#Trafford campaigners challenge Environment Agency – Environment Agency responds.

We got this press release below from BCAG.  We asked the Environment Agency for a comment and they got back to us very swiftly indeed.  That response is below the BCAG one.

BCAG Press release

Trafford-based Breathe Clean Air Group has challenged the Environment
Agency over a serious irregularity in issuing the controversial Barton
Renewable Energy Plant in Greater Manchester, with an Environmental
Permit.

Group Chairman Pete Kilvert has written to Secretary of State for
Communities and Local Government, Eric Pickles claiming that the
Environment Agency has clearly flouted the law and this should be taken
up with higher authorities.

The Barton Renewable Energy Plant is still awaiting planning permission,
but two weeks before a Public Inquiry last November, the Environment
Agency issued an Environmental Permit. “Not only did the timing of
the permit go against us” said Mr Kilvert, “but certain facts about the
danger of the incinerator were not revealed. One crucial fact that was not
revealed was that the Environment Agency failed to notice, when looking
at Peel Energy’s plans, that the nearest people to be affected by emissions
from the plant lived on Wilfred Street, not Tindall Street, Peel Green”.

The Breathe Clean Air Group says that Wilfred Street will receive 2 per
cent extra nitrogen dioxide from the plant, and they are already well over
the limit for this toxic and irritant gas, because of their proximity to the
M60 motorway.

Mr Kilvert has urged Mr Pickles, who will make the final decision about
the Davyhulme biomass incinerator by mid May, that he should not allow
it to be built. The campaign group has also planned to visit Parliament
next month to stress to MPs, the dangers of burning biomass. “We are not
opposed to alternative energy” added Mr Kilvert, “but biomass should not
be used as it adds to Global Warming and has serious health impacts”.

Environment Agency response (in full)

An Environment Agency Spokesperson said: “We carried out a thorough assessment of the application, and consulted with the Health Protection Agency and Primary Care Trusts amongst others, and we are satisfied that this took into account the impact on the whole of the Air Quality Management Area, including both Tindell Street and Wilfred Road.

“We set strict conditions within the permit to ensure that local people and the environment are protected.  We appreciate that some local people have ongoing concerns about the potential impact from the site. We would like to reassure the local community that if the facility does go ahead we will ensure that it adheres to these strict standards and will monitor it closely to make sure the conditions of the permit are met.”

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1 Response to #Trafford campaigners challenge Environment Agency – Environment Agency responds.

  1. Here is part of the Health Protection Agency’s (HPA) letter to Trafford Council’s planning department. I could forward you the complete planning officers letter to the council allowing permission for the incinerator, with my comments, I sent back to the planning department. The HPA accepts there will be adverse affects on human health but consider it negligible, we should be reducing any impacts on human health:
    Health Protection Agency (HPA)
    This response focuses on public health issues relating to emissions of chemicals from the facility. The scope of this response does not extend to wider health issues, such as the potential impact in terms of noise, which fall under the remit of other stakeholders. The advice offered by the Health Protection Agency is impartial and independent.

    Energy from Waste Facilities (EfW)
    Typically, emissions from a well-managed and well-regulated biomass incinerator should pose little risk to the health of local residents. As we understand the Regulations, because Barton Biomass incinerator will be mainly burning waste wood (as well as a small amount of virgin biomass material) it will come under the Waste Incineration Directive. Therefore, we expect the same strict emission limits to apply as they do to any new waste incinerator and there will be no significant difference in the generality of its emissions compared to other modern incinerators. The HPA has reviewed the evidence on incinerators and health and has published a Position Statement on the health risks from incinerators.

    The Position Statement contains the HPA’s independent expert advice based on reviews of peer reviewed research on the heath impacts of emissions from incinerators and also takes into account the views of the Expert Advisory Committees. The HPA’s view is that typically, a well-managed and well-regulated energy from waste facility presents little risk to local residents. The HPA’s statement concludes:
    ‘Modern, well managed incinerators make only a small contribution to local concentrations of air pollutants. It is possible that such small additions could have an impact on health but such effects, if they exist, are likely to be very small and not detectable. The Agency, not least through its role in advising Primary Care Trusts and Local Health Boards, will continue to work with regulators to ensure that incinerators do not contribute significantly to ill health.’

    It is assumed by the Health Protection Agency that the installation will comply in all respects with the requirements of the following domestic and European legislation:
    Environmental Permitting Regulations 2010
    Waste Incineration (England and Wales) Regulations 2002
    Groundwater regulations 1998 and the European Groundwater directive (80/68/EEC)
    European air quality framework directive (96/62/EC) and daughter directives.
    Compliance with the legislation listed above, together with good management and regulation should ensure that activities conducted by this installation present a low risk to the local population.

    It is expected that the regulator for the site (Environment Agency) will adequately monitor the installation and that they will ensure that any failures in plant or management procedures do not result in the release of substances which could adversely impact on public health.

