Related Article

Summary
Friends of the Earth is calling for:

Introduction
Brief Glossary
        Cemfuel
        EPAQS
        National Air Quality Objectives
        Particulates
        PM10
        SO2
Weather Conditions
Kiln Shutdowns
Health Impacts
        Breaches of EPAQS PM10 standards
        Breaches of EPAQS SO2 standards
        Comparison with City Centre Sites
Comparison with Uk National Air Quality Objectives
Odour Problems
Plume Grounding
Effect of Cemfuel on Castle Cement's emissions
Misleading Interpretation of Mobile Laboratory Results
The Health Implications

Conclusions
Friends of the Earth is calling for:

References

Table 1
Table 2
 
 

Summary
1) On Monday June 16th the Environment Agency published an 8-volume report [1] on a £500, 000 study examining air pollution around Clitheroe, Lancashire, a small town in a rural location which is adversely affected by air pollution from, predominantly, a cement works run by Castle Cement Ltd.

2) This report demonstrates the large air pollution problem that is present in Clitheroe, and proves that Castle Cement's Ribblesdale works is the main culprit. However, Friends of the Earth is disturbed by the misleading presentation of this work by the Environment Agency.

3) Weather conditions were windy during the survey period (14/10/96-8/12/96), which would be expected to reduce pollutant build up. In spite of this levels above the Government's EPAQS health limits for PM10 and SO2 were recorded at the Environment Agency's fixed monitoring sites.

3) The Environment Agency claims in its press release that 'Air quality was found to be generally typical of other similar areas', whilst in fact pollution levels were higher than those in the centre of Liverpool and Leeds!

4) Monitoring by mobile laboratory confirmed that Castle Cement-derived SO2 is responsible for the odour problems that residents experience, and measured high levels of particulate. The executive summary makes the very misleading statement that  'No exceedances of the EPAQS limits for Nitrogen Dioxide or PM10 particulate matter were recorded'. However the mobile laboratory only measured pollutants for a few hours in each spot,  and the PM10 EPAQS standard requires a 24 h average, so it was impossible for the EPAQS standard to be measured, never mind breached.
Friends of the Earth believes that this statement is inserted purely with the aim of misleading the reader.

5) The report shows that burning hazardous waste -derived Cemfuel does increase pollution. Emissions of both lead and particulates more than double. Due to missing data we have no information on its effects on SOx and NOx.

6) The Environment Agency's misleading presentation of this data demonstrates that it is not being 'a fair and rigorous regulator', as the Environment Minister Michael Meacher stated that he had told it to be on the 18th June in a written answer to parliament [5].
 
 

Friends of the Earth is calling for:
1) The Environment Agency to come clean on the real results of its survey - rather than its pro-cement industry, sanitised approach so far. The Agency's approach to the cement industry is further tarnishing its image.

2) No burning of hazardous waste (Cemfuel) until it has been proven that it has no effect on health.

3) A thorough study of the effects on respiratory health of air pollution in Clitheroe, now it is clear that health standards are being breached.

4) A thorough examination of exposure to lead of the people of Clitheroe, as this study shows that the burning of hazardous waste (Cemfuel) is more than doubling lead emissions. This study should involve blood and/or teeth samples, and include use of isotopic ratios to determine the origins of the lead in people's bodies.

Items (1) and (2) are the responsibility of the Environment Agency,
whilst (3) and (4) are the responsibility of the Department of Health
and the Regional Health Authority.
 

Introduction
This report from the Environment Agency cost £500, 000 of taxpayer's money, and used a variety of monitoring methods to establish air pollution situation in and around the small town of Clitheroe. This town has three industrial plants: ICI Katalco, Tarmac and Castle Cement.
Castle Cement has had a long history of air pollution problems, and this report was intended to discover the facts about air pollution in Clitheroe.
Below we list Friends of the Earth's analysis of the most significant findings of this Environment Agency study [1]. We also point out where we consider that the Environment Agency has been 'economical with the truth' in its presentation of the data, in some cases to a quite astounding degree.
 

Brief Glossary

Cemfuel - A mixture of hazardous wastes, mainly solvents, which Castle Cement burns in kilns 5&6 of its Clitheroe works, though not in kiln 7 of the same works.

EPAQS - The Government's Expert Panel on Air Quality Standards, who have set safety standards for several pollutants

National Air Quality Objectives - A set of standards objectives defined by the Government, aiming that the annual number of failures of EPAQS standards should be at a very low level by 2005. To test whether these objectives are being met requires a full years monitoring, as monitoring over a short period cannot reliably be scaled up. For example, windy weather during the monitoring period will not be repeated all year.

Particulates - small particles of material, which have been found to have significant negative impacts on health

PM10 - Particulates which are less than 10 .m across. These can penetrate deep into the lungs, aggravating Asthma and other respiratory problems. The EPAQS standard for particulates is 50 g/m3, averaged over a 24h period.

SO2 - An acidic gas, which irritates the lungs. The EPAQS standard for SO2 is 100 ppb, averaged over a 15 minute period.
 

