DAP Selangor's Comments on the DEIA Report for the proposed TTP at Broga

2003-10-09

Ketua Pengarah
Jabatan Alam Sekitar
Aras 3-7, Block C4
Pusat Pentadbiran Kerajaan Persekutuan
62662 Putrajaya

Tuan/ Puan,

RE: Comments on the DEIA Report for the proposed TTP at Broga

Selangor DAP wishes to register our strongest objection against the Thermal Treatment Plant for Solid Waste Management at Broga, Mukim Semenyih, Daerah Hulu Langat, Selangor. We believe that such project is unsustainable both environmentally and economically.

With the study and technical advice provided by several experts in the related fields, we are presenting our comments and views to your department, with the hope that your good office will treat our comments seriously.

Enclosed herewith a detailed response by Ingo Goedeke (a retired Chemist residing in Germany) to the DEIA presented by Perunding Utama Sdn Bhd. This serves as the integral part of our official comments on the subject.

Here are some of the highlights of the response:

Ebara Corp describes its technology as "zero-emission". Perunding Utama merely repeats the emission "guarantees" provided by Ebara.
Air pollution systems with bag filters and pure slaked lime injection without active carbon additives and SCR reactor as the only air pollution control measure is outdated.
21st century has advanced non-incineration technologies including waste separation, reuse, recycle, advanced composting of biowaste and advanced air pollution control systems.
Construction cost of these non-incineration technologies is much lower than incineration. For example, the construction cost for a capacity of 1,200 tonnes per day MSW treatment with advanced technology from FRG is about US$140 million, compared with US$375 million for the proposed Ebara incinerator in Broga.
If the flue gas emission values for the Ebara proposal, published in the Perunding Utama's DEIA, were compared with other incinerator flue gas emission values, it appears at once that Ebara 's incineration technology is not "zero-emission-technology", but in fact produce more pollutants than other incinerator types.
The Ebara/ ABB/PU consultant statment of dioxins destruction in the DeNOx reactor is only a promotion statement without any substantiation.
The incinerators developed in Japan have significantly higher emission rates than the European ones (refer to data obtained from Bureau of Waste Management Tokyo Metropolitan Government, fiscal year 1996).
Japan with its numerous MSW incinerators has the world's highest atmospheric dioxin level. Ebara Corp. is known in Japan as environment polluter. In 2000, the company was found polluted the Hikiji River in Fujisawa with a dioxin level about 8,000 times above the environmental standard of 1 picogram per liter. PU consultant seems to possess only obsolete KL waste composition data until Hassan et al research from 1998 as mentioned in the EIA in Chapter 8.11.3. They did not take the actual data which are available in 2003.
By the lack of data collection on the part of the EIA consultant, and the resulting completely wrong predicted emission data, the EHIA (Environment, Health Impact Assessment) done by PU is of course completely irrelevant and inconsequential.

Incineration is promoted by the incinerator industry as a safe technology, leaving less amount of waste in order to be disposed at landfills. Some companies like Ebara have named their technology as "zero-emission-technology". The facts are such claim cannot even pass the fundamental natural laws. Matter cannot be eliminated or disappear. Matter only changes its appearance design/forms. In summary, for e.g. Heavy metals, the input is the same as output. Only the division into gaseous, liquid and solid output is varying in relation with different incineration technology. "Zero emission" is complete nonsense which can be easily shown if looking at the incineration by-products (secondary waste stream).

Selangor DAP has also obtained some comments made by a local geologist. Here are some of the highlights:

In section 7.3, it is stated that the site is to be developed into an integrated waste treatment and disposal complex (WTDC) which include an incinerator and a sanitary landfill. Therefore it is important that even if the DEIA of the TTP is approved, construction should not start without the approval of the DEIA of the sanitary landfill, as both projects are integral parts of the integrated WTDC.
As the peak of the hill is about 200m higher than the TTP site and and the side slope of the hill is very steep, landslide masses consisting of soil and large boulders can move down slope at high speed and will have disastrous effects on the TTP.
4.2 million cubic meter or about 8 million tonnes of excess earth material will need to be disposed somewhere. The disposal site for the earth material is not identified. The DEIA should identify one or more disposal site and the impact on the disposal site be investigated.
More than 1 million cubic meters of rock materials will need to be excavated for the construction of the TTP (Section 7.3.1). There is no mention on the impacts of drilling and blasting in the DEIA.
The TTP site is underlain by granite material (section 8.2.1). Dust from granitic rock and soil contains significant amount of crystalline silica (quartz) which is both fibrogenic (cause silicosis) and carcinogenic (Group I of International Agency of research on Cancer). The health hazards due to the exposure to silica-bearing airborne dust by the workers and nearby residents during the site preparation and construction is not addressed in the DEIA.
The wind data used in the modelling of air pollutant (Chapter 9) is from KLIA meteorological station, which is located on a flat terrain near to the coast. The TTP site in contrast is located at the foothill of the Main Range that has a hilly terrain. The wind patterns is expected to be different. There is no statistical analysis to prove that the wind patterns in KLIA are indeed similar to the TTP site. Due to the fact that the wind patterns used is not representative of the TTP site, the air pollution models in Chapter 9 is spurious.

Selangor DAP's stance is very clear as far as the incinerator project is concerned. We have presented a better alternative to the government some months ago. Our MPs have brought up the issue in Parliament on numerous occasions. We are very upset by the arrogance shown by several cabinet ministers. All of them just shot from their hips without listening to the facts presented by the residents. Even the Prime Minister himself has made a few nasty remarks on the issue without checking his facts.

Incinerators are not only too expensive and unsustainable, they are like cancer factories. The people in Broga/ Semenyih/ Beranang/ Kajang have the right to a safe living environment. If the government insists that incinerators are safe, we challenge them to move it to Putrajaya.

By: Ronnie Liu Tian Khiew