John Englart

Consultation on Wollert Waste to Energy Incinerator Plant

A Waste to Energy Plant has been proposed by Cleanaway in Wollert, in the Northern Suburbs. Public Consultation on the proposal has begun.

Update: Due to complaints from the community submission deadlines have been extended to 11:59pm on 14 April 2024.

Update 2: Community meets and hears speakers on Wollert Incinerator project. Submissions needed by April 14

Waste to Energy Plants produce Toxic air pollution and greenhouse gas emissions from incinerators. The ash that is produced also contains toxic chemicals, including potential for heavy metals and PFAS. In particular, we question why Victoria is the only state that approves large incineration projects without requiring an Environmental Effects Statement. For transparency and accountability, we call upon the Chief Health Officer (CHO) and the Deputy CHO (Environment) to undertake a study of scientific literature regarding the health impacts of waste incineration and to publish their findings.

Much of the feedstock of the waste to energy are plastics that can not be recycled. Many plastics can only be recycled a very limited number of times, or can only be down-cycled. At end of life plastics are embedded carbon that can produce energy when burnt, but they often contain many additive chemicals from the plastics production process. Solving the plastics crisis requires reducing plastics production and use, not burning them as waste to release the toxic chemicals that will have health and environment impacts.

The Australia Institute has identified in a new discussion paper published January 2024 that the federal government could raise $1,300 per tonne of ‘virgin’ or un-recycled plastic through a levy on businesses that import or manufacture plastic packaging. “Australia is facing a growing tsunami of plastic waste and is expected to miss every recycling target it has set,” the Australia Institute’s Circular Economy & Waste Program Director Nina Gbor said. “We’re recovering less than a fifth of the plastic waste used each year, with consumption expected to more than double to nearly 10 billion tonnes by 2050.”

The report found on Waste to Energy Incinerators:

About 10% of plastic recovery in Australia can be attributed to plastic waste that is
converted to energy. 79 This is mostly in the form of ‘processed engineered fuel’, which is commonly used for combustion in cement kilns.80 This has been called a “practical and sustainable alternative to the use of fossil fuels”.81 But while energy recovery from plastic has been branded a sustainable alternative to fossil fuels by industry, environmental organisations have generally disagreed. The Ellen MacArthur Foundation, for example, contends that “while some one-time extra value is gained from the product in the form of energy, the materials are then lost from the economy, which means new virgin materials are needed to produce the next generation of products”.82 To put it simply, plastic is made from oil and gas, so burning it simply replaces one fossil fuel product with another – albeit one that goes via another route first as plastics. This means that waste-to-energy does not move us away from what is ultimately a fossil fuel economy.

Research suggests that waste-to-energy is not simply a ‘neutral’ replacement
to conventional fossil-fuel based power systems, but one that is actually more polluting.
Researchers found that “the CO2 emissions generated from plastic waste-to-energy systems are higher than those from current fossil fuel-based power systems per unit of power generated”.83 The environmental costs associated with incineration do not stop at greenhouse gas emissions. Plastic waste incinerators have been found to release toxic air pollution associated with a high risk of cancer.84 Incineration is an environmentally costly way to deal with the glut of plastic waste, and one that may be worse than existing alternative solutions

Australia Institute – Plastic waste in Australia

Legal NGO, Environment Justice Australia, found that the Lara Waste to Energy proposed plant that would incinerate mixed commercial, industrial and municipal waste, including organics, metals, and plastics, will

“produce pollutants such as Carbon Monoxide, Nitrogen Dioxide, Sulphur Dioxide, Particulate Matter 10 (PM10) and 2.5 (PM2.5), Ozone, Ammonia, Hydrogen Chloride, Polycyclic Aromatic Hydrocarbons. It will also produce metals and semi-metals such as Hexavalent chromium, cadmium and mercury. For several of these chemicals, there is no safe exposure limit.”

EJA Media release July 21, 2023, Chemical cocktail: Lara waste-to-energy facility proposal is on the nose

Early in February 2024 Climate Action Merribek signed a joint submission to the Victorian Government Department of Energy, Environment and Climate Action (DEECA) on proposals for Waste to Energy Plants to be established. A Proposal for a Waste to Energy plant at Lara in Melbourne’s west is well advanced and the submission was co-ordinated by people in the Western suburbs and Geelong.

EPA Victoria has now just released a public consultation by Cleanaway Operations Pty Ltd (APP024914) for a Waste to Energy Plant in Wollert in the northern suburbs. It will be known as the Melbourne Energy and Resource Centre (MERC). It will be located at 510 Summerhill Rd, Wollert VIC 3750.

Another Waste to Energy Incinerator is planned for Sunbury or Sunshine.

Location of the Wollert Plant

The Plant location on Summerhill Road has Merri Creek 1.2km to the west, and intermittent watercourse tributary creeks within 400m on either side of the proposed plant location. These are part of the Merri Creek Catchment and provide flow into Merri Creek. Any toxic water pollution from the plant is likely to pollute the Merri Creek catchment.

Suburbs of Wollert are located 2km south-south-east of the plant. Criagieburn is located 3.4km west of the proposed plant.

Biodversity surveys for endangered species: Golden Sun Moth, Growling Grass Frog and Matted Flax Lilly did not find any presence of these species on the dates surveyed.