Weather conditions
The weather was windy during the monitoring period, leading to good dispersion of pollutants. It is clear that without this wind pollution levels would have been much higher, as pollutants built up. However, this is not mentioned in the press release. Remarkably, in the Environment Agency's response [4] to the Environment Select Committee's report on the cement industry [2] it claims that 'The weather, during the study, covered most dispersion conditions and work at the three main
industrial sites (Castle Cement, ICI and Tarmac' was typical of normal operation.' (also note the kiln shutdowns mentioned below).
The report demonstrates the true conditions:
'The air quality measured at DoE national networks sites during the campaign was generally good, on account of relatively windy conditions. Thus the concentrations measured at these sites were generally lower than for 1996 as a whole' [1, Air Quality Review]
'..the campaign period was characterised by generally vigorous westerly flow producing relatively efficient dispersion of pollutants' [1, Air Quality Review]
 

Kiln shutdowns
During the monitoring period 28th October - 10th November, kiln 5 was shut down from 2 - 10th November, and both kilns 6 and 7 were shut down from most of the 8th November. In addition, Cemfuel (which is normally burnt in both kilns 5 and 6) was only being used at about 25% of fuel, rather than the normal 40%.
As a result of these changes, it would be expected that pollution, particularly during November, would be much lower than in normal operation.
Of course, Castle Cement also knew that this study was going on, so were able to alter their operational procedures if they so wished.
 

Health Impacts
Breaches of EPAQS PM10 standards
In spite of the windy conditions, two of the fixed monitoring sites (Higher Asker and Clitheroe Hospital) breached the 24h standard of 50 g/m3, with Chatburn avoiding it by a very narrow whisker , with 49.7 g/m3.

Breaches of EPAQS SO2 standards
The 15-minute standard of 100 ppb was breached at 5 out of the 7 fixed monitoring sites, despite the windy conditions.

Comparison with city centre sites
At several sites around Clitheroe average levels of PM10 particulates and peak SO2 levels were higher than in Liverpool or Leeds during the same period (see Tables 1 and 2). However, the press release states 'Air quality was found to be generally typical of other similar areas', and their response to the Environment Select Committee [4] said 'Indications
are that the concentrations of Sulphur Dioxide and PM10 air not unusually high for a semi-rural location like Clitheroe'.
Since pollution is higher than in the centre of a large city, it is hard to see how these statements can be justified - and comments in the rest of the report suggest that they aren't:

'The higher average [PM10 concentration] at the Chatburn site is similar to long-term averages for city centres and is notable in view of the fact that Chatburn is an outlying village' [1, Air Quality Review]

'It is also notable that the mean [PM10] concentration at Chatburn was larger than the values observed concurrently in Liverpool and Manchester and similar to long-term mean values for city centres.' [1, Air Quality Review]

'The peak SO2 concentrations recorded in the Clitheroe area were generally higher than those measured at DoE [air quality network] sites during the period' [1, Air Quality Review]
 

Comparison with UK National Air Quality Objectives
The comparisons with annual failure percentages are meaningless, as the survey was undertaken in a windy period - monitoring over the entire year would be expected to register far worse results.
 

Odour problems
The report confirms that emissions of SO2 from Castle Cement are correlated with the odour complaints from Clitheroe residents.[1, Summary]. However, no further progress has been made on identifying what chemicals cause this odour, as the odour of SO2 is only detectactable at concentrations above 450 ppm, higher than is detected here.
 

Plume grounding
The DIAL (Differential Absorption Lidar - a laser - based analysis method) measurements confirmed that Castle's plume frequently grounded [1, DIAL].
 

Effect of Cemfuel on Castle Cement's emissions
The report confirms that when Castle Cement burns Cemfuel (liquid hazardous waste)
Lead emissions increase substantially [1, Summary]. Lead emissions from the stack from kilns 5 and 6 increased from 0.11
mg/m3 on 28th October with no Cemfuel, to 0.28 mg/m3 on 29th October with Cemfuel [1, Monitoring at Castle Cement]. Unfortunately, neither PM10, SO2 nor NOx were measured in this stack on the 28th, when Cemfuel was not in use, so we have no baseline emissions for these pollutants.
However, total particulate is measured, increasing from 10.39 kg per hour on the 28th (no Cemfuel) to 18.48 on the 29th, 26.30 on the 30th and 23.87 on the 31st (all with Cemfuel). This data shows a doubling of particulate matter emissions when Cemfuel is being burnt.
 

Misleading interpretation of Mobile Laboratory results
As well as the fixed monitoring sites, the Environment Agency also operated two mobile laboratories, which measured pollution around the Clitheroe area.
The Executive summary for the Mobile Laboratories section of the report states that: 'No exceedances of the EPAQS limits
for Nitrogen Dioxide or PM10 particulate matter were recorded'.
BUT the only EPAQS limit for PM10 is 50 g/m3 24 hour average. All the monitoring in this report was done over a few hours, so it was impossible for this standard to be measured, never mind breached.
In Friends of the Earth's opinion this statement is only inserted in the executive summary to mislead - it has no scientific justification at all. Of the 25 PM10 measurements made, 18 had maxima above 50 g/m3, with the highest 253 g/m3 at Bellman farm roadside on 29/10/96 - we have no information on what the 24h average is at this site.
It is unfortunate that there is, as yet, no health standard for acute exposure to PM10, despite evidence that it has health implications for those with respiratory and cardiac problems [6]. The World Health Organisation have said that there is no safe level of PM10 as there is no threshold below which there is no health effect.
 

