BRAINS

Q1: What is wrong with burning rubbish and making it disappear?

A1: Mass burning (incineration) of waste does not make it disappear. Indeed the way that incineration changes the visible into the invisible and the known into the unknown is one of its most dangerous consequences. Just because you don’t see the pollution does not mean it isn’t there. (The Lethal Consequences of Breathing Fire, Pat Thomas, September 2007, Ecological Online article)

The end products of incinerating waste are filter fly ash, bottom ash and toxic gas and particulate emissions.

Filter fly ash contains concentrated dioxins and heavy metals, and accounts for about 5% of incinerated waste. It has to be sealed into containers and disposed of as hazardous waste in special landfill sites that are licensed to accept toxic waste. We are concerned about possible accidental releases and eventual leaching from these disposal sites.

Bottom ash could account for 30% of the original mass. It is not classified as hazardous waste in the UK. In Europe, Austria and Hungary treat it as hazardous waste, while others define it as non-hazardous material but impose stringent tests. Japan officially says it is non-hazardous but in reality the ash is vitrified to seal metals and dioxin-like chemicals for recycling. In the US the ash has to pass Toxicity Characteristics Leaching Procedure. The threat of liability for years to come has deterred many operators from using their ash.

Bottom ash does contain the same toxins as fly ash but at reduced concentrations. It is not inconceivable that eventually bottom ash will be classified as hazardous material in Europe. That will add further costs to incineration and may change the economic basis for justifying the incinerator

We are only too aware of what happened after the tunnel collapsed at the Tesco construction site in Gerrards Cross in July 2005, when bottom ash was used as infill material around the tunnel. Issues of contamination were investigated by the BBC’s “Inside Out” programme in February 2007. (#1)

Austria, Belgium, Denmark and Germany impose a tax on those who manage incinerators for each tonne of refuse burned thus discouraging the incineration of refuse. (Notiziario FIMMG – Italian Family Doctors’ Federation, May 2006)

The infamous incident in Newcastle where a mixture of bottom and fly ash was used for constructing paths in allotments is still fresh in people’s memory. (#1)

CHALLENGE: BCC must make sure that bottom ash as well as fly ash samples applicable to the planned incinerator and its waste streams are vigorously analysed to ascertain contamination levels, and that the residents are satisfied with the safety of the planned disposal practice.

Q2: Aren't modern incinerators safe and clean?

A2. Since there are substantial data maintaining they are not, we ask the Council to prove the safety of the incinerator they are planning to have built.

It is true that modern waste incinerators are designed to meet stricter emission standards when operating under standard design conditions. We do not know how much contamination is discharged when their operating conditions deviate from them. Regulations do not require continuous measurements of key contaminants such as dangerous fine particles called PM2.5, heavy metals such as mercury, cadmium, zinc, arsenic, etc. and dioxins.

Modern incinerators release harmful air-borne fine particles and produce hazardous ashes containing poisonous dioxins and toxic heavy metals. Most modern incinerators are larger so if something does go wrong, the impact on the area near the facility will be much bigger, just as is the case when modern bulk carriers founder.

A previous report to Parliament (Memorandum by Public Interest Consultants DSW 56) in 2000 estimated that incinerators would cause hundreds of deaths each year. The BSEM (British Society for Ecological Medicine) report discusses the study by Elliot who found an excess of 11,000 cancer deaths around incinerators and this may have been a considerable underestimate.

In fact in the USA the building of new incinerators has virtually been stopped since the mid 1990s. (#2) In Japan large thermal gasification plants are operating successfully and vitrification of the ashes is becoming more common to seal toxins within molten slag.

CHALLENGE:We ask the Council to prove that the currently planned incinerator and its operations will be safe with no adverse health effects associated with it.

Q3. What pollutants do incinerators produce?

A3.The United States Department of Health and Human Services, Agency for Toxic Substances and Disease published a list of eight groups of pollutants from an incinerator in Tennessee. They include acidic gases & unburned hydrocarbons, in addition to very fine air-borne particles, toxic heavy metals. They also produce dioxins and furans which can act as "Gene Switches" causing birth defects, mutation and cancer. They have actually identified more than 500 individual substances a large number of which are harmful to human life.(#3) Of course they also produce huge amounts of CO2 in contradiction to the UK’s commitment to reduce global warming.

Challenge:We request the Council to identify specific pollutants and inform us how much of them will be produced both in gas emissions and the ashes by the planned incinerator.

Q4. Surely the UK government regulations protect public health?

