These pollutants have significant health and environmental impacts on localcommunities, yet many go unregulated. In addition to direct health impacts on thecommunity, the incinerator emits copious amounts of greenhouse gases, contributing to thelarger problem of global climate change.

Point Source Pollution in Minneapolis

HERC is the number one known point-source producer of air toxin emissions in Minneapolis,and ranks as one of the top five point-source emitters for 5 of the 7 criteria pollutantsidentified by the Minnesota Pollution Control Agency.13 Covantas proposed 20% increase inburning at HERC does not come with a plan to keep pollutants emitted at current levels. Thisincrease comes at a high cost compared to the amount of energy generated, especially whenconsidering the known emissions.

HERCs Emission Track Record at a Glance

2002: Produced 51.89% of Dioxins emitted in Minnesota. 14

2005: Produced a total of 111,761 pounds of health damaging air pollutants; the next

closest point source polluter was Xcel Energys (now retired) Riverside Generating Plant,which generated 96,327 lbs of emissions. Further, the health damaging air emissions aredramatically higher per unit of energy generated, with HERC producing 2,824 lb/megawattgenerated versus 119 lb/megawatt generated at the Riverside Plant.15

See page 9 for table comparing emissions per megawatt generated to the Riverside Generating

Plant.

2009:Top producer of nitrogen oxides (NOX), a criteria air pollutant, generating 553 tons.16The 2nd highest emitter of Mercury in Minneapolis. The 4th highest emitter of carbonmonoxide, lead, and particulate matter 10, all of which are criteria pollutants in Minneapolis.

The 5th highest generator of sulfur dioxide in Minneapolis. The 8th highest producer ofParticulate Matter, a criteria pollutant in Minneapolis.

13Minnesota Pollution Control Agency. Point Source Air Emissions 2005 & 2009. Raw data. Minnesota, Minneapolis.

14"Citizen's Petitions for an EAW for HERC Expansion."

15MPCA Point Source Air Emissions 2005. Raw data.

16MPCA Point Source Air Emissions 2009. Raw data.


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Table 1: Emissions Generated per Megawatt of Energy (Coal v. Incineration)17EnergyGenerated(Megawatts)

Total Poundsof HealthDamaging AirEmissions/Year

Pounds of

Health

Damaging

Air

Emissions/Megawatt

Generated

Pounds ofMercuryEmitted/Year

Pounds of

Mercury/

Megawatt

Generated

Tons ofNOX /Year

Tons of

NOX/

Megawatt

Generated

HERC(incineration)

39.58 111,761.029 2,823.674 9.83101 .24838 552.888 13.960

RiversideGenerating

Facility

(Coal fired)

511 96,327.206 118.507 105.7966 .20704 45.487 .089

As illustrated in Table 1, The HERC incinerator generates significantly more health damagingair pollutants and criteria pollutants per megawatt of energy than the former RiversideGenerating Facility, which was coal powered in 2007, and retired in 2009.18

Table 2: Air Emissions from HERC by Pollutant19

Pollutant

Potential toEmit Tons PerYear

2007 ActualEmissionsTons Per Year



ProjectedActualEmissionsTons/Year

Particulate Matter 94.2 8.09 25.7 16.98 30.2

Particulate Matter 10 94.2 8.09 25.7 16.98 30.2

Sulfur Dioxide 100 9.52 13.05 11.69 15.3

Nitrogen Oxide (NOX) 881.2 539.96 525.99 552.87 530

Carbon Monoxide 261.6 49.98 48.31 39.45 56.8

Volatile OrganicCompounds 26.2 1.14 0.87 0.58 1.3

Lead 1 0.00684 0.00233 0.00114 0.008

Hydrochloric Acid 98.8 65.01 52.74 52.77 76.4

Mercury 0.126 0.00294 0.00358 0.00484 0.0057

Cadmium 0.09 0.00101 0.000317 0.00115 0.0014

MWC Dioxins/Furans 7.35 x 10-5 1.33 x 10-6 3.29 x 10-6 5.23 x 10-6 6.14 x 10-6

MWC Metals 94.2 8.09 25.7 16.98 30.2

Table 2 shows the emissions of HERC, as self-reported, in comparison to the potential thefacility has to emit. Though reported emissions often of allowed potential, each pollutant is

significant in its environmental and public health impacts.

See pages 11-12 for a list of health effects directly linked to each pollutant.

17Minnesota Pollution Control Agency.

18Xcel Energy Inc. "Riverside Generating Station."Xcelenergy.com. 2012. Web. 28 Oct. 2011.

.19

Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency. Hennepin Energy Recovery

Center Environmental Assessment Worksheet Draft. Draft V. Minneapolis, 04 Dec. 2009.


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Issues with Accuracy of Emission Data

Although four of the toxins emitted from HERC are tracked by continuous emissionmonitoring (CEM) systems, the other pollutant estimates are only based off four yearlymeasurements taken at Covantas discretion. All permits and data are based off calculationsfrom these self-reported estimates, which attempt to predict annual emissions byextrapolating these four snapshot measurements. This practice fails to measure the actualimpact HERC has on air quality in Minneapolis and surrounding communities.

