1) There are serious scientific mistakes in the ISC report
2) The Medical Working Group Report is not valid
3) The questions already raised by Quercus have still not been answered
4) Quercus is taking judicial steps if it does not receive answers shortly
 
 

1) There are serious scientific mistakes in the ISC report

According to the Minister of Environment, José Socrates, there were  no reasons put forward during the public consultation and discussion period that justified questioning the reports of the ISC and the Medical Working Group[1]. This, we feel, is not true. Quercus drew attention to a fundamental mistake in the ISC report:

It is not correct that there are no increased emissions from cement factories carrying out co-incineration compared to cement factories under normal laboration.

The US Environmental Protection Agency confirmed explicitly the opposite of that stated by the ISC report and it would appear that the European Commission does not accept this presupposition either.
The Evaluation Commission of the Environmental Impact of Cement Factories discussions in 1998 also contradicts the ISC. A detailed analysis of the quoted bibliography by the ISC also leads to the conclusion that there is no scientific basis for such a position.

Besides that, the ISC ignores a whole group of other organic pollutants in its 'no increased emissions' thesis. To be more
precise, this report ignores all organic pollutants aside from dioxins and furans, including PCBs, PAHs, benzene and others. It
even excludes the risks of accidents, despite regulations in the law that explicitly foresee such incidents: Law nº. 352/90 of 9 November permits 170 hours per year and per product line without any verification of limit emissions. If we take for example the cement factory installations in Souselas, where there are three production lines, this corresponds to 510 hours (3 weeks) without any verification of limit emissions. It is obvious that, if there were any hazardous wastes in the process, the consequences of eventual accidents could be very different than if there were no such wastes involved. The Evaluation Commission of the Environmental Impact of Cement Factories also expressed much concern about possible consequences of eventual accidents.

The ISC thesis that there are no increased emissions from cement factories burning toxic waste is therefore FALSE, as substantiated in more detail in Quercus´s report:
Evidence of Increased Emissions by Co-incineration of Hazardous Industrial Wastes in Cement  Factories:
A critical analysis of some important issues in the ISC and the Medical Working Group reports?
(www.quercus.pt/cir - Relatorios).
 

2) The Medical Working Group Report is not valid

The Medical Working Group concluded that co-incineration is harmless, based on the ISC's assumption that there are no increased emissions, as quoted from their report:

The available scientific proof points to the conclusion that co-incineration is harmless, at least in the sense that replacing
part of the conventional burning fuels for waste will not increase noxious emissions. Under these circumstances, co-incineration will not contribute to increased exposures to substances hazardous to the public health, neither through atmospheric emissions or through the cement produced? [ISC report Vol. 2, page 126].

As the thesis is false, the report of the Medical Working Group is also not valid. Besides that, the Medical Working Group ignored the possibility of accidents. It also ignored the fact that unfortunately, in Portugal the emission limits are often exceeded as a rule.

What is even more important is that the Medical Working Group does not answer the most important question:
Will the surrounding populations of the cement factories withstand the additional impact that co-incineration represents? Is it
possible, for example, that the degree of contamination of mothers' milk has not already exceeded the maximum allowable limits?

To answer these questions, it is necessary to carry out epidemiological studies before taking the definitive decision on the
co-incineration process. It is obvious that deciding first and carrying out an epidemiological study later is not a scientifically
defendable method.
 

3) The questions already raised by Quercus have still not been answered

Q       The Minister of Environment has not given any signal for the immediate implementation of the National Plan for Industrial Waste Prevention, or showed intentions to include in that Plan the detailed analysis of industrial sectors such as oil refineries and
electric energy production, responsible for large quantities of industrial hazardous wastes;

Q       The Minister has not given any guarantees that used oils and solvents will be excluded from the list of wastes that can be
          co-incinerated or that this list will be revised every two years;

Q       The Minister has not given any insight into matters such as the locality and functioning of the pre-treatment station for
          industrial wastes;

Q       The Minister has not talked about creating any 'S.O.S. Environment' hotline;

Q       The Minister ignored the necessity to penalize companies that do not hand in their industrial waste registers;

Q       The Minister continues to ignore other urgent measures other than co-incineration, such as landfills, to provide some
          temporary solutions for industrial waste;

Q       The Minister also ignored the fact that the Accompanying Commission (AC) for the co-incineration process should have
          sufficient technical and financial provisions, as well as access to all information and installations necessary in order to
          guarantee its proper functionality;

Q       The Minister ignored the need for a network to monitor the atmospheric emissions even before the start of any type of
          co-incineration, including during the test runs, and the need of more information about the parameters to be measured;

Q      The Minister ignored the necessity of an epidemiological research before any final decision;

Q       The Minister has not made clear which legal questions apparently forbid contemplation of the cement factory in Outão,
          located in the Arrabida Natural Park, as a potential site for co-incineration.
 

4)  Quercus is taking judicial steps if it does not receive answers shortly

Quercus is giving the Minister, by means of a letter, 10 days to respond to the conditions presented here, conditions on which depend the acceptance of co-incineration. If Quercus does not receive an answer within these 10 days, it is taking judicial steps in order to stop/modify the co-incineration process.
 

Lisbon, 11th April 2001

Quercus - National Association for Nature Conservation
Contacts: Rui Berkemeier +351 21 7788473 or + 351 93 4256581

[1] The task of the Medical Working Group was to study the impact on public health of the processes of incineration of hazardous industrial wastes, taking into account the localization near inhabited areas.