A4. We do hope so. However, we start to worry when we read Parliamentary Post 149, December 2000, 'Incineration of Household Waste, where they state that emission control can be balanced against EXCESSIVE COST, without stating who decides what is excessive cost. This clearly means that emission standards are NEVER guaranteed to be at a safe level and clearly raises concerns over whether the setting and enforcement of standards, and process authorisation fulfil the Agencies' requirement to protect human health.

Q5. Does EfW mean "the waste incinerator"? BCC says it is safe and clean.

A5. We are asking the Council this very question because the public is confused about the way the Council uses this term. Does it include safer plasma and thermal pyrolysis/gasification technologies? Did the Council carry out evaluations of them? Were the tender documents issued to suppliers of such technologies? Both EU and the UK governments recommend the local authorities to consider the developments of newer technologies to make sure best available technologies without excessive costs are adopted.

To a member of BRAINS team who had requested such information under the Freedom of Information Act on 22nd November 2007, the Council’s Freedom of Information Officer replied on 21st January 2008 as follows: “Energy from Waste is a generic term that for this Project means technologies which recover energy from waste and includes thermal waste treatment technologies which generate energy (e.g. incineration, pyrolysis and gasification). The results of the options appraisal in the approved Outline Business Case published in January 2007 cover this point. For the specific details, please see section 5 of the report from page 39 to 53.”

The above is the Council’s reply to a simple question, “Did the Council evaluate advanced thermal treatment such as pyrolysis and gasification either by thermal or plasma technologies as part of EfW or not? If yes, provide me with the results. If not, why not?”

When we examine section 5 of the referenced report and the summary of options appraisal table in section 11, it appears as if only the conventional incinerator had been selected to represent EfW. We are still kept in the dark as to whether the Council carried out proper evaluations of the advanced technologies or not.

On 4th February we received the following reply. To our questions

(1), “Is it correct to assume then that the Council will be receiving the detailed proposals (round 2) including EfWs based on pyrolysis and gasification technologies?”

BCC: “We cannot say, as we have not yet received detailed proposals. They are due later in 2008.”

To our question

(2), “At what stage will the Council be selecting either conventional incineration or pyrolysis or gasification technology?”

BCC: “We will evaluate proposals as per the published timeline, available at: http://www.buckscc.gov.uk/bcc/content/index.jsp?contentid=651070377.”

Martin Tett, BCC cabinet member strategic planning says in the September 2007 issue of Beaconsfield Life, "EfW (Energy from Waste) is a clean solution and people are not even likely to see fumes from the chimney unless on a very cold day", which sounds like the Council actually means “the waste incinerator”.

CHALLENGE: How can the Council justify confusing the residents especially when the reopened public consultation draws near?

Not being able to see fumes from the chimney does not mean they are safe. Hundreds of contaminants are not visible to the human eye. For example particles of about 2.5 microns and under called PM2.5s. You can fit more than one million of them on this single dot of the letter "i". And no naked eye can see them. Our own government ADMITS they cause respiratory & cardiovascular illnesses. They are also linked to infant mortality rates & birth defects. There is NO SAFE LEVEL at which ill health effects do not occur. (#4)

Q6. But the Council says that only 7.3% of the total particle emission comes from waste management. (Cllr. Martin Tett) & that cars, fireworks, bonfires and barbeques & even domestic cooking produce more dioxins.

A6. Can the Council explain how they can equate the particles produced in the incinerator at very high temperatures in the presence of heavy metals, dioxins and unburned hydrocarbon PAHs with particles from bonfires and barbecues?

“The higher the temperature at which a combustion process takes place, the smaller the dimension of the particles that are produced. They are inorganic particles, that are non-biodegradable and non biocompatible. Combustion transforms refuse that is innocuous into products that are toxic and dangerous.” (Notiziario FIMMG – Italian Family Doctors Federation, May 2006)

This is precisely what Prof. A. M. Gatti warns. It is the particles coated with these contaminants and their numbers that cause dangers! The smaller particles not only go into the blood stream but they are actually being found in the nuclei of cells without breaching the cell walls! Macrophages engulf them to protect the body but they CANNOT break down inorganic matter. So when macrophages die the particles just go back into the system. Now there is a technology to actually fingerprint particles to trace them to their emission sources, which is a warning to the decision makers who sanction building of waste incinerators. (#5, #5A)

The decision notice apropos the contested Newhaven incinerator includes the applicant’s description of the efficiency of the proposed bag filter. “The filters are designed to remove 95 to 98% of PM10 (larger) particles and 65 to 70% of PM2.5. Below PM2.5 (smallest) the filters are less efficient removing between only 5 to 30% of particulates.” The smaller the particles the more reactive surface areas per mass they have, making them particularly dangerous. This is precisely why many researchers such as Prof. A..Gatti are now calling for URGENT reduction in the already existing levels of pollution.

