First Minister of Wales - 5 May * From: XXXXXXXXXX Sent: 05 May 2017 16:30 To: Carwyn Jones (Ministerial) Subject: Barry Incinerator Concerns Dear Mr Jones, I am writing to you as Chairman of DIAG (Docks Incinerator Action Group). DIAG represents thousands of concerned Barry Town residents. We have 5,500 members of our Facebook group, over 100,000 views of our video materials, and regularly have hundreds of people attending our public events and demonstrations. We represent the public in what is now the biggest single issue facing Barry Town. I am writing to request your support in our cause. I am sure you are aware of the incinerator being built on Woodham Road, on the edge of Barry Town. (License for Biomass UK No2 Ltd. Incinerator, Barry Dock ref. PSN-000869). Biomass have the planning permission to build the incinerator, but they need a licence from Natural Resources Wales (NRW) before they can operate it. Indeed, NRW say that Biomass are building the incinerator “at their own risk.” DIAG are lobbying for NRW not to grant Biomass the licence, and would gratefully welcome your support in this. We are worried about the considerable risks to public health from the incinerator. Biomass want to burn 200 tons of waste wood per day; including MDF, glues, paints, plastics, varnish and melamine coatings. Biomass claim that emissions from the plant “Will not harm the health of residents,” but they have failed to evidence this. They have failed to state what standards will be used to safeguard more vulnerable groups; including thousands of children, babies, and those with asthma and COPD. The incinerator will release nitrogen dioxide and a cocktail of particulate matter, chemicals, metals, dioxins and furans – some of the most toxic chemicals known to science. The major source of dioxins & furans in the environment come from burning waste. Experts have warned these are a major cause of cancers, birth defects, breathing difficulties and heart disease. These poisons will fall over a wide area around Barry and beyond, wherever the winds carry it. Our scientists and technical experts at DIAG have identified many shortcomings in Biomass’s application data. Some of these key shortcomings (about noise and atmospheric pollution) have also been agreed upon by the leading experts at Capita, in a recent independent report commissioned by the Barry Town Council. Our fear is that the Biomass incinerator will be granted a licence to operate, based solely upon their own inadequate application documents. There are thousands of homes, a dozen schools, a major shopping centre and a children’s hospice within a 2km radius around the incinerator. All of which will receive the full impact of the pollution plume under certain weather conditions. Surely it is foolish and dangerous to rely exclusively on Biomass to claim it is safe; when they are the party who stand to profit from the incinerator! Every other incinerator of a comparable size has to be 1 vetted and granted an Environmental Impact Assessment (EIA) before it is allowed to operate. How can it be right that the Barry incinerator, in close proximity to so many thousands of people, is the sole exception to this rule? As well as the threat to public health from emissions during normal operation, DIAG note that the very real risk of an accidental fire in the incinerator’s woodchip stockpile (approximately 750 tons) has been largely overlooked. Biomass’s fire mitigation plan is badly incomplete; they have only considered the fire risk upon their own premises, but not the effect an accidental fire would have upon the town at large. Biomass have not disclosed how toxic the smoke from an accidental fire at their plant would be to local people. Instead, Biomass have pointedly ignored sensitive receptors including schools, nurseries, a shopping centre, a leisure centre and an open air market place within the 1 km “Fire Risk Circle.” This is a major oversight, and contrary to official NRW 2016 guidance. Accidental woodchip fires are certainly not uncommon (three of these fires in Bridgend, Maesteg and Newport Docks have recently burned out of control for weeks, sickening local residents with nauseous fumes). Such a fire and its unfiltered chemical smoke would pose serious risks to the health of thousands of Barry residents within the 1 km “Fire Risk Circle.” The independent Capita report found flaws in the Biomass application but (due to time restrictions and lack of independent data), it was unable to cover every area of risk; such as accidental fire risk, and the health risks to the most vulnerable, such as children and asthma sufferers. So new and independent data needs to be collected and analysed by a qualified party other than Biomass, before a licence can be considered. There are thousands of children who could be at risk, should an accidental fire occur at the incinerator. Approximately 