20 questions to UK EnvAgency re ICI Runcorn (pt 1)

[vivmount@greener.u-net.com (Vivien Mountford)]

  I enclose, in 2 parts, some questions about the regulation of the ICI
  Runcorn site, that Mike Matthews has sent to the UK Environment Agency on
  our behalf.  
  
  Mike Matthews was, until 4 years ago, the National Rivers Authority
  inspector for this ICI site. He is now the Principal of a local firm of
  environmental consultants,  which we have retained to assist us in making
  formal representations to the Environment Agency about their regulation of
  the ICI site. The aim was to ensure that the special audit of the site which
  the Agency have been doing recently, rigorously covers all the deficiencies
  in the running of that site.
  
  As an individual, resident in Halton FoE's catchment area, Mike also
  recently joined Halton Friends of the Earth, and he has agreed to become our
  representative at the ICI Community Forum meetings held quarterly in Runcorn.
  
  I enclose Mike's covering letter to the Agency and their initial reply.  I
  will send the "20 Questions" as a separate message, together with selected
  pages from the Appendices.
  
  I have not scanned in all of the appendices, as these comprise some 30-40
  pages, including copies of several Environmental Incident Report Forms from
  the public registers, to illustrate points made in the list of questions. 
  
  Viv Mountford
  Industry & Pollution Activist, Halton FoE
  
  ######################################################################
  PEAK ASSOCIATES
  Environmental Consultants
  
  our ref PKNW 96/30 & 97/02
  
  Mr Ian Handyside, Regional General Manager 
  Environment Agency 
  Richard Fairclough House 
  Knutsford Rd, Warrington WA4 1HG
  
  18th August 1997
  
  Dear Mr Handyside,
  
  As I am sure you are aware we are retained by two local residents(with legal
  aid) and the local Friends of the Earth branch to advise and represent their
  interests in relation to certain IPC applications at ICI's Merseyside
  Operations at Runcorn. Our clients overriding concern is that they do not
  feel that they or the environment they live in, is being adequately
  protected by your policing of ICI's site at Runcorn, This is a matter which
  they fully intend to remedy.
  
  Our clients are committed to improving their local environment and we
  therefore see your ongoing large scale audit of the site as a valuable
  opportunity to promote our client's interests and achieve change by
  consensus rather than conflict in the courts or national media.
  
  I have therefore been authorised to raise our main areas of concern and to
  attend the meeting with yourselves and our clients that has been suggested
  by yourself and is refered to in Mr Basin's [note from Viv - should be
  Bastin] (of the Dept of Environment Transport and the Regions) letter to Ms
  Mountford dated 7th August 1997.  Our clients aim at the meeting will be to
  expand and justify our clients case and promote the adoption of what we
  believe are standard and routine pollution prevention practices at Runcorn.
  
  The matters raised in the attached paper are necessarily critical of what
  has been allowed to happen at Runcorn and whilst I do not expect you or your
  officers to concur with all the criticisms levelled, I would be disappointed
  if you did not consider some of criticisms are valid. In particular I would
  draw your attention to Appendix I and our concerns over the reasons behind
  so many of the unauthorised releases.  Release no 74 is a particular
  favourite of mine and I have attached a copy for your interest!
  
  At the very least I hope that you will consider the concerns raised by local
  people who we believe are 'stakeholders' in the safe running of this plant
  and whose views should therefore be considered as part of the audit process.
  
  I will contact you next week to see when/if you are prepared to meet us.  I
  would welcome a four hour meeting, that would allow us some time to discuss
  each of the issues raised.
  
  		Yours sincerely,
  
  		M Matthews (Principal Consultant)
  
  cc Alex Radway
  
  ##########################################################################
  ENVIRONMENT AGENCY
  
  Our ref		GA/SJB 
  Your ref	PKNW 96/30 & 97/02
  
  Date		28 August 1997
  
  Mr M Matthews Principal Consultant 
  Peak Associates 38 Padgate Lane 
  Padgate Warrington Cheshire   WA1 3RU
  
  Dear Mike
  
  ICI OPERATIONS AT RUNCORN
  
  Thank you for your letter of 18 August, addressed to lan Handyside. As he is
  away on leave at present I have been asked to reply on his behalf.
  
  Firstly let me state that I am pleased that the offer we have made on many
  occasions to meet Ms Mountford has been accepted. This is the best way of
  making progress. As Ian's diary is very congested over the coming weeks, I
  cannot commit him to a specific time and date, but we will contact you on
  his return to finalise arrangements.
  
  I have to say that I was not aware that. you were retained by the two local
  residents and Friends of the Earth to represent their interests.  I assume
  that some contractual relationship exists between you and your clients. We
  would like you to confirm this at the meeting, and whether Peak Associates
  has any other interests it represents, contractually or otherwise.
  
  I note that the two local residents have legal aid. Please let me know the
  names of the solicitors acting in this matter and whether they would wish to
  attend the meeting.
  
  Yours sincerely
  
  G AGER
  Area Manager - South