As for dioxins, the U.S. EPA found that medical and municipal waste incineration were the first and second largest sources of dioxin air emissions in 1994 contributing 84% of the total emissions. In Japan incinerators are responsible for 93% of dioxin emissions, in Switzerland for 85% of emissions and in the UK responsible for 79% of emissions. The authors of the European Dioxin Inventory state "Despite considerable effort having been spent during the last years to decrease emissions from municipal waste incinerators, this source still dominates the input of dioxins into the atmosphere.” (Reply to Enviros Communication of September 2006, British Society for Ecological Medicine)

Q7. Enviros, consultants who have been working for DEFRA (Department for Environment, Food and Rural Affairs), say that a small incinerator (100,000 tonnes/year) will produce only a few grams of dioxins. The Environment Agency has concluded "dioxin emission contribution to exposure of local population is entirely negligible". What harm could such small amounts of dioxins do public health?

A7.DEFRA’s position statement is based on the work done by the consultants Enviros. Royal Society’s review of November 2003 criticized the report by pointing out: (1) No consideration is made for the effects of recovering materials. (2) Giving a misleading impression in view of the large uncertainties of the data. (3) Caveats associated with the uncertainties particularly in the health effects are not adequately presented, which could mislead the reader. (4) The report’s relevance to waste management decision-making by Local Authorities is limited, as several important issues are not addressed. These include the effect of local environmental and health sensitivity to pollutants and the impact on emissions of specific waste management activities operating under non-standard conditions.In response to substantial concerns raised in the review of the report in November 2003 the authors produced a revised version. Royal Society's review of the final version was in March 2004.(#12)

“The largest source of dioxin and furan emissions has been, and still is, waste incineration.” (Dore et. Al) Dioxins are some of the most poisonous chemicals ever produced by humans. 　They are never "made" deliberately. Exposures to infinitesimally small quantities, 1 or 2 trillionths of a gram, are linked to cancer, severe reproductive and developmental problems, damaging the immune system and interfering with the hormonal systems. 　There is no threshold below which dioxin intakes are considered safe, so "a few grams" is actually a very significant quantity.

Dioxins are bioaccumulative. Once discharged into the environment dioxins work their way up to the top of the food chain. Men have no way to get rid of dioxins other than letting them break down according to chemical half lives. The half life in humans is 8 years and that in soil is more than 10 years. (#6)

Women, on the other hand, have two ways in which dioxins can exit their bodies.

(1) Dioxins cross the placental barrier into the growing infant.

(2) Dioxins are present in breast milk and are taken in by the baby.

World Health Organisation has set guidelines for daily intakes. A recent Dutch study found that nursing infants consume about 50 times more dioxins per day than adults do. (#1)

Q8. Enviros consultants working for DEFRA say that incineration makes no significant difference to dioxin pollution in the environment. Is this true?

A8. British Society for Ecological Medicine estimated the number of people who would reach the daily intake guideline intakes if all the dioxins from a 400,000 tonnes per year incinerator were consumed by them. For air emission the number would between 2 and 3 million, for ash it would be 180 million.

That's a lot of people and a lot of toxicity being produced every day 24 hours 365 days a year! Obviously not all the dioxin would be consumed but as dioxins do not break down easily they would continue to contaminate the vegetation indefinitely affecting the food supply for generations.

And that's not all. The US Environment Protection Agency's virtually safe daily dose is 500 times lower than the WHO guidelines so the above figures are VERY conservative. Even more importantly, sections of the population are already exceeding the WHO daily limits for dioxins. Let's also remember that during a critical period of development the foetus is exquisitely sensitive to hormone fluctuations of a few parts per trillion and yet dioxins are already found in their serum at just this concentration." (#2)

Even the tiniest increase in some toxins is significant indeed. 　In any case their estimations of emissions can be very inaccurate. Constant sampling has shown they are underestimating by a factor of anywhere between 5 and 50 times. (#7) No facilities in the UK have constant sampling at present.

Furthermore according to the US EPA: “Fugitive emissions and accidental spills may release as much or more toxic material to the environment than direct emissions from incomplete waste incineration...” There is also the risk of catastrophic waste releases in fires and explosions. Incinerator ash is hazardous waste." (A strategy for a toxic free America - Greenpeace)

But can accidents really happen?