600 of these children attend Holton Primary and St Helen's Infant school; these are at highest risk, because these schools lie within the designated 1km “Fire Risk Circle.” Additionally, the incinerator’s application licence fails to consider the specific risks to very small children and babies, such as those who are still breast feeding from their mothers. Barry’s town centre, shopping centre, leisure centre, medical centre, retail park, a superstore, an open air market, two nursery schools and a train station are also located within the incinerator’s 1km “Fire Risk Circle.” It is hard to believe, but Biomass fully expect their licence to be rubber-stamped without a proper fire risk mitigation plan in place for the thousands of people who live in and move through these densely populated areas. In their haste to light their incinerator…Biomass have simply ignored them. Another area that has been overlooked by Biomass is the aftermath of a firefighting operation, resulting from an accidental fire. The environmental impact of the draining away of contaminated water and foam needs to be accounted for under CIRIA 736 (Containment systems for the prevention of pollution). Again, Biomass have failed to do so adequately in their application. 2 It is a scientifically established fact that children suffer far more from pollution than adults, because their lungs are not fully formed. In fact, the lungs of children can be stunted by exposure to pollution. There is a higher than UK average incidence of asthma in local Barry surgeries. We see the following: Ravenscourt Surgery: 8% Waterfront Medical Centre: 6.12% West Quay Medical Practice: 8.92% Practice of Health: 6.79% Court Road Surgery: 7.2% St Bride’s Surgery: 7.36% Highlight Park Medical: Practice 6.53% Sully Surgery: 7.25% These are all already higher than the UK average of 6 percent. Source: www.asthma.org.uk/get-involved/campaigns/data-portal/. I am unsure if these statistics include the very young children who suffer from asthma but are not diagnosed until they reach 5 years old. These very young children may not register among these official figures. The stress on local Health care providers can only increase, with increased pollution and its effects upon vulnerable children. Barry is already a heavily polluted town, with Aberthaw Power Station, Cardiff Airport, Dow Corning and heavy traffic all emitting pollution into our atmosphere. I repeat, the incinerator permit application data is inadequate and flawed. Another example is that the wind data in the application is taken from Rhoose airport’s weather station (5 miles away); instead of being based upon more relevant local data. The effect that the dock basin has upon local wind patterns in the area is considerable. DIAG have utilized projections from the respected ‘Plume Plotter’ website; and we have evidence that the levels of pollution are considerably higher and more prone to hitting the town, than the inadequate projections in the Biomass application for licence. The Biomass application document shows their projection of a pollution plume hitting the Buttrill’s area of Barry including homes and schools. (See Section 5, page 14 ‘Assessment of Impact - Human Health Impacts’) The pollution they illustrate here is at a level high enough to trigger an investigation by the NRW. But this is only the 18th worst case scenario they have projected. However, projections 1 – 17 remain concealed in the Biomass archives. DIAG believe Biomass should be made to publish all their data, and not ‘cherry pick’ less polluting scenarios. The expert consultants at Capita also flagged contradictions in the way that Biomass were presenting their atmospheric pollution figures in the application documents. Once again, fresh data needs to be gathered and analysed from a trusted independent source. We believe that harmful emissions could ground anywhere in 3 Barry. However, the many hillside homes and schools are at highest risk because the incinerator’s chimney is not high enough to clear them. (See again the Biomass application illustrating this, Section 5, page 14, ‘Assessment of Impact - Human Health Impacts’). Furthermore, we believe that data for existing pollution in Barry should be independently collected before the incinerator’s licence is considered. Perhaps air pollution monitors could be placed outside school premises, to give a baseline figure for existing pollution; and could later be used to assess the difference in pollution should the incinerator be given a licence to operate. Finally, there are also questions of Dow Corning pipelines being in the vicinity of the incinerator and the chemical tankers that come into docks. I remember the spill from a tanker into Barry Docks – the chemicals floated on the top of the water and caused considerable damage. Any fire mitigation plan must account for a worst case scenario.