    Point Source Emissions from Air
    We note that the applicant proposes the use of a stack of 44.23 metres in height which is based on a requirement that no structure should be greater than 45 metres within the vicinity of an aerodrome (Barton Aerodrome, Salford). The applicant has undertaken detailed dispersion modelling of stack emissions using ADMS (version 4.2). It is not the role of the HPA to check these calculations and predictions and we have assumed that the predicted levels of emissions are correct.

    The applicant has modelled predicted concentrations of nitrogen dioxide, sulphur dioxide, particulate matter, carbon monoxide, acid gases, volatile organic compounds, heavy metals and dioxins and furans. Calculations presented show that the contributions are considered to be insignificant as predicted levels of all the considered pollutants are well below relevant UK Air Quality Strategy (AQS) standards and objectives or Environmental Assessment Limits (EALs).

    With the exception of nitrogen dioxide emissions, which are considered separately below, we are also reassured to see that modelled pollutant emissions when added to background air concentrations do not exceed relevant AQS objectives. We would expect that any issues of potential fugitive emissions, including any differences to predicted levels during plant start–up and shut-down, would be addressed within the Environmental Permit.

    However, we note the proposed facility is situated close to an Air Quality Management Area (AQMA) – determined on nitrogen dioxide levels – and despite emissions of nitrogen dioxide levels being extremely low they will inevitably add to the existing high levels. Diffusion tube data indicates background levels are particularly high, and above the AQS objective in the northern part of the AQMA. We understand that the responsibility for assessing such impacts rest with the Local Authority and so we do not intend to comment further on this specific issue.

    Human Health Risk Assessment

    Additional detailed health risk assessments were also conducted for dioxins, identified contaminants of concern and particulate matter.

    The Industrial Risk Assessment Program-Human Health (IRAP-h version 4) which is based on the United States Environment Protection Agency (US EPA) Human Health Risk Assessment Protocol has been used to calculate the transport and fate of trace contaminants emitted in the stack exhaust gases. The Contaminants of Potential Concern (COPC) were identified as Group 1, 2 and 3 metals (i.e. mercury, cadmium, thallium, antimony, arsenic, cadmium, chromium, lead, and nickel), dioxins and furans. Additionally though not identified as COPC in paragraph 12.149 of the planning application, benzo(a)pyrene is identified as a COPC in table 12.25 and we therefore assume it has also been considered in the calculations.

    The methodology by which human health risk from COPC has been carried out uses a mixture of approaches including total cancer risk probability and Hazard Quotients (paragraphs 12.167 – 12.174).

    In terms of cancer risk estimation, the Heath Protection Agency considers that actual accuracy of such predictions cannot be assessed and that such extrapolations still involve some considerable uncertainty and should be used with caution. However, for the purposes of this assessment, we consider this represents a conservative approach to estimate potential risks and so is considered to be an acceptable approach in this instance.

    Also an acceptable risk level of 1 in 100,000 has been used by the applicant. We assume this refers to an excess lifetime cancer risk, not an annual risk and we would ask the Local Authority to confirm this with the applicant.

    Dioxin Risk Assessment
    The level of exposure to metals, dioxins and furans emitted from the proposed facility has been quantified at selected sensitive receptors within the vicinity of the site.

    In residential locations, the key exposure pathway is through the ingestion of soils and home-grown produce although it is noted that the ingestion of eggs from home-reared birds has only been applied to farms/allotments, but not to residential premises. The Local Authority should ensure that they are satisfied that consumption of eggs from home reared chickens at nearby residential gardens is unlikely. If there is a potential for this, then this pathway should additionally be considered in the risk assessment.

    On agricultural premises, potential exposure through the ingestion of above and below ground produce, and as a result ingestion of beef, milk, pork, poultry and eggs produced in farms within the vicinity of the site, has been included, as appropriate. The relevant pathways of exposure were identified as: inhalation; ingestion of soil; ingestion of home-grown food; ingestion of eggs from home-grown chickens; ingestion of home-grown chicken, beef and pork produced and used at local receptor farms and schools and breast milk.

    Based on the risk assessment in paragraph 12.175, the predicted highest intake of dioxin and furans is at an adult receptor at the allotments off Tindall Street (0.43fg ITEQ/kg bodyweight/day), but this is only 0.02 percent of the Tolerable Daily Intake (TDI) of 2 pg ITEQ/kg bodyweight/day recommended by the UK Committee on Toxicity. The HPA agrees that this can be considered as an insignificant contribution to the current background daily intake of dioxins, which arises from other sources, but mainly from the diet.

    However, dioxins are also considered separately in the cancer risk assessment (figures 12.12 and 12.13), despite the UK position that a TDI approach is appropriate.

    We would ask the Local Authority to confirm with the applicant that an alternative hazard quotient approach for dioxins would not materially affect the conclusions of the overall risk assessment for thresholded contaminants. From the statement in paragraph 12.175, which predicts a very small intake compared to the TDI, we assume that this would be the case.

    Other Contaminants of Potential Concern (COPC)
    Of the other COPC, specific reference is made only to arsenic (paragraph 12.173). The estimated exposure of adults and children to these contaminants does not indicate a significant risk to health.

