The Problems of Incinerators in Taiwan

George Chen, Executive Director, Taiwan Watch Institute

Herlin Hsieh, Assistant Researcher, Taiwan Watch Institute

Threaten from Burning Policy

Owing to the limited land areas and the high density of population, as well as the long-term principle adopted by the government’s policy that the economic development is always the first priority, Taiwan has become a linear society that has been subjected to the values of mass consumption. Furthermore, with mass production and mass consumption, it generates mass of waste. In order to dispose of the unwanted and dislikeful waste, with the difficulty of finding possible sites for landfills, and the pressure coming from garbage wars between townships that caused pile of garbage on the street, our government decided to use the most simple and fastest way of waste treatment to meet the urgent need of Taiwan. Hence, in 1986, on a technical meeting held by Executives Yuan, it was decided to adopt incineration as the first priority for waste treatment and landfills as the secondary one. And the incineration was deemed as a long-term waste disposal method. Consequently, in 1990, a plan called “Construction Project for MSW Resource Recovery Plants”, for building 21 large-capacity MSW incinerators, was proposed by the EPA. Again in 1996, another plan was proposed to encourage the public owned and private enterprises to build another 15 large capacity MSW incinerators in BOO/BOT. Hence, the EPA planned to build a total of 36 large capacity of MSW incinerators, of which 4 plants that their building projects have been abandoned by the government due to the great objection from the communities. If it proceeds as the EPA’s expectation that the projects of building 32 large capacity incinerators can be finished by 2008, then the total design capacity of all the incinerators in Taiwan, including 11 small capacity MSW incinerators , 17 medical waste incinerators, and 63 industrial waste incinerators, will reach 27,300 tons per day. If the national waste generation is kept at 20,000 tons per day, which is the current national daily waste generation, then by 2008, another miracle will happen again in Taiwan, that is the incineration rate of waste would reach 100%, and will be another world number one.

Heavy Burden from Too Many Incinerators

We don’t have enough garbage to afford it, not to mention the sufficiency of the money and health to afford the toxics generated by the incineration.

The “Construction Project for MSW Resource Recovery Plants” proposed by the EPA in 1990 is based on the assumption of 5% annual growth rate of MSW, and calculated from 1990 with a national waste generation of 18,753 tons per day that year. In this case, the national waste generation would reach 26,378 tons/day in the year 1997. On the other hand, not only did the annual national waste generation stop growth, but it also decrease since 1998, from 24,331 tons per day in the year 1997 down to 19,886 tons per day in the year 2001. It shows a great discrepancy between the expectations of the so-called“fix (already decided) policy” and the actuality. (Please refer to Table 1)

Currently there are 19 large capacity MSW incinerators in operation. The total design capacity of these 19 incinerators is 21,000 tons per day, which is over the current national waste generation of 19,886 tons per day. Furthermore, there are less than 9,000 tons per day of waste sent to the incinerators. It results in a surplus capacity of 12,000 tons per day, which is 29% more than the 9,300 tons per day of the general industrial waste that was planned by the EPA for sending to the MSW incinerators for disposal. Now many of the incinerators has been short of garbage, such as: Chayi Lutsao (嘉義鹿草) incinerator, which has a design capacity of 900 tons per day, has two furnace and only one of which is in operation; several months ago, Hsinchu City (新竹市)government publicly solicit the other city government to send their garbage to the Hisnchu incinerator; Pingtung Kenting (屏東崁頂)incinerator, with a design capacity of 900 tons per day, only burns 600 tons per day of garbarge; neither of the three incinerators in Taipei city do operate in full capacity, and Baitou(北投) incinerator, one the three incinerators, only use half of its capacity to burn garbage. In addition, the incinerators in South Kaohsiung City(高市南區)、Changhua Hsichou(彰化溪洲)、Kaohsiung Nengwu(高雄仁武)、Kaohsiung Gangshan(高雄岡山) all have the problems of not enough garbage for burning (Please refer to Table 2).

Official Illegal Dumping of Hazardous Ash

There will be 20% of ash left after the garbage is burned in addition to the emission of toxins from the stack and the wastewater. Among the ashes, 90% of which is bottom ash, 10% is the fly ash that is filtered and collected by the air pollution control devices. No matter how strict the dioxin emission standard set by the EPA for large capacity incinerators on August 6, 1997, which is 0.1 ng-iTEQ/Nm3, there is a lot of ash containing high level of heavy metals and dioxins, which is sent to landfills by authorities without proper treatment. Furthermore, the EPA revised the regulation in order to solve the problem of the inability of many incinerators to treat the ash properly.