For example: when startup, shutdown, and malfunctions occur, emission changes areusually not reported. 20 A committee of the National Academy of Sciences observed in a reportpublished in 2000:

Such upset conditions usually occur during incinerator startup or shutdown when the

composition of the waste being burned changes sharply. Upset conditions can also becaused by malfunctioning equipment, operator error, poor management of the

incineration process, or inadequate maintenance.21

Following industry expert Alan Mullers review of HERC records, he shared that it:

Revealed many upsets, many but not all resulting from failed boiler tubes. Boiler tubes

fail due to some combination of inadequate maintenance and the burning of highly

corrosive fuels such as garbage. A tube failure injects large amounts of steam/hot water

into the combustion chamber, severely disturbing combustion conditions and causing

very high emissions which can last for hours.22

The draft Environmental Assessment Worksheet (EAW) of HERC thus far does not provideenough information to determine how close these estimates are to the actual emissions. Evenwhen the draft EAW is complete, it will lack these real emission measurements. It has beenindicated that the final EAW will include dispersion and deposition data relating to HERCemissions. If so, this would be a major step forward assessing the true impacts that HERC hason Minneapolis and surrounding communities. Even so, given the magnitude of known healthdamaging air emissions from HERC and potential health impacts, only a comprehensiveEnvironmental Impact Study (EIS) is capable of providing sufficient information to the public,and for assessing alternatives. With the information provided by the EIS, Hennepin Countyand the City of Minneapolis can more accurately assess the health impacts of an increase in

waste incineration.

20"Citizen's Petitions for an EAW for HERC Expansion."

21Waste Incineration and Public Health. National Academy of Sciences.

http://books.nap.edu/catalog.php?record_id=580322

"Citizen's Petitions for an EAW for HERC Expansion."


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PublicHealthWith an increase in materials burned, Minneapolis and surrounding communities can expectto see a proportionate increase in emissions. Although these increased emissions are not

likely enough (in isolation) to push Minneapolis into nonattainment of federal air standards,these standards only reduce health concerns; they do not eliminate health issues. As shown inTable 3 below, emissions from HERC have significant health consequences when introducedto human lungs.

Table 3: Health effects of HERC Pollutants

Pollutant Health Effect Rate

MonitoredNitrogenoxides

(NOx)

Low levels of nitrogen oxides in the air can irritate your eyes,nose, throat, and lungs, possibly causing you to cough and

experience shortness of breath, tiredness, and nausea.23

CEM System(Greenhouse

Gas & CriteriaPollutant)Carbonmonoxide

(CO)

CO can cause harmful health effects by reducing oxygendelivery to the body's organs (like the heart and brain) andtissues. At low concentrations, fatigue in healthy people andchest pain in people with heart disease. 24

CEM System(CriteriaPollutant)

Sulfurdioxide(SO2)

Children who live in or near heavily industrialized areas wheresulfur dioxide occurs may experience difficulty breathing,changes in the ability to breathe deeply, and burning of the noseand throat. Children may be exposed to more sulfur dioxide

than adults because they breathe more air for their body weightthan adults do.

Long-term studies surveying large numbers of children indicatethat children who have breathed sulfur dioxide pollution maydevelop more breathing problems as they get older, may makemore emergency room visits for treatment of wheezing fits, andmay get more respiratory illnesses than other children.Children with asthma may be especially sensitive even to lowconcentrations of sulfur dioxide.25

CEM System(CriteriaPollutant)

Particulate Exposure is linked to a variety of issues including: irritation of Estimate

23"ToxFAQs for Nitrogen Oxides."Agency for Toxic Substances and Disease Registry. CDC, 23 Mar. 2011. Web. 25

Oct. 2011. .24

"Basic Information on IAQ: Carbon Monoxide (CO)." EPA. Environmental Protection Agency, 12 Apr. 2011. Web. 25

Oct. 2011. .25

"ToxFAQs for Sulfur Dioxide."Agency for Toxic Substances and Disease Registry. CDC, 23 Mar. 2011. Web. 26 Oct.

2011. .


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Matter (PM) the airways, coughing, and difficulty breathing, reduced lungfunction, aggravated asthma, chronic bronchitis, irregularheartbeat, nonfatal heart attacks, and some cancers.26

based on fourdays a year(CriteriaPollutant)

Volatile

organiccompounds

(VOC)

Eye, nose, and throat irritation; headaches, loss of coordination,

nausea; damage to liver, kidney, and central nervous system.Some organics can cause cancer in animals; some are suspectedor known to cause cancer in humans.27

Estimate

based on fourdays a year

Lead (Pb) Lead can adversely affect the nervous system, kidney function,immune system, reproductive and developmental systems andthe cardiovascular system. Lead exposure also affects theoxygen carrying capacity of the blood.28

Estimatebased on fourdays a year.Pb is a bio-accumulatingsubstance(CriteriaPollutant)

Hydrochloric Acid (HCI)

Chronic occupational exposure to hydrochloric acid has beenreported to cause gastritis, chronic bronchitis, dermatitis, andphotosensitization in workers. Prolonged exposure to lowconcentrations may also cause dental discoloration anderosion.29

EPA has notestablished aReferenceDose forhydrochloricacid.

