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EnvAgency ICI dioxin report - Letter to M Meacher

  -- part 2 ---
  I enclose a copy of  the letter I sent to Michael Meacher.
  Viv Mountford
  10 June, 1997
  Dear Mr Meacher,
  Ref: Matters relating to leaks and policing of the ICI / EVC site at Runcorn. 
  We have spent the past five years fighting against ever increasing numbers
  of leaks at the ICI site, and the extremely weak enforcement by the
  regulators, as well as three incinerator proposals for that site.  
  May I start by saying how very refreshing it is to have a Minister of
  Environment who is obviously committed to proper enforcement of the
  pollution standards.  We welcome your statement telling the Environment
  Agency that they must take a tougher line on enforcement and prosecution.  
  The frustrations of the past few years are lifting as we now see a real
  chance of reducing the chances of a disaster on the Flixborough scale.
  There have been far too many near misses in the past couple of years, but up
  till now, it has been impossible to make any progress in getting these
  stopped before a real disaster occurs.
  There are several related matters which are still of grave concern, and I
  would be grateful for your help.
  1.	The Environment Agency's Special Investigation Team should be an
  independent team.
  You are doubtless aware that the Environment Agency announced on May 2 that
  it was setting up a special investigation team to audit the management
  practises at the ICI Runcorn site.  
  We note that this announcement came about a week after a Sunday Times
  journalist requested the Agency to list all the unauthorised releases from
  this site.  We are extremely worried that this special investigation team
  may turn into just a damage limitation exercise to repair the dent in the
  Agency's public image,  especially as this team will include all the
  existing site inspectors.  
  The Agency's special investigation team should be a completely independent
  team, preferably from outside the area. They should not just review ICI's
  site management practises. They should also review the way the Agency's
  local inspectors police the ICI site, and see what improvements could be made.  
  Instead, we find that this special team includes all the current ICI site
  inspectors.  They will clearly not be capable of making an objective
  judgement of what needs to be done.  They will be likely to spend as much
  time justifying their past decisions as in auditing ICI  Also, they have
  only given themselves till the end of July to complete this investigation.
  This is clearly not long enough to do a thorough site audit.  This adds to
  our fears that this review is unlikely to achieve anything.
  Although many of the 472 pollution incidents at ICI Runcorn since 1995 have
  been fairly trivial, there have been far too many near-misses, with the same
  sort of leaks happening again and again.  There have also been far too many
  major leaks, such as the 150 tonnes of chloroform leaked on April 9 and the
  50 tonnes trichloroethylene leaked on May 4.
  ICI have been extraordinarily lucky so far. The recent leaks have not caused
  any obvious health problems, but some day the luck will run out and the
  local people might be the ones to pay the price.
  Who knows how much of these leaked chemicals have been getting into our food
  supply through fishes in the Mersey estuary anyway?  Or in the longer term
  contributing to the locally high levels of asthma and cancer and rare
  diseases like motor neurone disease?  We just don't know.
  2.  	The Environment Agency's Dioxin Report on the ICI/EVC Runcorn site.
  In  January, the Environment Agency published an information report about
  dioxin emissions at ICI's Runcorn site.  The document had many flaws, so we
  sent a detailed 30-page critique of it to all levels of the Agency in early
  March, with copies to key local councillors, local and national MPs.  
  Throughout the ensuing correspondence with the Agency's Regional Manager,
  Ian Handyside, he has continually avoided giving any response at all to our
  criticisms of the contents of this document.  He has answered the peripheral
  questions but consistently avoided answering the main criticisms.  Instead,
  the Agency offers us a meeting to discuss it.  However, this is too
  important a matter to just discuss behind closed doors. 
  You may recall, I sent copies of my critique to you and to Joan Ruddock.
  Apart from one local MP, Mike Hall, Ms Ruddock was the only recipient who
  pursued this for us.  She passed it to John Gummer and received a response
  via James Clappison at the DoE, which simply comprised all the
  correspondence so far between me and the EA regional manager Ian Handyside.