The health implications
This study makes it clear that the air pollution from Castle Cement is leading to regular breaches of the health-based air quality standards.
Friends of the Earth therefore believe that the Department of Health should immediately fund a study of the effects of this air pollution on the health of those exposed to it.
The report also shows that the population of Clitheroe and surrounding areas is exposed to increased lead emissions when hazardous waste (Cemfuel) is burnt. Lead is a known neurotoxin (which is why it is being phased out of petrol), and accumulates in the body. It can be measured in the blood and teeth, and, using a sophisticated technique called 'Isotope Analysis' the sources of lead can be discovered (e.g. how much exposure comes from lead in petrol or paint compared with how much comes from the cement kiln pollution). We believe the Department of Health should also fund a programme to examine lead levels in the blood of the people of Clitheroe.
 

Conclusions
Friends of the Earth welcomes the effort and financial resources that the Environment Agency have put into commissioning this detailed study.
However, we are appalled at the misleading interpretations that have been put on this data in the press release accompanying the report and in the executive summaries of the individual reports.
This pro-cement industry spin reinforces Friends of the Earth's concerns that the Environment Agency is not doing its job properly.
In their desire to keep friendly with the cement industry, the EA are deliberately misleading the Government, Parliament and the Public.
The attitude of the Environment Agency towards regulating the cement industry has recently been condemned by the House of Commons Environment Select Committee, who said in their report published in March 1997 [2] that the Agency was 'inconsistent' and 'inefficient' in its handling of the cement industry and that there were "serious inadequacies" in
monitoring of pollution at cement kilns.
The Environment Minister Michael Meacher, launching the Government's response to this report [3]
in a written answer on the 18th June said that the Agency must be 'a fair and rigorous regulator' [5]. Michael Meacher also said that:

'The Agency's management has assured me that it is committed to the changes which are needed to ensure that industrial pollution is controlled in a manner which will command the full confidence of Parliament and the public. I can assure Members of this House that I intend to hold the Agency to that promise'

This report shows that the Environment Agency is not following Mr
Meacher's instructions.

Friends of the Earth is calling for:
1) The Environment Agency to come clean on the real results of its survey - rather than its pro-cement industry, sanitised approach so far.
The Agency's approach to the cement industry is further tarnishing its already poor image

2) The Environment Agency should stop Castle Cement burning Cemfuel, which this report confirms doubles lead and particulate emissions, until it has been proven that it has no effect on health.

3) The Department of Health to fund a thorough study of the effects on respiratory health of air pollution in Clitheroe, now it is clear that health standards are being breached.

4) The Department of Health to fund a thorough examination of exposure to lead of the people of Clitheroe, as this study shows that the burning of hazardous waste (Cemfuel) is more than doubling lead emissions. This study should involve blood and/or teeth samples, and include use of isotopic ratios to determine the origins of the lead in people's bodies.
 

References
[1] Environment Agency, 'Air Quality Monitoring in the Clitheroe Area of
Lancashire' (8 volumes), June 1997.
[2] House of Commons Environment Select Committee, 'The Environmental
Impact of Cement Manufacture', March 1997.
[3] Government Response to the Third Report of the House of Commons
Environment Select Committee Session 1996-7, June 1997.
[4] The Environment Agency's Response to the House of Commons
Environment Committee Report on the Environmental Impact of Cement
Manufacture, June 1997.
[5] Hansard Written Answer 4830, 18th June 1997, also in Department of
the Environment, Transport and the Regions press release 'Environmental
Impacts of Cement Manufacture: Government Response to the Environment
Select Committees Report', 18th June 1997.
[6] 'Non-Biological Particles and Health', Committee on the Medical
Effects of Air Pollutants, Department of Health.
[7] 'Monitoring of plume grounding events in the vicinity of the Castle
Cement Works, Ribblesdale', NPL, 1995
________________________________________________________________________
_
This Report was written in July 1997 by:
Dr. A. Michael Warhurst,
Industry and Pollution Campaigner,
Friends of the Earth (England, Wales and Northern Ireland),
26-28 Underwood Street,
London N1 7JQ
Tel: 0171 490 1555
Fax: 0171 490 0881
Email: michaelw@foe.co.uk

Ver: 1.1
 
 

Dr. A. Michael Warhurst
Industry and Pollution Campaigner
Friends of the Earth
26-28 Underwood Street
London N1 7JQ
Tel: 0171 566 1685
Fax: 0171 566 1689
Email: michaelw@foe.co.uk
Web Site:- Introduction to Hormone Disrupting Chemicals  (personal, not FoE):
--------------------------------------------------------------------

Other Related Articles
April 2000
The Peak Associates Report
    The Environmental Impact and the Public's Perception of The Effectiveness of Integrated Pollution Control At
    Castle Cement Clitheroe Lancs