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EnvAgency ICI dioxin report - Letter to EA

  -- part 3 ---
  I enclose a copy of  the most recent letter I sent to the Agency,
  summarising our previous correspondence on this topic.  I enclosed this
  letter with my letter to Meacher.
  Viv Mountford
  ###### Letter to Ian Handyside, NW Regional Manager, Env Agency  #############
  1 June, 1997
  Dear Mr Handyside,
  Ref: Critique of the ICI/EVC Runcorn Dioxin Report of January 1997. 
  Thank you for your letter of 14th April.  I apologise for being unable to
  reply earlier.  In view of the time which has elapsed since we began our
  correspondence about the above report, it seems worth reviewing the salient
  points and milestones:-
  On March 15 1996, in the aftermath of all the questions arising both from
  the Dispatches TV  programme on dioxins, and from ICI’s misleading and
  contradictory statements made after that  programme, you announced that the
  Environment Agency was setting up a team to investigate  dioxins from the
  ICI Runcorn site. The team would produce a public information report. 
  On January 21st this year, your team, headed by Alex Radway, published this
  report.  It was fatally  flawed, especially in the section which gave
  comparisons of the total dioxin arisings currently and  after each proposed
  incinerator.  The tables of dioxin emissions to land and to water were
  incomplete, and were used to draw completely erroneous conclusions.  Take
  the example of table  10, dioxin releases to water, reproduced here. 
  [[Retyped version of Table 10 from UK Environment Agency report on dioxins
  from ICI/EVC Runcorn]]
                      Table 10 : Site releases of dioxin to water (grams TEQ /
  PROGRESS DATE                                    |
  SOURCE                      |  Now           | Post ICl's EIP          |
  Post EVC's            | Post ICl's       |
                                        |                    |
  | Incinerator         |Fluorochemicals|
                                          |                    |
  |                               | Incinerator     |
                                          |                    |
  |                               |                          |
  Vinyl chloride (1)          | )                  |          0.1
  |          0.1                |          0.1      |
                                          | )   0.2           |
  |                               |                       |
  Per-Tri (1)                      | )                   |          *
  |          *                   |          *            |
                                          |                     |
  |                              |                         |
  CTF                                 |     *               |          *
  |          *                   |          *           |
                                          |                     |
  |                              |                        |
  Chlorine                         |     *               |          *
  |          *                   |          *           |
                                          |                     |
  |                              |                       |
  EIP (ICI)                          |     -              |         TBD
  |          TBD             |          TBD      |
                                          |                     |
  |                              |                        |
  VC3 Incinerator (EVC) |     -              |          -
  |          TBD             |          TBD        |
                                          |                     |
  |                              |                        |
  Fluorochemicals incinerator|     -     |          -                     |
  -                   |          TBD      |
  (ICI)                                 |                     |
  |                              |                       |
                                          |                     |
  |                              |                       |
  TOTAL                            |     0.2           |          0.1
  |          0.1                |          0.1       |
  TBD = To Be Determined (once the plant is operational)
  Note * : Very small amounts of dioxin may be present, but at levels that are
  too low to allow            
  Note 1 : VC and Per-Tri both currently discharge into Weston Marsh Lagoons.
  --------------------------[[end of retyped table
  As you can clearly see, no estimates were given for dioxin arisings from six
  of the seven potential  sources your team identified. This means that the
  total line shown is false - it is not the true current  total, nor is it a
  true estimate of the total dioxin levels after each incinerator. It is
  simply a repetition  of the emissions estimate from the vinyl chloride
  production plant alone.
  Dioxins from three of the four production plants are said to be at levels
  too low to allow  measurement, yet your inspectors have apparently never
  asked ICI to measure them. Dioxins from  the three proposed incinerators are
  shown as ôto be determinedö, yet it is unusual for the Agency to  request
  dioxin monitoring in aqueous effluent, so the amount seems unlikely to ever
  be determined. 
