Dear Sir,

Have no illusions. Castle Cement, the German owned operator of the Padeswood plant, has to treat their new kiln as a toxic waste incinerator not a cement kiln because they want to burn paper, plastics, old tyres and CEMFUEL, a volatile cocktail of toxic wastes, rather than coal. CEMFUEL, with 20 times more Group III heavy metals, and 1,000 times more halides like bromine, chlorine and flourine, than the coal that it displaces, costs less than one sixth the price of coal. CANK opposes the erection of a 360ft high and 60ft wide preheater tower on Landscape grounds, and the new incinerator because the particle and dioxin emissions from using CEMFUEL could create a very serious long term risk to public health over a wide area of North Wales, Cheshire and the Wirral.

Modernisation of the plant is overdue, for there have been more than 250 unauthorised emissions in the past 4 years, but high incinerator temperatures will break down some of the chlorine based substances into dioxins and furans, amongst the world's most dangerous chemicals. Most of these will form part of the cement or go into landfill, but some will emerge in the gas "plume" and settle on downwind farms. Dioxins only leave a body as part of the food chain in the form of milk, so infant babies are most at risk. When LESS THAN TWO GRAMS of dioxins and furans were accidentally mixed into animal feed in Belgium, $1 billion worth of food had to be destroyed.

Michael Meacher, the Environment Minister, said in Parliament:
        "We know scientifically that there is no safe threshold below which one can allow such emissions .... incinerator plants
        are the source of serious toxic pollutants: dioxins; furans; acid gases; particulates; and heavy metals .... it is wrong to say
        that we should not worry about it...".

The heavy metals in CEMFUEL will be vapourised by the new incinerator, but will re-condense on cooling into ultra-fine particles weighing just a few millionths of a millionth of a gramme (picogrammes) : typically, the smaller the particles the more damage they do to human health. Dr Holgate, one of the most senior specialists on Respiratory Cell and Molecular Biology said "there is now increasing evidence that the ultra fines ....in their own right do have a special tissue damaging effect, independent of their chemical composition".

Dust emissions are to be controlled by some 3,000 fabric bags, like a Hoover bag but 19 feet long and 5 inches wide, and detecting and replacing bags with holes is difficult. Despite Castle Cement's claim that 99.9% by weight of the dust is filtered out, CANK have been advised that up to 90% of the ultra-fine particles will penetrate the bag fabric.

CANK believes that this is a very serious public health issue. It is not confined to Flintshire, but concerns us all. The application should be refused on health grounds, or called in by the Welsh Assembly and made the subject of a public health enquiry.