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EnvAgency ICI dioxin report - Letter to EA
-- part 3 ---
FYI
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 /
year
|
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
measurement.
Note 1 : VC and Per-Tri both currently discharge into Weston Marsh Lagoons.
--------------------------[[end of retyped table
10]]----------------------------------------
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
22]]----------------------------------------
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
improvements.'
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
provided.'
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
Report.'
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
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