Mercury Impaired neurological development for children. Mercuryexposure at high levels can harm the brain, heart, kidneys,lungs, and immune system of people of all ages.30

Estimatebased on fourdays a year

Cadmium Long-term exposure to lower levels of cadmium in air, food, orwater leads to a buildup of cadmium in the kidneys and possible

kidney disease. Other long-term effects are lung damage andfragile bones.31

Estimatebased on four

days a year

MWC

Dioxins &

Furans

Are persistent, bioaccumulated and likely to be humancarcinogens and are anticipated to increase the risk of cancer atbackground levels of exposure.32

Estimatebased on fourdays a year

26"Particulate Matter (PM)." EPA. Environmental Protection Agency, 23 Mar. 2012. Web. 09 Apr. 2012.

.27

"Volatile Organic Compounds (VOCs)." EPA. Environmental Protection Agency. Web. 25 Oct. 2011.

.28"Lead." EPA. Environmental Protection Agency, 29 Mar. 2012. Web. 09 Apr. 2012. .

29"Hydrochloric Acid (Hydrogen Chloride)." EPA. Environmental Protection Agency, Jan. 2000. Web. 25 Oct. 2011.

.30

"Health Effects of Mercury." EPA. Environmental Protection Agency, 7 Feb. 2012. Web. 09 Apr. 2012.

.31

"ToxFAQs for Cadmium."Agency for Toxic Substances and Disease Registry. CDC, 3 Mar. 2011. Web. 25 Oct. 2011.

.32

"Dioxins and Furans." EPA. Environmental Protection Agency, 18 Apr. 2011. Web. 25 Oct. 2011.

.


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Heath Concerns about Dioxins, Furans and Particulate Matter

Two pollutants considerably harmful to human health, dioxins and furans, are among thetoxins emitted during the incineration process. Incinerators cause significant emissions ofdioxin and other chlorinated organic compounds that have well known toxic impacts on

human health and the environment.33

Dioxins are known carcinogens at low doses andbioaccumulate over time, so communities in the vicinity of an incinerator continue to storethese harmful pollutants each time they are introduced in their bodies. 34

Particulate matter (PM) is a criteria pollutant that is made up of very small particles thatpenetrate lungs and cause adverse health effects. These health problems include asthma, lungcancer, cardiovascular issues and premature death.35 The matter is categorized based on size.PM is the name of particulate matter emitted, and is labeled with a number that describes thesize of the particle. PM 10 is one of the smaller particles. It is these respirable particles, andespecially the ultrafine particles, which can reach the deepest regions of the lungs, and whichare thought to be responsible for causing adverse impacts on human health.36

The majority of particulate matter from incinerators is ultrafine in size, and current airpollution control devices on incinerators only prevent 5 to 30% of the respirable (


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Some reported elevated exposure among nearby residents while others found no evidence ofincreased exposure.39

Map 1: Average per capita income in communities surrounding HERC

39Allsopp, Michelle, Pat Costner, and Paul Johnston 25.

HERCTables 1 and 2 were created at

the request of Representative

Karen Clark (District 62A)


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Map 2: Asthma hospitalizations per 10,000 people in communities surrounding HERC

As seen in Maps 1 and 2, the residential areas within a two-mile radius surrounding HERC isprimarily low-income and has high levels of asthma hospitalizations. With an expandedpermit, the negative health effects of air pollution can be expected to increase.

Although many studies confound data about incineration in general, scientists have directlylinked toxins like particulate matter and sulfur dioxide to diseases like asthma and otherchronic health problems. The average rate of asthma hospitalizations for the United States is17 per 10,000 people in the most recent data from 2004.40As can be seen in Map 2, themajority of the communities around the HERC have over 41 asthma hospitalizations withsome areas as high as 200+ hospitalizations due to asthma per 10,000 people. This data alsoindicates what scientists have known for some time; childhood exposure to pollutantsincreases with decreasing socioeconomic status.41

40"Asthma Prevalence, Health Care Use and Mortality: United States, 2003-05." CDC. Centers for Disease Control and

Prevention, 06 Apr. 2010. Web. 4 Nov. 2011. .41

"The Biology of Disadvantage: Socioeconomic Status and Health."ANNALS OF THE NEW YORK ACADEMY OF

SCIENCES 1186.1 (2010): 1-275. Web. .

HERC


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Children and Air Pollution

There are eighteen elementary schools operating within a two-mile radius of the HennepinCounty incinerator. Children are disproportionately affected by air pollution due to their size,rate of breath, and type of breathing. Children typically breathe fast and through their mouth,

which allows them to take in air quicker and without the nose as a filter for pollution.42 Withsignificant, consistent exposure to the pollutants emitted, Minneapolis children are thepopulation at highest risk to feel the negative health effects of the diminished air quality.