Yes on Sunday 2 January 2005 in El Dorado, Arkansas there was a fire at a waste incinerator. It required the evacuation of 1,500 people living within a few miles of the plant.This accident comes hot on the heels of an explosion at another hazardous waste incinerator in Argentina (Campana, Argentina, 18 November 2004). The accident was so serious that one operator died in the blast and five firemen were injured by the ensuing fireball. (The Irish Times, PRESS RELEASE - 13 January 2005)

But that couldn't happen in the UK?

Yes it could. In 2004 at Crymlyn Burrows on the Neath/Swansea border, there was a catastrophic fire. The fire contaminated local houses and the beach at the nearby Swansea Bay. The operating company, an arm of the Portuguese HLC , has gone bankrupt owing 40 million pounds, (http://publish.indymedia.org.uk/en/2005/10/326736.html) If not a fire, we had a serious incident in Newcastle associated with disposal of the ashes from Byker incinerator. (#1) .

Q9. We live two miles away from one of the preferred sites. Will I be affected?

A9. If, as the Council says, the chimney is 65m tall, people within a 15 mile radius downwind can be affected. There are possibly more than 500 different contaminants being emitted. We clearly need to raise the question of high exposure zones and to obtain satisfactory answers from the authorities about the level of residents' exposures to emissions. (#8)

CHALLENGE:We ask the Council to explain to us the exposure zones for different substances such as lead, mercury, cadmium, dioxins and furans, PAHs and particulate matter, especially PM2.5 and under.

Q10. What will be the impact on road traffic in the area?

A10. According to the assessment study of 2005 prepared for Veolia (Newhaven) having the incinerator of the same capacity, we could be seeing up to 264 daily movements of HGVs and other vehicles on our already dangerously congested roads compromising the principle of road safety. At peak time, likely to be 09.00 to 10.00, there could be as many as 79 vehicle movements. That is one in every 40 seconds!

But this is only for coping with the 210,000 tonne incinerator. (#9) 　In reality both sites are also considered for MRF (Material Recycling Facility) with its inevitable increase of vehicle movements.

What about the Council’s the other responsibility under the Strategic Planning Authority to deal with waste from all sources including commercial, industrial, construction and demolition which accounts for 89% of the total? Can we be sure that the incinerator capacity will not be expanded to treat commercial and industrial waste?

All this is on top of the already approved construction plan of locating Motorway Service Area adjacent to Junction 2 of the M40, where with car park space for 600 vehicles, 6,000 trips or 12,000 movements can be expected every day! A study for the Federal German Government has revealed that lorries do 63,000 times more damage to the road system than cars do.

Just imagine what impact this would have on your daily life if it all became reality!

CHALLENGE:Does the Council guarantee that the principle of road safety will not be compromised and that there will be no future expansions of the facilities once the present project is completed?

Q11. Then what waste solution do you suggest?

A11. Not one solution, but a selection appropriate to the waste arisings in the area where the solution(s) is/are to be applied. But first we ask the Council to inform us on the following two points so that we can properly participate in public consultation.

• (1)the detailed projections of the County’s household waste and its biodegradable proportion that needs to be diverted from landfill in order to assess the appropriate capacity (size) of the treatment facility


• (2)how they have performed evaluations of alternative technologies including Plasma Gasification and Thermal Gasification because the Council’s use of the term EfW is confusing to the public. We do not understand why Mechanical Biological Treatment/Anaerobic Digestion(MBT/AD) was given such poor score compared with EfW when it has been adopted by other local authorities.

CHALLENGE:How can the Council justify the plan to lock the County’s tax payers into a 25 year contract for a conventional incinerator allowing the operator to import rubbish from outside the County for years?

Where is the flexibility to adapt to changes in regulations, developments in technologies and economics, or anticipated culture change for reduce/reuse/recycle?

Q12. Isn’t the plan for a single incinerator for the whole County the cheapest option?

A12. If you want the cheapest, why not double the size of the incinerator to 460,000 tonnes and import rubbish from far and wide and sell electricity generated to maximize profits? Evaluation must be better than that. There is a reasonable suspicion that the plan may cause harm to our environment and health. The Council is responsible for providing satisfactory answers to the following questions.

CHALLENGE: CHALLENGE: Did the Council carry out proper evaluations of all the alternatives? Did the Council study possible multiple installations of smaller facilities in several locations? Did the Council take into account potentially large health and environmental costs associated with incinerators? (#10)

In the light of several new findings regarding the health effects of airborne particulate matters the Environment and Health Committee of the European Respiratory Society have recently published their concerns on the mismatch between the best scientific evidence and EU policy. (#11)