Reworld (formerly Covanta) is seeking approval to burn up to 57 tons per day (20,805 tons annually) of biomedical waste at their facility at 170 Enterprise Drive, Bristol, CT. This would make Bristol the third or fourth largest such burn site in the nation and a regional destination for medical waste.

Biomedical waste includes pathological, chemotherapy, and infectious wastes produced by medical care or research on human or animal subjects. Medical waste contains a high fraction of materials that produce toxic emissions when burnt.
These materials include:

• Plastics, especially polyvinyl chloride (PVC), from which medical supplies are made. The burning of these materials creates dioxins, which are among the most toxic chemicals known to man.
• Per- and polyfluoroalkyl substances (PFAS). Due to their properties, PFAS are commonly used in health care settings.
• Heavy metals, specifically mercury.

Releases of dioxins, PFAS, and heavy metals are concerning given their status as persistent pollutants. Because these “forever chemicals” take a long time to break down, they build up in the environment, in food and water, and in our bodies. This process of bioaccumulation increases our exposure to and risks to our health from these toxins. The health impacts of dioxin, PFAS, and mercury exposure include a range of cancers, immune deficiency and disorders, reproductive and developmental problems, and hormonal disruptions. Health impacts of mercury exposure include damage to the brain, nervous system, liver, and kidneys.

Consistent with these risks, the federal government applies strict emissions limits to medical waste incinerators. However, Reworld plans to exploit a loophole in federal regulations that will allow it to burn medical waste in Bristol without following these standards. Instead, Reworld will follow antiquated rules that allow up to 10x as many emissions of toxic pollutants — unless Connecticut applies the medical waste incineration standard and holds the incinerator to it through real testing.

Yes, but only during the test. At most, Reworld tests for dioxins and heavy metals once per year. Incinerator emissions levels can vary from day to day based on what is being burnt; research at peer incinerators found that toxic emissions can be over 1,000 higher on days when there is no testing. Because the annual test at the Bristol facility is scheduled in advance, and Reworld is allowed to adjust the incinerator operations during the test to lower emissions (i.e., game the system), the results from this test cannot be generalized to cover the other 364 days per year.

In addition, there is no testing for PFAS emissions, ever.

The annual test is not random, but is a) scheduled in advance, b) conducted by the plant or its contractor itself, and c) during the test, the plant is allowed to vary its operational parameters to reduce emissions levels.

The proposal would not tighten up testing requirements, despite allowing the incinerator to burn riskier waste. Reworld would still only have to test once per year, and would still be able to game the system. In fact, medical waste emissions might never even be measured, as Reworld would be allowed to suspend the burning of medical waste during the test.

At a minimum, the following should be required as a condition of any permit to burn biomedical waste:

• Installation and operation of continuous dioxin sampling. This equipment, which automatically tests and reports dioxin levels throughout the year, is being installed in a growing number of jurisdictions. Continuous dioxin sampling systems are commercially available and affordable from various manufacturers.
• Installation and operation of continuous mercury monitoring. During the environmental justice process, Covanta committed to install such equipment and, in fact, requested that the state condition its permit to burn biomedical waste on this. However, the firm has since reneged on this promise, and no additional mercury monitoring requirement is in the draft permits.

Yes. The proposal would allow Reworld burn waste up to biosafety level 4 (BSL 4). BSL 4 is the highest biosafety level and is reserved for the most dangerous pathogens: diseases that are easily spread, that have no vaccine or treatment, and that cause severe to fatal disease (i.e., death). There are only 13 BSL-4 laboratories in the United States; examples of pathogens that would be handled in these labs include Ebola, Lassa, and Nipah viruses.

Transportation, storage, and handling of these dangerous materials creates risks for workers, first responders, and community members, especially should there be an accidental release (e.g., through a truck crash or plant malfunction).

These risks could be reduced by treating (i.e., sterilizing) all wastes before transportation to Bristol and/or utilizing a dedicated medical waste incinerator rather than a general municipal solid waste incinerator such as the Bristol facility, which was not designed to handle infectious materials.

No. While incineration of medical waste was once common, the industry is now in transition. As safer, more ecological approaches to waste management have been developed, the number of medical waste incinerators in the country has fallen from a high of around 6,000 in the 1980s to under 30 today — a decline of 99.5%.

With medical waste incineration obsolete, Rhode Island and Delaware have been able effectively to ban the construction of any new medical waste incinerators in their states.

Yes. The proposal includes both a new state permit for the burning of biomedical waste and renewal of existing state permits for operation of the two burner units at Reworld’s Bristol incinerator. The draft renewal permits carry forward, unchanged, the language of the existing permits which holds the incinerator to the sound level limits set in state noise regulation.

The current public hearing process is an opportunity to comment on the noise pollution language in the draft permits and to improve the language in the final permits so that it is more effective.

No permit for the burning of biomedical waste should be issued until Reworld brings the facility into compliance with existing state noise regulations. There should be no reward for rule-breaking.

In addition, secondary noise pollution control requirements using the dBC scale should be included in the permits, as an additional requirement on top of the existing dBA limits. Current regulations only use the dBA scale, which underweights low-frequency noise, what industrial sources such as the the incinerator tend to produce. (In other words, current standards are biased in favor of Reworld.)

No. The current public hearing process is an opportunity to improve the language in future permits.

The noise investigation, which the Bristol-Burlington Health District (BBHD) launched in response to resident complaints, and which has resulted in the issuance of two notices of violation to Reworld, is a separate legal process to bring the company into compliance with existing state regulation.

Reworld, formerly known as Covanta, is the owner and operator of the incinerator in Bristol. Reworld is owned by a Swedish private equity firm, with the negotiations currently under way for the sovereign wealth fund of Singapore to acquire a minority stake in the company.

Absolutely not! While Bristol Residents for Clean Air started in Bristol, our group is open to residents from all over Connecticut. To get involved, e-mail us.