The article 15 paragraph 4 of the regulation “The Methodologies and Facilities Standard for Storage, Cleaning and Treatment of General Waste” says: “The fly ash shall be stored and collected separately and shall not be mixed with the bottom ash.”. The fly ash is regarded as hazardous industrious waste in this regulation and shall be solidified and then sent to the specified landfills for the hazardous ash. But the article 20 paragraph 2 of the same regulation, which is revised on May 1999, says: “Fly ash that is mixed with the bottom ash, is used as covering materials on the landfills with 2 layers of water proof cloth underlain and reinforced pollution control devices, is regarded as a reuse activity.” It is revised for those incinerators without solidification facility. Now the two conflicted paragraphs coexist in the same regulation, a very ridiculous phenomenon.

Furthermore, the authorities never care about the fact that some of the bottom ash examined by the TCLP(Toxic Chemicals Leaching Procedure) has exceeded the standards and shall be regarded as hazardous industrial waste, not only the fly ash. (Please refer to the attachments concerning the analysis reports of the incineration ash.) They neglect the fact and ignore their responsibility of protecting the health and safety of the people by saying that their procedure for treating the incineration ash is in accordance with the regulation, in which the bottom ash is regarded as non-hazardous.

Even for those incinerators with solidification facilities, their actual procedure of the solidification is very casual. For instance, the solidified ash of the 4 incinerators in Kaohsiung area, which is sent to Yanchao(燕巢)landfills, is so fragile that it can not stand the slight tread of a person. According to our regulation, the solidified fly ash shall be capable of bearing over 10 kg/cm2 (around 10 atm) of pressure, which is high above the tread of a person. Make things more worse, around Yanchao(燕巢)landfills, there are orchards that grows fruits such as pamgranit(芭樂) and dates(棗子). Due to the unreliable solidification, the dioxin-contaminated dust from the crushed particles can be transferred by rain and wind, and then severely contaminate the fruits and crops nearby.

The incineration ash, no matter solidified or not solidified, is dumped on the landfills without caution, and cannot reach the loose standard set by the authority. At Shulin(樹林) landfill, where the incineration ash from the three incinerators of Taipei County was buried, there’s no water proof cloth covering the soil, thus the incineration ash is directly dumped on the soil. It would contaminate the soil and the underground water. As for the ash from Baitou incinerator, the largest and newest one of the three incinerators in Taipei City but without solidification facility, it shall be, after mixing, used as covering materials on the landfills with 2 layers of water proof cloth underlain and reinforced pollution control devices, according to the regulation. But it was found that the mixed ash was not used as covering materials but buried in a specified area of the Shanzhuku(山豬窟) landfill, with dust floating all over the air. Not only did it violate the regulation, but it has also caused great threat to the health of the workers. In south Tauyuan, the operator of the incinerator has been sending the incineration ash back to each township, which doesn’t have any ability to dispose of the incinerator, by the ratio of the waste they send to the incinerator. The result is that the incineration ash has been dumped all over the county.

Smuggling of Hazardous Waste into the MSW Incinerator

MSW incinerator is designed to burn the household waste, which component is simple, not so much toxic; the pollution generated is less severe. But the EPA allows the non-hazardous industrious waste to be burned in the MSW incinerators, it opens a way for the hazardous industrious waste to be smuggled into the MSW incinerator because it is impossible for operators to check so many garbage trucks in detail to see if there’s hazardous industrious waste mixed inside. It would create severe environmental pollution. In December 2001, some of the residents in Baitou(北投), as they cannot stand the stink from the incinerator in almost every night, made an un-notified inspection of the garbage trunk and found some medical waste was mixed inside.

Further, the EPA made an excuse for building more MSW incinerators by claiming that the 19 MSW incinerators has been operated in full capacity, based on a calculation of summing up the total quantities of the household waste and industrial waste. In this way, taxpayer have to pay money for building incinerators that is actually for the disposal of the waste generated by the industries, which, according to the regulation, shall be paid by the industries themselves. Isn’t it an official collusion with the business?

Shrinking the Budget for the Incineration Alternatives

The EPA has been repeatedly saying that their waste management policy of current stage is recycling, reduction (both are just cloaks) and “incineration”(it is the point). However, after years past, we could not find there’s any change in the 1986’s waste treatment policy, that is, the first priority of the EPA’s consideration is still incineration. In less than 12 years, they has built nearly 20 large capacity MSW incinerators, consumed nearly 100 billion NT$ (=3 billion USD) of the taxpayer’s money. But for the promotion of composting, one of the important incineration alternatives, there is still not a complete program, such as the standard models of the composting system for the urban area and the rural area. They have only been budgeting 200 or 300 millions NT$ (6 or 9 million UD$) each year for all the local governments’ composting programs. With so many programs to share the budget, there’s not so much left for each program. Under this circumstance, plus the lack of thoughtful executing program, the local governments have only been muddling through their work. Hence, the taxpayers’ precious money was consumed without efficiency.

In the “National Environmental Protection Program”, there are only 2 or 3 sentences describing how they will promote the treatment of the compostable that is over 25% (weight percent) of the household garbage. On the contrary, there are several pages describing how they will promote the building of incinerators. In addition, there are action plans and building programs that make the incineration policy implemented.

