EnvAgency ICI dioxin report - Bastin's reply

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

  As you may know, in January 97, the UK Environment Agency published a report
  on dioxin emissions from the ICI/EVC site in Runcorn.  This report had many
  flaws, and I sent them a comprehensive critique.  They have never given any
  written reply to any of the points I made about that document, but keep
  offering to meet me about it.  I think they now believe that the meeting we
  will be having with them about their special audit of ICI, will suffice, but
  I do not agree.  However, it seems that they simply dare not lose face by
  admitting that their report's conclusions (that 2 more incinerators will be
  a net benefit in terms of dioxin emissions) are based on incomplete and
  erroneously presented data.  Having had no reply from the Agency to any of
  my specific criticisms, also no satisfactory response from writing to John
  Gummer when he was Env Sec, I wrote to our new Environment Minister, Michael
  Meacher, in June.
  
  Mr Meacher passed on my letter to Tom Bastin, MP, to deal with.  I enclose
  his reply. Basically he uncritically accepted what the Agency told him.
  
  I have not yet drafted a reply to Mr Bastin, as my head is becoming quite
  dented from hitting this particular brick wall, but I will shortly.
  
  I will send, in separate messages, copies of 
  1) the letter I sent to Michael Meacher, Environment Minister. This was
  about various issues, including the faults in the Environment Agency's
  ICI/EVC dioxin report, and the lack of any real reply from the Agency.
  2) 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
  
  ########## Reply from Tom Bastin, Dept of Transport, Environment etc ###########
  
  Department of the Environment, Transport and the Regions
  
  TOM BASTIN
  INTEGRATED POLLUTION CONTROL POLICY
  AIR AND ENVIRONMENT QUALITY DIVISION
  ROOM B2/41 ROMNEY HOUSE 43 MARSHAM STREET LONDON SW1P 3PY
  
  DIRECT LINE: 0171 276 8747 DIVISIONAL ENQUIRIES: 0171 276 8311 FAX: 0171 276
  8592 
  GTN CODE: 276
  
  
  DATE: 7 AUGUST 1997
  
  Dear Ms Mountford
  
  POLLUTION CONTROL AT THE ICL/EVC RUNCORN SITE
  
  Thank you for your letter of 10 June to Michael Meacher concerning
  industrial pollution at the ICI/EVC site in Runcorn. You raised four related
  issues:
  
  1.       The Environment Agency's Special Investigation Team
  
  There have been a number of significant environmental incidents at ICI's
  Runcorn site over recent months. The Environment Agency considers this
  unacceptable and has created an independent audit team to consider if there
  are any common themes behind the events. I understand that this has involved
  a review of the incidents and a consideration of similar operations on a
  wider range of site processes. The Audit team has focussed on the following
  particular themes:
  
  - environmental aspects of the inter-plant piped transfer of materials. -
  environmental aspects of tank filling operations and dealing with any
  spillages - procedures for the design and inspection of storage tanks and
  bunds - maintenance of selected plants - procedures relating to plant
  overhauls - procedures relating to alarms, trips and interlocks (protective
  systems)
  
  In your letter, you express concern about the composition of the
  investigation team. The audit team comprised five experienced pollution
  control officers and a manager who spent 5 days auditing the Runcorn site
  between 3 and 9 July. Four of the team came from the Agency's Integrated
  Pollution Control (IPC) section and there were also officers from the Waste
  Regulation and Water Quality sections.
  
  Four of the team had had some routine involvement with the site but two came
  from other Agency offices in the North West. The Agency consider that this
  composition provided a good blend of skills combining the local knowledge of
  the site officers with the 'fresh eyes' of those new to the site.
  
  The Agency's decision to put together the team at Runcorn was only one of
  several measures taken. The other measures include:
  
  - calling in Runcorn site managers to answer questions on their
  environmental performance - enforcement action leading to prosecution for
  two serious offences; ICI were found guilt on both occasions on 20 March and
  2 July - national action by the Agency's Director of Operations who called
  in ICI national senior managers to express concern over the environmental
  performance at a number of sites round the country.
  
  2.      The Environment Agency's Dioxin Report
  
  The 1997 Information Report (Regulation of Dioxin releasesfrom the Runcorn
  operations of ICI and EVC) was prepared by the Agency to provide a clear
  overview of the issue and the Agency vigorously refute that it is flawed.
  The Report was intended to aid local debate and was specifically aimed at a
  non-technical audience which made it necessary for some of the data to be
  simplified in order to convey the findings - I understand that this approach
  has met with a favourable responses from many readers.
  
  The assessment of dioxin releases from the site and levels in the local
  environment is continuing and the Agency will make appropriate amendments to
  the report as dictated by new data or evidence.
  
  Since taking office, Mr Meacher has encouraged the Environment Agency to
  meet local stakeholders, to ensure that they are kept fully informed of
  developments, especially at controversial or contentious sites. I understand
  that the Agency has already offered to meet you to discuss their dioxins
  report and your critique and I would encourage you to take up the offer.
  
  3.    MAFF's nationwide sampling of dioxin levels in human breast milk
  
  The results of the MAFF survey of dioxins in human breast milk were reported
  in Food Surveillance Information Sheet No. 88 (copy enclosed). This included
  the congener specific results, and I enclose a copy. The survey was carried
  out as part of an inter-laboratory trial organized by the World Health
  Organization. Samples were collected from mothers in Birmingham, Glasgow and
  Cambridge, and the three sets of samples were pooled prior to analysis. As
  none of these locations is in the North West region, I regret that MAFF is
  not able to provide the information you request for this area. You may
  however be interested to know that MAFF plans to establish an archive of
  human milk samples from individual mothers across the UK. These samples will
  be analysed for a number of contaminants including dioxins. The survey is
  still being designed.
  
  4.      MAFF's survey of dioxins in cows' milk
  
  I enclose a copy of Food Surveillance Information Sheet No. 107 which
  reported the results of the MAFF survey of dioxins and PCBs in cows' milk
  from farms close to industrial sites. I also attach the congener specific
  results for the three samples taken from individual farms in the Runcorn
  area. I can confirm that these samples were analysed individually and were
  not pooled. The concentrations of dioxins in these samples were all within
  the expected range for the UK and
  
  well below the Maximum Tolerable Concentration of 16.6 ng TEQ/kg for dioxins
  and PCBs in cows' milk. There is therefore no risk to human health from the
  milk from any of the farms tested.
  
  MAFF cannot give the grid references for the these farms as the farmers were
  given assurances of confidentiality in this non-statutory survey. I can
  however confirm that they are all within 4.5km of the ICI/EVC plant. MAFF's
  criteria for inclusion of farms was that they should lie within 7km of the
  site. Two of the farms were also within 4.5km of the Alvaney tip and the
  third within 7km of this site. Thus it is not possible to rule out any
  influences from this site.
  
  A number of industrial processes may operate in areas surrounding any
  specific industrial site used as the centre of a sampling area. It is not
  possible from the results to determine the relative contributions of any of
  the sites listed to the concentrations of dioxins found in the milk from the
  farms sampled. The intention of the survey was simply to ensure that milk
  produced in the vicinity of industrial sites representative of processes
  known to have the potential to produce dioxins and PCBS poses no risk to
  human health.
  
  Yours sincerely 
  
  Tom Bastin
  
  [[He enclosed MAFF Food Surveillance Sheets nos 
          88 - May 96 Dioxins in Human Milk
          107 - June 97 Dioxins & PCBs in Cows Milk from Farms close to
  Industrial Sites.
  After a reminder, he later sent the test results for cowsmilk sampling at
  the 3 farms near ICI & Alvanley]]