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Objection to Environmental Permit Application EPR/EP3731XL/A001

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Objection to Environmental Permit Application EPR/EP3731XL/A001 Halton Action Group Against The Incinerator (HAGATI) Objection to Environmental Permit Application EPR/EP3731XL/A001 PART TWO Response to the Environmental Permit Application Halton Action Group Against The Incinerator (HAGATI) Executive Committee Chairman Sir Kenneth Green Kt; BA; MA; DLitt; CIMgt Vice Chairman Mr Jeff Meehan HNC Elect Eng; End Electronics/Computing Secretary Mrs Sue Bowden (Local Government Officer) Treasurer Mr Alan Gorry (Company Director (Retired)) Committee Members Dr John Beacham CBE; DSc; FRSC Dr Simon La Frenais MB; ChB; DObstRcog Mrs Debbie Middleton JP Mr Mike Stackpool MSc; Cphys; MIinstP Advisers Professor John S. Dearden BSc; MSc; PhD; ACGI; MRPhrmS Mrs Susan Smith BSc. Hons. MInstP. CPhys . 2 Index PART TWO – Environmental Permit Application Page Section 1 Objection Overview 4 Section 2 Environmental Justice 11 Section 3 Chimney Height 16 Section 4 Size of Development 26 Section 5 Existing Industrial Pollution 29 Section 6 Filters and Abatement 32 Section 7 Fuel Variations 34 Section 8 Transportation 36 Section 9 Carbon Emissions 38 Section 10 Accident Risks 39 Section 11 Air Quality 40 Section 12 Emissions 42 Section 13 Existing Air Quality 46 Section 14 The Health Impact Assessment 47 Section 15 Best Available Technique (BAT) 48 Section 16 The Stockholm Convention 52 Section 17 Randle Island 63 3 SECTION 1 Objection Overview a) This is HAGATI’s formal objection to Permit Application EPR/EP3731XL/A001, recommending that a permit be refused, for the reasons detailed within. The objection, outlining our concerns, follows the same format as that of the Permit Application itself as far as possible, rather than any order of importance, with additional sections relating to Environmental Justice, Randle Island and other relevant issues. Each section contains and analysis of the issues, a listing of errors and omissions, a summary of outstanding issues and, where appropriate, recommendations for action. b) The Permit Application to relates to a proposal to build by far the largest incinerator in the UK at Weston Point Runcorn, which is the worst possible location in the UK for such a development. c) This is a densely populated area with some 16,000 people living with 2km of the site, some house less than 50m from the site boundary, three pre-schools, three primary schools and a Further Education college. Thereafter, the higher ground of Runcorn is densely populated as far as the nearby towns of Widnes and Frodsham. d) It is one of the most polluted areas in the UK with large areas of contaminated land due to its industrial and chemical manufacturing legacy, especially heavy air pollution levels due to traffic using the flowing to and from the Jubilee Bridge and their emissions and increasing fall out from air traffic using Liverpool John Lennon Airport. e) Twenty years ago, the Luvella incinerator was built very close to the proposed location of the Ineos incinerator. After three years of successful campaigning mounted by residents, the incinerator was demolished on the grounds of safety and the effects on their everyday lives. The village of Weston, overlooking the site, provides vivid evidence of the impact of pollution on land, buildings and the health of residents, caused by the dumping of toxic wastes from the site below. As a result, houses were sealed or demolished, polluted areas landscaped as unfit for development, and people relocated outside the village. f) The prevailing winds are south and west, thereby exposing all these residential areas to downwind fallout for the great majority of the year whilst in the calm periods, which equates to over a month in any year, there will be minimum dilution and a greater concentration will fall on houses and schools closest to the site. g) The terrain is hilly, and the proposed incinerator would be sited 600m from an 80m hill, with residential properties located on its slopes. This escarpment is a major factor, leading to particular concern about the chimney stacks’ location and size. h) As detailed in the HAGATI Response to the Health Impact Assessment, the Borough has a dreadful health record. i) In our view, the likely cumulative effect of these factors must be regarded as a major concern. The proposal to build the largest EfW incinerator in the UK in such a location is highly irresponsible. 