  I was very impressed that Ms Ruddock found time to relay this reply to me,
  just a few days before the election.
  Ms Ruddock was sent a copy of the report by the Agency, and she may still
  have all the associated correspondence.  
  I sent another letter (enclosed) to Mr Handyside on June 1, in a final
  attempt to get him to admit that their report is dangerously flawed.  It
  does not give the correct figures for dioxin emissions currently, nor for
  future dioxin emissions estimates after each incinerator is built.  This
  means that the report's conclusions are based on completely false foundations.  
  He has not yet replied to this latest letter.  When he does, he will
  doubtless simply reiterate their offer of a meeting.  I and others have
  received a public relations-style fob-off on this issue at all managerial
  levels of the Agency:-  from Ian Handyside (NW Region Manager), from George
  Ager (local area manager) and from Keith Murray, the manager of the ICI site
  inspectors who authored the report. 
  Halton Council's planning decision to permit two more incinerators at the
  ICI site, must have been at least partly influenced by this flawed document,
  so this is a very serious matter, and the Agency know this.  I have to
  conclude that Mr Handyside just dare not admit to the errors.
  As I seem to be hitting a brick wall, I would be extremely grateful if you
  would pursue this with Mr Handyside.  The document is well laid-out and
  superficially pleasing, but it is clearly wrong.  At least 100-200 copies
  have been distributed around the region.  They must privately accept that
  this document is flawed, but even now, they wave copies of it on every
  conceivable public occasion, to demonstrate that they've actually done a
  plausible piece of research out here in the regions.  
  3. 	MAFF's nationwide sampling of Dioxin levels in Human Breast-Milk
  MAFF have recently completed a nationwide study of dioxin levels on human
  breastmilk.  We have been lobbying for just such a study to be made on the
  local Runcorn population, to test whether the dioxins emitted from ICI's
  production plants have affected the local population.  
  We suspect that the MAFF study, if conducted in a sensible manner, would
  provide us with this information.  It depends on the extent to which samples
  were pooled before testing.  If milk samples were pooled at a local level,
  then local differences would be obvious.  However, if samples were pooled
  over a whole region or even nationally, this would average out any local
  We would be grateful if you would ask MAFF to supply the test results for
  any human milk sampling which was done in this area, or indeed in the North
  West region. We would like to know whether samples for each area were tested
  separately or pooled together on a regional or national basis. 
  We would like all the detailed test results for the North West Region,
  giving the geographical area to which each sample relates, and the congener
  profiles and the TEQ value for each dioxin congener.
  4. 	MAFF's dioxin sampling in cow's milk
  In January 1997, MAFF finally published the results of their "Survey of
  Cow's Milk from Farms in the Vicinity of Potential Sources of Dioxins".  I
  have a copy of the detailed report giving the concentrations and congener
  profiles for each area.  
  However, the results for the ICI site and for the Alvanley PCB tip, are
  given as a combined result,  with the comment "These groups of industrial
  sites are located very close to each other".  Table 21 which gives these
  results is headed "Concentrations of dioxins ... in milk from farms within
  4.5 km of ICI Chemicals & Polymers and/or of the Alvanley Tip near Runcorn".  
  There does not seem to be any logical reason for lumping these two very
  different sites together in this way.  They are over six km apart. The
  pollution is of a completely different type, and the generally easterly wind
  direction means that pollution from each of these two sources will be
  unlikely to combine together.  The wording implies that the farms sampled
  could be anywhere in quite a large area of North Cheshire.  These farms
  could be up to 10 km from ICI, if they were on the furthest side of Alvanley
  Tip from the ICI site.
  We would be grateful if you would ask MAFF to supply the grid reference for
  each sample involved in the sampling for table 21, and a breakdown of the
  congener prolfiles and dioxin values for each sample if the samples were not
  pooled before testing.
  Yours Sincerely,
  V A Mountford
  Industry and Pollution Activist, Halton Friends of the Earth.