See also related report in The Chester Chronicle 22nd December 2000
To Ms L Heathcote,
The Environment Agency,
PO Box 19,
South Preston,
PR5 8GD.
7th January 2001.
Dear Madam,
BJ1389; Proposed Incineration of the Hazardous Toxic
Waste “Cemfuel”
in Kiln 7 at Castle Cement’s Ribblesdale Plant,
Clitheroe.
On behalf of the Group, I wish to oppose the above application, for the reasons set out below;-
1.As Group Chairman, I made a formal submission to the
Agency, yet was not invited to the “surgeries” nor was
I sent a copy of BJ1389. Several other
consultees were treated in exactly the same way. When this was raised
with Mr Coulburn by two members, his
response to both was unacceptably rude.
2.Castle were allowed to trial a “lower” specification
of “Cemfuel” than that proposed, yet this was not
revealed, not least at the 6th December
meeting with FoE Group members at Walton Summit. Why not?; the
necessity for openness was one of the
major criticisms of the March 2000 SELCOM investigation into the
Agency, but this is ignored.
3.Once again, the Agency has contrived to arrange “consultation”
at a time when the World is otherwise
occupied; this has happened far too
often for it to be a coincidence, as has been suggested.
4.The wording in BJ1389 is highly misleading, notably the
garbled explanation as to the departure from the
proposed mix, and the claim of “maximum”
rate of substitution in the tables when only a 33% average was
achieved.
5.The results show that even so, this was only achieved
after relaxing the CO levels for the trials and again
during the trials, so as to prevent
“trips”.
6.In setting scrubber “off-times”, no account has been
taken of the high residual levels of metals present for
hours in the kiln, which must be released
into the atmosphere when the scrubber is off.
7.Confirmation was sought at the surgery, and is again
requested, as to whether there is continuous
tamper-proof recording of the scrubber
and monitors.
8.It was not possible to ascertain at the “surgery” if
the proposed mix was burnt at all, nor why Castle could not
provide “Cemfuel” to meet it, but it
was confirmed, on several occasions and in response to direct questions,
that ANY departure from the mix trialled
would trigger new trials.
9.This Group has no faith in the Agency to adequately monitor
Castle Cement, in particular following the
Lancaster prosecution, since when the
foot has been taken off the pedal, rather than a heightened level of
diligence. Plume grounding continues,
as the Judge said it must, yet the Agency does nothing.
10.No cognisance is being taken of the possible health effects
of incinerating “Cemfuel”, in spite of current
studies, as pointed out by Peak
Associates.
11 The assertions regarding only one mix of “Cemfuel” being on
site at any one time beg acceptance of Castle’s
and the Agency’s competence and goodwill,
neither of which can be taken for granted. It is significant that
Castle have the gall to suggest that,
even though the proposed trial mix could not be “found”, it should be
approved for continuous burning; this
is scandalous!.
12.I refer you to Peak Associates’ comment that, in approving
“Cemfuel” in Kiln 7, the Agency would knowingly
be “approving a process which is unable
to operate within authorised limits” and may leave it open to Judicial
Review.
13.No decision should be taken until the conclusions of the Padeswood
Public Inquiry and the Judicial Review are
published. It is not sufficient to say
[at the surgery] that “any conclusions will be taken into account”.
14.Given the inability of the valley to self-cleanse and the continuing
problems of air quality from Industry, there
should be a comprehensive health study
of the human and animal population, as demanded by two of the
Selcoms.
Finally, it is our view that kiln 7 is too unstable to incinerate hazardous toxic waste, and we call upon the Agency to reject the application. We also remind the Agency of the promise [7 above] that any departure from the mix trialled will set in motion a new set of trials.
Yours Sincerely,
Mr J D Mortimer, Chairman.