4 Environmental Justice The Environment Agency recognises that there are areas that are already receiving an unfair portion of negative environmental pressures. It admits, and we accept, that the only way in which these areas could receive relief is either by stopping already licensed processes or the payment of compensation, neither of which courses of action will be taken. Importantly however in areas identified as bearing this imbalance, the Environment Agency position statement on Environmental Justice states that no further additional negative effects will be permitted. We believe that Halton, as an Environmental Justice Audit will prove, is perhaps the worst possible place where an incinerator should be permitted. Chimney Height and Dispersion Compounding the problem of the wrong siting, in view of the statistical evidence on health and environment in Halton, is the geography of the local terrain, with a steeply rising 80m hill in close proximity to the incinerator chimney. We believe that the information provided by modelling in the Ineos EIA is incorrect. The data (in graphical form) contradicts the claim by Ineos that increasing the chimney height does not give an improvement in ground level dispersion. Our main concern is that the topography was not considered fully or correctly. A proposed 106m stack adjacent to an 80m hill with population in the fallout area is an obvious issue. We believe the resultant pollution will add to existing pollution and pose further health hazards to a population already suffering poor health outcomes. This, combined with the belief that operational failures will occur (start-up/shutdown, filter failures, etc), is even more a cause for concern. Past experience of chemical plants in the area supports the view that this is not an unlikely outcome. The Health Hazards We are concerned that the pollution arising from the incinerator will be inadequately diluted. The wind analysis shows that almost all the population of Runcorn (120,000 people) is liable to receive fallout. Whilst this may be relatively small in terms of actual amounts, it is an additional burden on an already pollution-stressed area (industrial, road and air traffic). Our particular concerns are fine and ultra fine particles for which incineration is a prolific source. Although the plant has filters, their efficiency in removing ultra fine particles is not complete and certainly not efficient below PM 10 . Furthermore, failures and sub-optimal operations will take place resulting in increases in emissions. Fine and ultra fine particles (PM 2.5 or less) are associated with a variety of ill-health effects, even thought they are not yet fully investigated or understood. It is not only the particles themselves but also the associated pollutants bound to them. There is a growing body of concern, which should lead to the adoption of the precautionary principle. The Noise Nuisance Increased noise will arise from three sources – (1) construction; (2) operation and (3) the transport of RDF in and of bottom filter ash out. The noise from construction will have a finite time limit, but the plant operation will not. Transport represents the major noise nuisance. There are a significant number of houses adjacent to the proposed railway line into the site and to the adjacent roads to be used by 5 vehicles. This noise and the vibrational effects from the trains cannot be mitigated and will occur at night as well as day. The operator Ineos has been disingenuous about this nuisance . In addition, there are a number of other reasons why this proposal has been opposed by HAGATI (being the local residents’ action group). The process is not the Best Available Technology (BAT), the siting is close to a large population downwind and the Application contravenes local, national and international conventions, regulations and policies. Both the Health Impact Assessment (HIA) and the application for an Environmental Permit are flawed and in the case of the HIA, not fit for purpose. The documentation supplied with the Application is factually incorrect, has many important omissions and either by design or accident is misleading in its presentation of information. The Halton Action Group Against The Incinerator (HAGATI) is not anti-incineration. When incineration is a controlled combustion process it has many uses in the chemical and other industries as a method of rendering harmless compounds that have a potential for negative health and environmental impacts. This is achieved by ensuring a continuous uniform feed and maintenance of optimum operating conditions such that the elements released during combustion are controlled and filtration and abatement equipment prevents the release of toxic substances. The proposed incinerator site lies within one of the largest chemical industry complexes in Europe and already houses two such incinerators, the EIP (Environmental Improvement Plant), removing primarily chlorinated hydrocarbons and the Lurgi Incinerator burning liquid chlorinated hydrocarbons such as hexachlorobutadiene. These toxic chemical incinerators already in use on the Ineos site have been constructed and operated without local opposition. Neither are we opposed to power stations, as less than 10Km away is the massive Fiddlers Ferry site with a capacity of nearly 2,000 MW. The Rocksavage Power station supplies the nearby Ineos Fluor site and even closer, the Scottish Power 75 MW plant is adjacent to the proposed facility and has also run without cause for complaint for a number of years. It is however impossible to understand how dispersion and dilution from the twin 42m stacks of the Scottish Power station will not be adversely affected by the construction, less than 100m away, of an enormous building that is of exactly the same height as those stacks.
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