  There are similar errors in the tables showing emissions to air and in solid
  wastes.  However, the  erroneous total lines from each of these tables are
  passed forward into table 22, reproduced below  from the conclusions section.
  [[Retyped version of Table 22 from UK Environment Agency report on dioxins
  from ICI/EVC Runcorn]]
                      Table 22 : Estimated site releases of dloxln and total
  UK releases
                                  |  UK total        |
  Site Release                                |
                                  |  Release in    |     Now     |  Post ICI's
  |  Post EVC's      | Post ICl's     |
                                  |   1996            |                 |  EIP
  | Incinerator    |Fluorochemicals|
                                  |                        |                 |
  |                          | Incinerator        |
  To Atmosphere     | 560-1100      |    0.002    |     0.222     |     0.242
  |         0.244        |
  grams TEQ/year)  |                        |                 |
  |                          |                           |
  To Water                |  Unknown      |     0.02    |      0.1        |
  0.1               |         0.1           |
  (grams TEQ/year) |                        |                 |
  |                          |                          |
  Solid Wastes         |  1,500-12,000 |   512.00  |  517.00    |     6.5
  |          6.5          |
  (grams TEQ/year) |                         |                 |
  |                         |                          |
  --------------------------[[end of retyped table
  The conclusions section states that table 22 
           'shows how dioxin releases will change with the installation of the
  three incinerators which are being built to effect other environmental
  However, it clearly does not!  Table 22 omits any estimates of dioxins to
  solid wastes from either of  the two more recent incinerators and omits any
  estimates to water from any of the three  incinerators.  We also believe
  that the dioxin emissions to air are grossly underestimated, and I have
  given the reasons for this belief in my critique.
  The above was just one of the many elements of this report which were
  misleading or wrong, so I  wrote a comprehensive 12-page critique of this
  report (more than 30 pages including appendices).  I  sent you a copy on 4th
  March, as well as copying it to Halton and Vale Royal councils and strategic
  MPs, councillors and Environment Agency managers.
  Before I issued my critique, it was sent to Alan Watson, who until recently
  headed the Industry &  Pollution section at Friends of the Earth UK.  He is
  now a public interest environmental consultant.   My critique was also read
  by Dr Vyvyan Howard, senior lecturer at the Infant & Fetal Toxico- pathology
  Laboratory, Liverpool University.  They both agreed that my document was
  fair, well  thought out and clearly presented.  
  In all our correspondence since, you have not given any reply at all to any
  of my comments on the  content of the report.  You said that you found my
  critique contradictory and misleading,  but you  appear to be unable to
  state your grounds for making that statement.  Also, it seems to be a view
  not shared by your staff, a couple of whom recently remarked to Friends of
  the Earth members that  'Viv Mountford really knows her stuff'
  To continue my review of our correspondence:-
  On March 11, you sent me an acknowledgement of my critique.  In this, you said:-
       'We will study your comments carefully and a full response will be
  On March 25, you sent me your main response. In this four page letter, you
  concentrated on  responding to my peripheral criticisms on the timing of the
  dioxin report; the weakness of  Environment Agency enforcement at the ICI
  site, and the authorisation process for the HFC  incinerator.  You gave no
  reply to any of my criticisms of the actual content of the Dioxin report.
  All  you said about this was:- 
   'I am disappointed that you appear to have such a negative attitude towards
  the Dioxin Information Report. I have to say that the Report has generally
  been well received in other quarters .   'I appreciate the obvious effort
  you have put into reading our Report, but I do find your  critique
  misleading and it contains a number of contradictory arguments. However, the
  Project Team will check through the critique and make any necessary
  amendments to the Information Report. The public have been very confused by
  the technical arguments about dioxins and so the Report was specifically
  presented in a manner that would make it amenable to a non-expert audience.