    Overall we agree with the conclusion that “it is highly unlikely that exposure to emissions from the facility will lead to an adverse impact on health” (paragraph 12.174).

    Impact on Overall Air Quality – particulates
    Emissions modelling:
    Detailed flue emissions dispersion modelling using the advanced computer software model ADMS version 4.2 was conducted. The highest peak concentration of PM2.5 is predicted to be 0.08 µg m-3, while the worst case concentration at any local receptor is predicted to 0.026 µg m-3 (nearest dwelling on Tindall Street). The peak concentration is 0.3 percent of the relevant AQS objective (25 µg m-3) and is considered by the applicant to be an “insignificant contribution” (paragraphs 12.119 -12.122). Likewise the predicted contribution for PM10 particulates to ambient levels is also considered to be an “insignificant contribution” (paragraphs 12.116 -12.118).

    We would agree with both these conclusions.

    COMEAP approaches to risk assessment:
    With reference to the potential health effects of particulates the applicant has also presented estimates of potential impacts on human health using numerical values from the work of the Department of Health Committee on the Medical Effects of Air Pollutants (COMEAP). The population assessed by the applicant were the populations of Davyhulme West, Davyhulme East, Barton, Irlam and Winton. For PM2.5 , the COMEAP assumes that there is no threshold for health effects of particulate exposure and that the exposure coefficients developed by COMEAP for PM2.5 assume that the all-cause mortality rate increases by 6% for every 10 µg/m3 rise in particulate air concentrations, measured as an annual average concentration.

    However we would point out the COMEAP methodology and the PM2.5 coefficient is concerned with ambient concentrations of particulates and was not intended to be applied to specific individual sources of pollution.

    These coefficients are derived from epidemiological studies and so are likely to be most reliable in predicting the effects of exposure to air pollutants similar to those which were actually studied.  In general, this is the ambient urban air pollutant mix made up of particles emitted from vehicles, from re-suspended road dust and from sources such as power stations that produce secondary pollutants (formed in the atmosphere rather than emitted per se) which drifts across urban areas.  Whether particles emitted from incinerators are more or less toxic than ambient air particulates is another source of uncertainty in applying these coefficients to assess impacts from such point source emissions

    Additionally epidemiological studies from which these coefficients are derived tend to focus on large populations and results are presented without reference to potentially susceptible groups.  Susceptibility to the toxicological effects of ambient air pollution is likely to vary from person to person and, for example, those in generally poor health (more commonly found amongst the elderly than amongst the young) are also likely to be at increased risk.
     
    Given these reservations, paragraphs 12.176 to 12.180 of the planning application are concerned with applying the COMEAP methodology, assuming the combined population for the 5 wards to be 52,878.and the annual death rate for the area to be 9.8 per 1000 population (2009 data). Consequently the total annual number of deaths in the 5 wards is estimated to be approximately 518. However the annual death rate is based on data not specific to these wards and this is another source of uncertainty in this assessment.

    The additional impact on the annual death rate from additional PM2.5 emissions from the plant was calculated using predicted additional levels of PM2.5 in the 5 wards. The application predicts that the particulate emissions from the plant would result in a 0.011% increase in deaths brought forward (paragraph 12.180). This is also expressed as 0.06 deaths brought forward per annum for this population. The applicant considers this impact “would not be noticeable”.

    Given the above caveats, the HPA considers that the calculations need to be interpreted with considerable caution, but indicate that the potential health impact is likely to be very small.

    However the applicant has not provided the detailed calculations of how the figure of 0.011 percent increase in the risk of death and the predicted impact of 0.06 additional deaths brought forward per year was derived and we recommend that the Local Authority requests this information. We would also suggest that these calculations are expressed in other ways (e.g. excess annual and lifetime risks for the population), and with caveats added about their derivation to be sure that misleading interpretations of these figures do not arise.

    Conclusion of Human Health Risk
    Providing the incinerator complies with relevant regulations, the human health risk assessment suggests that the risks to human health from emissions from this proposed development are negligible. The assessment demonstrates that the maximally exposed individual is not subject to a significant carcinogenic or non-carcinogenic risk, arising from exposures via both inhalation and the ingestion of locally produced foods.

    If the releases are no larger than those indicated in the planning application, then, as in our comments on the emissions and health assessment data, we consider that they will make a very small contribution to overall air quality, and any potential health effect is considered by the HPA to be exceedingly low. It is worth repeating an extract from the HPA’s position statement about the impacts on air quality from modern well-run incinerators which is also provided in section 4 above:
    “It is possible that such small additions could have an impact on health but such effects, if they exist, are likely to be very small and not detectable.”

    The Health Protection Agency advises the Local Authority to ensure that consumption of eggs from home reared chickens at nearby residential gardens is unlikely. If there is a potential for this, then the applicant should be required to consider this pathway in the risk assessment.

    In addition we would also advise that the Local Authority confirms that the calculations in terms of number of deaths bought forward are made explicit and that the conclusion is more clearly caveated to avoid misunderstandings.

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