Children tend to be especially vulnerable to criteria pollutants, including particulate matter.Studies have also shown that criteria pollutants can affect lung function and growth forexposed children. High levels of PM exposure can trigger an asthma attack faster in childrendue to irritation and inflammation in their small airways.43

This exposure can also cause damage in the long run. Irritants and toxicants present in airand water can result in cellular and molecular level damage that, when initiated during

childhood or adolescence, could create vulnerabilities to future disease.44

It should also be noted that the impacts of HERC extend well past the City of Minneapolis andHennepin County. Though these two governmental bodies have direct authority over thefacility and the proposed expansion, they are not the only communities impacted. The diffusenature of pollution from HERC warrants broader consideration about all the communitiesimpacted by this proposal.

Finally, HERC collects and burns garbage from all municipalities in Hennepin County, creatinga perverse incentive that works counter to the preferences contained in the solid wastemanagement hierarchy put forward by the MPCA. Even if cities like Minneapolis choose to

adopt policies that encourage residential composting and other zero-waste initiatives, HERCwill continue to work at full capacity. This means that if Minneapolis does a better job ofmanaging and reducing waste, its citizens will still be subject to the air pollutions from HERC pollution that comes from surrounding cities.

42"OEHHA Air: Air Pollution and Children's Health." Oehha.ca.gov/. Office of Environmental Health Hazard Assesment,

26 Nov. 2003. Web. 04 Dec. 2011. .43

"OEHHA Air: Air Pollution and Children's Health."44

"The Biology of Disadvantage: Socioeconomic Status and Health."ANNALS OF THE NEW YORK ACADEMY OF

SCIENCES 1186.1 (2010): 1-275. Web. .


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GreenhouseGasEmissionsGreenhouse gasses are chemicals that trap heat inside the earths atmosphere and contributeto global climate change. The main greenhouse gas contributors produced from the

incineration process are carbon dioxide (CO2), methane, nitrogen oxides (NOx),hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. They are reported as CO2equivalent (CO2e) in Table 4 from the draft HERC EAW.45 Despite being considered aninnovative energy solution in some states, waste-to-energy plants in the U.S. emit morecarbon dioxide per megawatt-hour than coal- fired, natural-gas fired, or oil-fired powerplants. 46

Table4:CarbonDioxide(CO2)EmissionsDatafromDraftHERCEAW

The analysis and modeling of greenhouse gas emissions from municipal solid wastecombustion (MSW) in Table 4 only includes scope 1 & 2 emissions, which are the two types ofemissions in direct control of the facility. Covantas draft EAW for HERC fails to report ormodel the scope 3 greenhouse gas emissions, which include the activities and shipment ofwaste before and after its time at the Center. 47 This is a major deficiency in that HERCreceives waste not only from Minneapolis, but from its neighboring cities in Hennepin County.As a result, transportation of that waste and emissions related to the transportation must bemeasured to assess HERCs full impact.

45Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 31.

46Eureka Recycling. Recycling, Composting and Greenhouse Gas Reduction Minnesota. Eureka Recycling. Web. 5 Nov.

2011. http://www.eurekarecycling.org/pdfs/Composting_Recycling_GreenhouseGases.pdf2.47

Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 31.


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In 2007, the Minnesota legislature passed the Next Generation Energy Act, with the goal ofreducing greenhouse gas emissions among all sectors by 15% below 2005 levels by 2015,30% by 2020, and 80% by 2050.48 Increasing the waste burned in the incinerator willsignificantly increase greenhouse gas emissions and is converse to the goals of this Act.The proposed expansion would increase the amount of CO2 emitted from the

incinerator by 53,701 tons of CO2e, which is equivalent to consuming 113,295 barrels of oil,using 9,552 passenger vehicles for a year, or sequestered by 10,387 acres of fir-tree forest. 49

48Minnesota Statutes 2008, section 216H,02, subdivision 1.

49http://www.epa.gov/cleanenergy/energy-resources/calculator.html#results


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ToxicAshDisposalThe first law of thermodynamics states that energy or matter can neither be created nordestroyed. Although the concept is simple, it is important to keep in mind that waste does not

disappear when burned.When municipal solid waste is burned in an incinerator, about 20%or approximately 400lb/ton remains as ash. 50 Throughout that process, heat is generated andit releases matter and gases into the air. 51 The remaining waste is classified into twocategories: fly ash and bottom ash, both of which are concentrated forms of the wasteburned.52

The fly ash is concentrated debris from pollutant filters, typically containing toxic metals andorganic matter. The majority of the ash remaining from the incineration process is calledbottom ash, which makes up about 80-90% of incinerator weight. The main chemicalcomponents of bottom ash are silica (sand and quartz), calcium, iron oxide, and aluminumoxide.53 Both of these materials must be trucked to and disposed of in landfills in Minnesotaat a significant cost to the incinerator.