Development licence submission period closes on 20 March 2024. Consultation timeline:

  • In person information session 2 March 2024
  • Online information session 6 March 2024
  • Q&A closes 13 March 2024
Google Maps: Location of 510 Summerhill Road, Wollert

The Wollert Waste to Energy proposal

The MERC has been designed to thermally treat a design capacity of 380,000 tonnes per annum (tpa) of waste feedstock, consisting of residual Municipal Solid Waste (MSW) and residual commercial waste, which is waste that would otherwise be sent to landfill. Waste feedstock processed by the MERC will be subject to a Waste Acceptance Protocol to determine eligibility and suitability for processing both prior to arrival and upon arrival on-site. The Proposal will also incorporate maturation and processing of bottom ash to recover recyclable metals, with the intent to utilise the remaining ash as an aggregate in construction.

Residual waste is waste that is left over from recycling and resource recovery operations and waste from source separated collections. Source separation involves separating waste into common material streams or categories for separate collection. Waste processed at the site will be subject to a Waste Acceptance Protocol to ensure only appropriate waste is used as feedstock.

The WtE process would generate approximately 46.3MW gross of electricity, 4.7MW of which would be used to power the facility itself and the associated on-site by-product and residue handling processes, with 41.6MW (328,700 MWh/year) exported to the grid as base load electricity. In addition to supplying electricity to the grid, there is also potential to supply energy in the form of heat and/or process steam to local industrial users.

Projected Greenhouse Gas emissions

The projected greenhouse gas emissions are nominal figures based on data provided. Actual waste incinerated (and associated emissions) will change based on waste throughput and waste composition (calorific value), and other factors that may change over the life of the life of the project.
Combustion of waste during operation of the MERC is projected to contribute most of the Scope 1 emissions, at just over 187,000 tCO2-e/y. Approximately 3% of these emissions are due to combustion of organic (renewable) materials. Diesel combustion at boiler start-up or shutdown will contribute to just over 1,500 tCO2-e/y. This is reduced to 6 tCO2-e/y if biodiesel is used instead of diesel.
Scope 2 emissions arising from electricity purchased from the grid during start up and shut down of the boiler are projected to be just over 1,100 tCO2-e/y.
These Scope 1 and Scope 2 emissions will contribute to a 14.9% and 2.3% increase, respectively, to Cleanaway’s current reportable (NGER) emissions.

Katestone Environmental Pty Ltd – Greenhouse Gas Assessment (Nov 2023)

Environment Effects Study denied by Planning Minister

Unlike Lara, Wollert was actually referred to the Minister for Planning for an Environmental Effects Statement (EES). It was decided on 5th October 2023 that the project didn’t need one!

Submission to DEECA on Waste to Energy Plants

Here is the Summary of views & recommendations in the submission to DEECA on Waste to Energy Plants:

  1. We don’t believe any of the three proposed cap limits strike the right balance.
  2. We do not support doubling the volume of waste permitted to be heat treated. As none of the existing operators’ projects have advanced past the design stage, we think they should come under the same regulations. One million tonnes is already too much.
  1. We call on the government to pause the scheme until some of the existing operators have commissioned their plants and there is real evidence by which to judge their efficacy and safety.
  2. We call on the government to remove incineration as an acceptable thermal technology in its WtE scheme.
  3. We request that thermal waste projects require sizeable buffers and they should not be permitted in IN2Z industrial zones.
  4. We challenge the byline that the Victorian waste to energy framework is “supporting sustainable and appropriate investment”.
  5. DEECA needs to evaluate the impact on councils and ratepayers of the high WtE contract costs.
  6. Local communities facing the threat of a nearby incinerator are entitled to know it won’t become a stranded asset. Proponents should share a basic version of their business case and the government should require a bond in case of default.
  7. We continue to question why Victoria is the only state that approves large incineration projects without requiring an Environmental Effects Statement.
  8. We call upon the Chief Health Officer (CHO) and the Deputy CHO (Environment) to undertake a study of scientific literature regarding the health impacts of waste incineration and to publish their findings.
  9. We urge the government to put a moratorium on incineration projects while it fully investigates the public health risks and the growing evidence regarding the bioaccumulation of toxins in soils, agricultural produce and the environment.
  10. We expect the Victorian government to consult more constructively with affected local communities and environmental groups about its WtE policy and regulations.
  11. We recommend the Victorian government applies the UN Cleaner Production Principles to its WtE scheme.
  12. We urge the government to use its powers to drive investment in genuine reuse and zero waste programs and circular economy initiatives.
  13. We support Boomerang Alliance’s call for comprehensive product stewardship schemes that require industries to pay for collection and recycling programs for their products.
  14. We call on the Victorian and federal governments to drive packaging reforms and positive change in order to achieve their targets.
  15. We urge the Victorian government to boldly tackle the plastics problem and embrace the vision for a New Plastics Economy.
  16. We encourage the government to establish an extended producer responsibility scheme ASAP.

See Below for the full submission:

2024-02-02-Joint-Sub-VIC-WtE-Review-2Feb24Download

References

Engage Victoria – EPA Victoria, 20 February 2024, Cleanaway Operations Pty Ltd (APP024914) https://engage.vic.gov.au/cleanaway-operations-pty-ltd-app024914

Environment Justice Australia (EJA) Media release July 21, 2023, Chemical cocktail: Lara waste-to-energy facility proposal is on the nose https://envirojustice.org.au/press-release/chemical-cocktail-lara-waste-to-energy-facility-proposal-is-on-the-nose

See Zero Waste Australia list of Facsheets associated with Waste Incineration, https://zerowasteaustralia.org/publications/

Lilia Anderson and Nina Gbor, The Australia Institute, Plastic waste in Australia And the recycling greenwash, 12 January 2024, https://australiainstitute.org.au/post/plastic-packaging-waste-tax-could-raise-billions/

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