  A number of simplifications have been made to aid the Report's clarity, but
  the sources of information can still be referenced. This was necessary to
  convey the issue in a concise and easy to understand manner. I do not accept
  your allegation that we have published a "biased inaccurate document".  Much
  effort has gone into researching the dioxin issue and establishing the
  veracity of our information sources. We are satisfied that the Report is a
  fair reflection of the best scientific understanding available to us.'
  You also copied your letter to Halton and Vale Royal councils, as I had sent
  them my critique.  Thus you effectively discredited my statements in their
  eyes, without substantiating your remarks.
  On 7th April, I replied. I said: 
       'Before I issued my critique, it was reviewed by independent scientists
  who are very knowledgeable in the related areas of dioxin and incineration.
  They endorsed my document   as being an accurate assessment of your
  Information Report. They are as surprised as I am  that you found my
  critique misleading and containing "a number of contradictory arguments".
  You must surely agree that it would be fairer if you would substantiate your
  remarks by giving   me (and the other recipients of your letter) details as
  to what you found misleading and   contradictory in my document. It would be
  in the public interest and in the spirit of LA21 to do  this and also to
  reply to each of my detailed criticisms of the content of your AgencyÆs
  Information Report.'
  On April 14, you replied. You still made no attempt to answer any of the
  criticisms I made about the  dioxin report, or to justify your criticisms.
  All you said on that topic was:      'Your critique has been studied by the
  Dioxin Information Report Team who concluded that  our Report is accurate
  and does not require amendment and therefore we will not be re- issuing the
  and you concluded by saying:  'I believe that you also raised the issues of
  dioxins at the launch of our Mersey Leap on 9  April, Dr Keith Murray
  indicated our willingness to meet with you for discussions. I would also
  like to reiterate the same offer I made in my letter of 22 February 1996
  which you did not  take up.' 
  When Keith Murray waylaid me while I was trying to visit the public
  registers on April 17, he pursued  his theme that a meeting would be more
  appropriate than giving a written reply to the other points  raised in my
  critique.  He appeared to be saying that some of my questions were unclear
  and hence  needed discussing.
  Please would you ask Dr Murray to write and tell me which of my questions he
  and his dioxin  information team find unclear, and I will do my best to
  explain them. 
  Would you also please explain how, if they don't fully understand my
  questions, your dioxin team  have managed to conclude that their report 'is
  accurate and does not require amendment'. 
  While a meeting would of course be helpful, I do not feel that this would be
  very useful while your  team have failed to give even a sketchy response to
  my well-substantiated criticisms of their report.
  You allude to your previous offer of a meeting, a year ago. You made that
  offer while sending a  written response to my questions arising from ICI's
  statements made after the 'Dispatches' TV  programme 'Dioxin, the Perfect
  Poison'.  As the Agency's written response gave fairly frank  answers to all
  my questions at that time, I saw no purpose in a meeting then.  
  In conclusion,  I have made clear written criticisms of the content of your
  dioxin report, and you have  made absolutely no attempt to address my
  concerns about the content of the report.  The issues  which you are
  currently avoiding answering in writing are too important to discuss behind
  closed  doors.  I am asking you again to justify your (probably libellous)
  written remarks, in a written reply.
  If I do not receive such a reply, I am forced to the conclusion that you are
  simply incapable of  admitting that your dioxin team were so eager to
  reassure the public, that they wrote a  fundamentally flawed document.
  Instead, you seem to be doing everything in your power to cover- up this error.
  The Agency announced on May 2nd that it was setting up a multi-disciplinary
  investigation team to  carry out an urgent review of environmental
  management systems at ICI Runcorn.  We welcomed  this as a great step
  forward.  However, I now gather that this team includes the same group of
  inspectors who currently regulate the site, members of whom wrote this
  flawed dioxin report. 
  It should be obvious that such an important review should be performed by
  people not previously  involved in regulating that site.  A genuine review
  cannot be achieved by the same personnel who  previously allowed ICI to get
  away with 472 unauthorised releases since 1995, with hardly more  than
  slapped wrists.  
  Yours Sincerely,
  V A Mountford