Ash from incinerators poses a greater risk to contaminating groundwater than other forms ofwaste because of the high concentration of metals and toxins. A study of incinerator ashlandfilling demonstrated that, the ability of the wastewater extracts to cause geneticmutation was ten times as great in an incinerator capable of only incomplete combustion;10% of these mutagens were reportedly disposed in the wastewater.54

The ash from HERC is currently disposed of in two landfills, the majority of which (~80%) ishauled to the landfill in Rosemount, Minnesota. The ash from HERC is stored in its own cell,where its leachate is tested for compliance with EPA and MPCA regulations and discharged tothe Metropolitan Waste Water Treatment facility in St. Paul, Minnesota. The remaining 20%ash is hauled to the ash monofill at the Lake Area Disposal Landfill in Sarona, Wisconsin. Ashfrom the HERC is combined with ash from other waste combustor facilities and disposed inthe ash monofill.55


Torres Ray , and D. Scott Dibble.51Combs, Susan.

52Lam, Charles H. K.; Ip, Alvin W. M.;Barford, John Patrick;McKay, Gordon. 2010. "Use of Incineration MSW Ash: A

Review." Sustainability2, no. 7: 1943-1968.53

"Municipal Solid Waste." EPA. Environmental Protection Agency, 19 Mar. 2012. Web. 9 Apr. 2012.

.54

Rowan, S. C. "Incinerator Toxic Emissions: a Brief Summary of Human Health Effects with a Note on Regulatory

Control." Medical Hypotheses 52.5 (1999): 389-96. Pubmed.gov. Harcourt Brace & Co. Ltd, May 1999. Web. 20 Sept.

2011. http://www.ncbi.nlm.nih.gov/pubmed/10416945 pg. 5.55

Covanta Hennepin Energy Resource Company LP. & Minnesota Pollution Control Agency 20.


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TheCostofIncinerationAlthough an incinerator may sound like an economically viable option for waste disposal andenergy generation, the overall costs are incredibly high. Incineration is not an efficient way to

generate electricity because it has to spend money to dispose of the waste ash, comply withpollution control standards, and upgrade the mechanical aspects of the plant. The U.S. EnergyInformation Administration compared the capital and operating costs of incineration with 26other ways to generate electricity and found that it has the highest capital cost and highestfixed operating and maintenance costs.56

Minneapolis Solid Waste & Recycling specifically services approximately 105,000 households,with ~101,434 of those recycling. Service revenue has been estimated at $28 million for 2011,compared to $27.6 million for 2010.

Table5:SolidWasteDisposalFeesforMinneapolis57

Base Fee $24.00 per month

Disposal Fee + 5.00 for disposal of one large cart worth of garbage

+ 3.00 for disposal of one small cart worth of garbage

Recycling Credit - 7.00 if you participate in the recycling program.

Tax Total bill x 9.75% = State Waste Tax

As shown in Table 5, the 2011 base unit charge was set at $24 per dwelling unit withadjustments of $7 made for recycling credits. Monthly charges for large and small disposalcarts are set at $5 and $3, respectively. Increase in service revenue is due to anticipatedrevenues from large cart to small cart conversions.58 The $3 $5 disposal fee paid byMinneapolis residents goes towards tipping fees paid by waste haulers to HERC. As a resultMinneapolis taxpayers are paying upwards of $6,300,000 annually to pay for the cost of itsoperation (assuming all Minneapolis residents have a large cart). In essence, Minneapolisresidents are paying for an industry to pollute themselves and their neighbors. When youcontrast these economics with those of recycling, which are addressed later on, this is anincredibly difficult policy to justify and maintain.

56Updated Capital Cost Estimates for Electricity Generation Plants, U.S. Energy Information Administration in

November 201057

City of Minneapolis. "Billing." City of Minneapolis, Minnesota - Official Web Site. Web. 18 Oct. 2011.

.58

"City of Minneapolis 2011 Budget Financial Plan." City of Minneapolis. Web. 8 Dec. 2011.

.


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Costs and Benefits of Garbage Incineration Relative to Alternatives

One of the best ways to assess particular strategies in dealing with solid waste is to examinethe costs and benefits of a particular approach. However, this is a very difficult calculation tomake given the range of uncertainty regarding how much, and at what price waste is being

managed in Hennepin County and Minneapolis in particular. The best data available comesfrom the Minnesota Pollution Control Agencys Metropolitan Solid Waste Policy Plan and theircalculations on cost/ton and total cost of various waste management strategies. Table 6extrapolates that data to determine total waste being managed and applies an estimate of howmuch waste was managed with that strategy.

Table 6. Cost associated with waste management strategies in Metropolitan Area.

