Public comment submission form
The CT Department of Energy and Environmental Protection is accepting comments on the burning of biomedical waste at the Reworld (Covanta) incinerator in Bristol until August 5. You can submit comments via the form below.
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Dear Sir or Madam: I am writing to oppose the draft permits for Reworld, Inc. to burn biomedical waste (BMW) in Bristol. BMW incineration creates risks that are unacceptable, unnecessary, and that have not been adequately considered in the regulatory process. The incineration of BMW releases toxic pollutants, including dioxins, furans, heavy metals, and PFAS. These substances cause severe illnesses including cancer, respiratory issues, cardiovascular diseases, and other critical health conditions. Dioxins, furans, and PFAS are notorious for their persistence in the environment and their ability to bioaccumulate, leading to long-term health impacts. The draft permits fail to adequately mitigate or measure these risks. They do not require more stringent emissions controls or continuous emissions monitoring for these toxins, even though such technology is proven, available, and mandated by a growing number of jurisdictions. In partial response to these concerns, Covanta committed to installing additional technology to monitor mercury levels and ensuring that this was stipulated in the draft permits during the public participation process. However, this requirement is absent from the permits. The incinerator is situated in a community that ranks above the 99th percentile in Connecticut for the release of toxic chemicals. The permits do not address the cumulative health burden experienced by local residents and fail to live up to the spirit of Connecticut’s environmental justice (EJ) law – a law which the operator claims it does not have to comply with. Furthermore, the siting of the facility near the city line means that much of the affected population was not included in the EJ or public process. Noise pollution ranks second to air pollution as the environmental exposure most harmful to health, yet the draft permits provides no relief for noise pollution emanating from the plant. Instead, they carry forward the provisions of the existing permit on noise, which are inappropriate for industrial noise and lack needed monitoring and adequate enforcement mechanisms. Under the permits, over 1,000 trucks could transport chemotherapy, pathological, and infectious wastes up to biosafety level 4 into the state annually, posing a risk of accidental releases not only of toxic chemicals but of pathogens that are easily spread, fatal, and for which there is no treatment. The draft permits do not satisfactorily address the transportation of such dangerous materials in a state that already struggles with truck crashes and spills. The draft permits would position Connecticut as one of the few states hosting a major medical waste incinerator, importing waste from across the Northeast. This is unnecessary given that safer, non-burn technologies like autoclaves are used nationwide to process medical waste. With over 99% of medical waste incinerators closing down since the 1980s, and states such as Delaware and Rhode Island now banning medical waste incineration, it is clear that incineration is neither the standard nor the best practice for handling biomedical waste. In light of these concerns, I urge DEEP to reconsider the issuance of the draft permits. Sincerely,
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