As for the resource recycling, there is a Resource Recycling Management Fund setup by the EPA, which is suffering a loss due to the poor management. For instance, this fund raises money from PET bottle makers and importers according to the quantities of PET bottles they have input to the markets, and then subsidize the recyclers based on the quantities of the PET bottles they have recycled. Now the PET bottles recycled are more than the PET bottles input into the market, thus cause a loss to fund. Facing this problem, the EPA decided to cancel the subsidy for PET bottles, without considering improving the real flaws in this practice. Not only does it threat the livelihood of the people relying on the subsidies of PET bottles recycling, but it will also reduce the recycling rate of PET bottles. Is it because there are so many incinerators eager for garbage, the recycling rate is not the point anymore? We cannot help but suspect that it maybe the real consideration behind the decision of the EPA. We remembered in 2001, when the incumbent head of EPB (environmental protection bureau) of Taipei City, Mr. S.H Shen, went with the Taipei City mayor Mr. E.J. Ma to visit the South Korea. When he is asked about the impression of the large-scale plan of collecting the organics for composting in South Korea, he boasted of the large capacity of the incinerators in Taipei that he didn’t have to worry about the treatment of the compostable.

A Dirty Collusion with the Syndicate

When there was news that the incinerators in Kaohsiung were competing for the garbage by reducing the charge of the treatment cost, the EPA claimed that the deficiency of garbage was not the problem of burning policy, but a result of the garbage market; In other word, the EPA still persist in the burning policy, and will finish the building of the total 32 MSW incinerators by the year 2008; then Taiwan would become the world number one burning country with incineration rate higher than 90%.

The “fix” burning policy set up many preferences to attract the investment of the syndicates. The 20 years contract to guarantee the definite amount of garbage is to guarantee the income of the business for 20 years, the refund of all the investment cost, as well as a quite high profit. The bid for the Yulin Linnai (雲林林內) incinerator with 600 tons/day of capacity was won by Daho company in 2001. In this company’s financial planning proposal, they estimated the pre-tax net profit during the operating period of 20 years would reach 4.47 billion NT$ (around 135.5 million US$), that is, 223.5 million NT$ every year, while the bid they won was 5.96 billion NT$, of which 3.01 billion NT$ was construction cost.

Let’s take another examples. Meilong(美濃) township has to provide 50 tons of guaranteed garbage to the Meilong small-capacity MSW incinerators, which charges 3,715 ND$ per ton for treatment cost. But now the actual amount of garbage from Meilong is less than 35 tons, that is, they have to pay the additional treatment cost of more than 15 tons per day continuously for 4 years; but the operator of a nearby incinerator, Nengwu (仁武) large-capacity MSW incinerator, they not only didn’t charge the treatment cost, but they also pay back to the Kaohsiung county government 147 ND$ for each tons of garbage treated. Both the incinerators mentioned above belonged to the Kaohsiung County. If the government think that the garbage has to be incinerated, why don’t they send the Meilong township’s garbage to the Nengwu incinerator?

Furthermore, in the contract of the under-construction Taidong MSW incinerator, which is designed with capacity of 300 tons per day for the garbage from both Taidong City and Taidong County, the guaranteed amount of garbage from Taidong City is 167 tons per day, while their actual amount of garbage is less than 100 tons per day. If this incinerator is built, then during the 20 years of operating period, they have to pay an additional treatment cost of 67 tons per day, with the treatment cost charged 2300 NT$ per ton. That is, they have to waste 154,100 NT$ per day, which equals to 56.25 million NT$ per year, or 1.12493 billion for 20 years.

When the syndicates win the bid for the incinerators, under the guaranteed contract, they don’t have to worry about the raising of money for the building and operation. Within 20 years of contract period, no matter how the market varies, the money will flow in continuously. Isn’t it a governmental guarantee that the syndicates can legally “rob” the taxpayer of their hard-working money? This policy is a “guarantee” to the syndicates, but a “ tyranny” for the people.

Sustainable Burning Policy

Before the planning and construction of the incinerators, the government should have known there will be 20% or 30% incineration ash left; and even the EPA secretary manager Mr. Y.N.Chen has pointed out, that according to the judge of USA supreme court, the incineration ash shall be regarded as hazardous industrious waste. Especially the fly ash is public recognized as containing high level of dioxins and heavy metals. But in the stage of the planning and construction, they didn’t consider and assess carefully the impact of the incineration ash at all, and the EPA pretended not see that the incinerators construction authorities or vendors didn’t attach the industrious waste disposal proposal for the approval of the local government before the application to the EPA for building the incinerator. It is a violation of the regulation. Now all the incinerators didn’t follow the regulation during the stage of EIA (Environmental Impact Assessment). The EPA, as the direct supervision authority, obviously has neglected its duty by not correcting the violation of the construction authorities and vendors in the long-term.