ManagementMethod

Cost/ton Total WasteManaged (tons)

Total estimatedcost

% of WasteManaged withMethod

Recycling $110 $143 1.1 1.3 million $121 138

million

38.53%

Organics $80 193 11,000 87,500 $880,000 $7million

0.39%

Garbage

Incineration

$168 207 982,143 1.2million

$165 203million

34.40%

Landfill $130 162 761,538 946,154

$99 -123 million 26.68%

Total waste managed tons were estimated using the least cost/ton estimate divided into the total estimated cost

contained in the Metropolitan Solid Waste Policy Plan.

Though there is much variability in the data, it is evident on a simple cost per ton basis that

garbage incineration is the most expensive way to address this issue. In contrast, sourceseparated organics (or composting) and recycling offer far better rates of return per dollarspent. The operating costs of HERC are anticipated to be $21.5 million in 2011. When thiscost is contrasted with the estimated $5.5 million spent on recycling programs by HennepinCounty, it reflects a huge disparity in that per-ton garbage incineration expenses are nearly 4times as great as recycling programs. While it should be noted that the costs stated here aretotal costs of these programs versus just the public costs incurred, they do reflect the price ofthese solid waste management strategies.

Finally, this report doesnt include additional economic costs of an expansion to burningrelated to air pollution. The various health impacts, though often difficult to quantify in direct

economic values, are nonetheless real and should be a serious consideration when ponderingthe costs and benefits of expanding garbage incineration. Further, this analysis does notaddress the costs and benefits of reducing waste altogether.


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EnvironmentalAssessmentWorksheetInadequacies:

Why Minneapolis needs an Environmental Impact Statement

Covanta has proposed that the HERC incinerator increase to full capacity burning, meaning a20% or 212 tons increase. This increase liesjust underthe 250 tons that would mandate anEnvironmental Impact Statement, and allows the use of a less extensive EnvironmentalAssessment Worksheet to analyze the potential impact of expansion. 59

The initial Environmental Impact Statement (EIS) for HERC was compiled in 1986. Using thesedated numbers means that the emission estimates, estimated health impacts, and impact ofalternative means of disposal inadequately describe risks posed today. While the EIS from1986 is inadequate, the proposed increase is an appropriate time to re-examine the realimpact of the Center today. The latest financial data for Covanta Holdings from bothBloomberg and Morningstar make it readily apparent that the company is more than capable

of financing the costs of an EIS. Given the impacts of the project on our environment, it isproper for them to do so.60

Michael Greenberg, an expert in environmental policy describes, One of the greatestdrawbacks of the EIS process relates to administrative discretion () By allowing extensionsof some permits, the EPA is allowing abuse of some of the most harmful environmentalpolicies.61 Covanta has clearly sought a similar route with the incinerator, In November 2009Covanta and Hennepin County attempted to circumvent environmental review altogether byapplying to the Pollution Control Agency for a rarely used administrative permit. 62 Covantasought this permit to avoid the process of completing an Environmental AssessmentWorksheet (EAW), which it has now stalled by failing to provide the MPCA sufficient

information to complete the EAW.63

It is critical to understand the real impact of incineration on the city before the proposalmoves forward.


Torres Ray , and D. Scott Dibble.60

Frank Hornstien, State Representative.61

Michael R. Greenberg, Environmental Policy Analysis and Practice, pg. 19162

Frank Hornstien, State Representative.63

State Representatives, Frank Hornstein, Jean Wagenius , Jim Davnie , Bobby Joe Champion , Diane Loeffler , Patricia

Torres Ray , and D. Scott Dibble.


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APathForward:TheBenefitsofCompostingandRecycling

Current Waste Composition

As you can see from Graph 1, provided by the HERC draft EAW, less than half of the wastepicked up from residential garbage carts is non-recyclable or recoverable material intendedfor incineration. Recoverable material comprises more than half of the material disposed of byresidents. If even a portion of the material is diverted, citizens can dramatically reduce theresources destroyed in the incineration process.

Graph 1: Composition of Garbage Carts in undisclosed community

According to SCORE data shown in Graph 2, the recycling rate of Hennepin County hasremained flat since the plant began its operations in 1989.64 This rate looks at the proportionof total waste that is recycled, not the percentage of recyclables that are recycled. Despitestagnant performance for two decades, the Hennepin County waste management plan onlyseeks to increase the recycling rate by a small percentage. Extrapolating this plan, we haveadded what the recycling rates would be expected to look like over the next 8 years to thegraph.

64Hennepin County Environmental Services.


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Graph 2: Hennepin County Recycling Rates: Appendix A

Though garbage incineration was originally proposed as a transition solid waste management

strategy, this data seems to indicate a stall in policies aimed at increasing recycling rate.

Energy Advantages of Recycling and Composting

The benefits of recycling and composting over incineration are significant. Overall, recyclingproduces a net reduction in energy 3.6 times larger than the amount of energy generated byincineration and 11 times larger than the energy generated by methane recovery at alandfill.65 Although incineration does generate some energy, it does not compare to theamount of energy saved from recycling and composting. Methane from landfills and the BTUsgenerated from incinerators are sometimes captured and converted into energy. However,energy from waste is inefficient and does not eliminate the pollution.66 When composting orrecycling, you eliminate the need to extract, process and transport new raw materials for aproduct. At the same time, in the U.S., four primary materials industries paper, metals,plastics, and glass consume 30.2% of the energy used for all U.S. manufacturing. 67

In addition to outright energy savings, using compost for soil application allows for energysavings from reducing need of machinery, engineering, development, and maintenance forimproving soil quality. Compost applications increase soil organic matter, thereby reducingsoil erosion, water logging, nutrient loss, surface crusting, siltation of waterways, and more.68When used for agricultural purposes, compost can reduce the need for chemical fertilizers as

well. Synthetic fertilizers, for instance, are huge emitters of NOx emissions; in the U.S., theseemissions represented 88.6 Teragram CO2E or 1.2% of all greenhouse gas emissions in2005.69

65Eureka Recycling 4.

66Eureka Recycling 2.

67Platt, Brenda, David Ciplet, Kate M. Bailey, and Eric Lombardi 19.



0

10

20

3040

50

60

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

2020

Lb.Recycled/Total

Waste

Generated

Year

Hennepin County SCORE Recycling Rates


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Economic Advantages of Recycling

Incineration and landfilling may be convenient options for waste disposal, but theirconvenience comes at a price for the economy. Tipping fees paid by trash haulers for wastedisposal vary by state, but on average tipping fees are highest for incineration, whereasrevenue is actually generated from some recycling programs.70

By developing the infrastructure for recycling and composting, a community is investing inlocal jobs. Incinerators and landfills sustain only 1 job for every 10 positions at a recyclingfacility.71 Recycling and composting initiatives create jobs that can serve toward bolsteringthe local Minneapolis economy not to mention its environment and the health of its citizens.More research is needed to determine exactly how much additional revenue, and how manyadditional jobs, could be expected with increased diversion of recoverable materials from thecurrent waste stream.

Environmental Advantages of Recycling

When material is combusted in an incinerator, the material is permanently lost. Thiscontinues demand for extraction of new materials to create new products. For every ton ofmunicipal waste discarded, about 71 tons of waste are produced during manufacturing,mining, oil and gas exploration, agriculture, and coal combustion. When material is recycled,it continues to provide material for new product and lessens the demand for extraction. Forevery ton of virgin aluminum recycled, 2.7 tons of solid waste related to mining, extraction,

and virgin material manufacturing are avoided.72

Resource extraction, production and transport are all energy intensive processes that lead tothe production of greenhouse gasses. Much of this energy used is from non-renewable

70Ljupka Arsova, Rob Van Haaren, Nora Goldstein, Scott M. Kaufman, and Nickolas J. Themelis. "The State Of Garbage

In America." BioCycle 49.12 (2008): 22. Web. 26 Oct. 2011. .71

The Institute for Local Self Reliance 62.72

The Institute for Local Self Reliance 21.

Energy Saved by Recycling

Paper 44% energy

savings v. rawmaterials

Glass Bottle 30% energy


Aluminum Can 90-97% energy



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resources such as coal and oil. These non-renewable fuel sources have significant impacts onair pollution, land degradation and climate change.

Many of the health damaging air pollutants also have a negative impact on the environmentalsurroundings and bioaccumulate in the soil and animals. These toxins include mercury; this

chemical travels to bodies of water and has been found to increase the risk of cancer forpeople consuming fish with high mercury content. Particulate matter also contributes to areduction of visibility in industrial facilities, acidifying lakes and rivers, and acid rain thatdegrades stone and other materials.73

Graph 3: HERCs Waste Isnt Garbage74

As Graph 3 shows, the most recent waste analysis required of Covanta under its permits show32% of the materials entering HERC are organics and over 51% are recyclables.75 This meansthe majority of material can be captured and diverted to recycling and reuse efforts, leavingonly 16.5% as other waste. Most of this other waste is comprised of items (likeelectronics, appliances, construction debris, and tires) that have specialized disposalrequirements and cannot be incinerated. This leaves the remaining ~10% of waste, which islargely made up of furniture, mattresses, leather, clothing, carpets, and all the small materials

that fall to the bottom throughout the sorting process. These items are the items that wouldremain if our waste stream was properly managed before materials reached the HERC. Withsuch a small group of items to dispose of in an efficiently managed waste stream, focus can

73"Particulate Matter (PM)."

74Covanta Hennepin Energy Resource Company, L.P. Solid Waste Composition Study Report of the Hennepin Energy

Recovery Center. 14 Sept. 2007. Raw data. Minnesota, Minneapolis.75

Covanta Hennepin Energy Resource Company, L.P. Solid Waste Composition Study Report of the Hennepin Energy

Recovery Center. 12 Nov. 2012. Raw data. Minnesota, Minneapolis

Organics

32%

Paper

31%

Plastics

15%Metals

4%

Glass

2%

Electronics/Appliance

3%

Textiles/Leather

3%

Construction Debris

3%Furniture/Tires/Other

7%

HERC Solid Waste Composition

Organics Paper Plastics

Metals Glass Electronics/Appliances

Textiles/Leather Construction Debris Furniture/Tires/Other


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shift to how to best reuse and recycle these remaining products. This is what San Franciscohas done, beginning to create jobs by establishing markets for the reuse of goods that wouldbe otherwise disposed. The alternatives before our community, along with the fact that theamount of recyclable and compostable materials is significantly greater than the amount ofwaste for which HERC is seeking to increase incineration, effectively eliminates the need for

such an expansion.

With over 90% of the materials currently being incinerated at HERC having alreadyestablished disposal methods that are more efficient than incineration, the conversation mustshift to better waste management systems. Graph 1 showed that residential carts are bettersorted than the waste that arrives at the HERC, as seen in Graph 3. This leaves the impressionthat while residents are to blame for some of this errant disposal, there are huge holes in oursystem that we must explore before we can even consider burning more of our so-calledgarbage.


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Conclusion

When HERC was approved and built in the late 1980s, it was assumed to be a short-termalternative to direct landfilling while other programs and capacities were developed.

Recycling and composting were assumed to eventually take away the need for the Centeritself. Separate from the desires of Covanta, the HERC facility was intended not as a wastemanagement solution, but rather a placeholder for technologies to come.

Today, we have the technology and information to understand - more than those involved inthe original construction of HERC ever could - just how deep the impacts of incineration areand just who poorly we are doing at recovering materials. Decision makers need to reevaluatewhether HERC is a necessity for an era where nearly everything being incinerated could bediverted from the waste stream into already established processes for reclaiming materials.

Recommendations

As demonstrated in this report, waste incineration presents challenges in energy efficiency,economic efficiency, public health concerns, and more. MPIRG strongly contends that thepreponderance of the evidence supports the following recommendations:

1. The Minneapolis City Council should deny Covanta the conditional use permit toincrease waste incineration at HERC by 20%, or 212 tons of garbage per day, as thecitys comprehensive plan dictates negative health effects to Minneapolitans should beavoided in zoning decisions.

2. The City of Minneapolis should move towards curbside composting as a wastereduction strategy to remove the 32% of incinerated materials that are organics.

3. The City of Minneapolis should continue its efforts to streamline recycling to increaseparticipation rates and remove the 51.5% of incinerated materials that are recyclables.

4. Hennepin County and the City of Minneapolis need to seriously consider how HERC fitsin the current waste management scheme. The key consideration being the ratherperverse incentive that HERC creates by allowing for improperly sorted waste fromacross Hennepin County to be burned. By doing so, not only does Minneapolis bear thebrunt of air pollution deposition, it also reduces the incentive that other cities have toreduce their waste through recycling and composting.

5.

Failing these other policy recommendations, at the barest minimum a full EIS shouldbe required to determine the extent of negative health effects.


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Appendix A76

Table of recycling rates in Minneapolis by yearRecycling Rates Minneapolis

Year Total Trash Total Recycling Total Waste Recycling Rate

1991 713,747 617,438 1,331,185 0.463825839 46.38258394

1992 700,762 659,256 1,360,018 0.484740643 48.47406431

1993 689,081 676,992 1,366,073 0.495575273 49.55752731

1994 729,326 686,982 1,416,308 0.485051274 48.50512742

1995 752,218 561,795 1,314,013 0.427541432 42.75414322

1996 791,457 577,621 1,369,078 0.421905107 42.19051069

1997 844,730 571,563 1,416,293 0.403562681 40.35626809

1998 885,288 577,914 1,463,202 0.394965288 39.49652885

1999 904,947 588,053 1,493,000 0.393873409 39.38734092

2000 939,831 594,111 1,533,942 0.38730995 38.73099504

2001 986,001 591,289 1,577,290 0.374876529 37.48765287

2002 959,509 593,274 1,552,783 0.382071416 38.20714163

2003 1,005,694 591,844 1,597,538 0.370472565 37.047256472004 947,994 603,722 1,551,716 0.389067329 38.90673293

2005 984,538 597,180 1,581,718 0.377551498 37.75514978

2006 982,230 598,219 1,580,449 0.378512056 37.85120558

2007 982,805 604,239 1,587,044 0.380732355 38.07323552

2008 854,215 596,972 1,451,187 0.411368073 41.13680732

2009 784,128 573,038 1,357,166 0.411368073 41.13680732

Appendix B

Definition: Environmental Impact Statement (EIS)

An EIS must contain a detailed statement of the following 5 factors771. The Environmental impact of the proposed action2. Any adverse environmental effects that cannot be avoided if the proposed

action is implemented3. Alternatives to the proposed action4. The relationship between local short-term uses of the human environment and

the maintenance and enhancement of long-term productivity5. Any irreversible and irretrievable commitments of resources that would be

involved if the proposed action is implemented

76 MN SCORE Recycling Data77 Environmental Policy Analysis and Practice, Michael R. Greenberg (189)


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Documents

REPORT: Reevaluating Waste Management in Minneapolis