Inadequate Monitoring at Allerton Incinerator
AmeyCespa claim to be following Environment Agency emission monitoring standards. However, these guidelines are inadequate.
Why is monitoring of emissions of waste incinerators conducted by spot checks rather than continuously? What is the effect of the operator getting advance notice? Why accept a system in which the high emissions that can occur during a period of poor operation can be missed simply because of spot checks only?
Is it acceptable that infrequent monitoring means that the operator and the public might never find out about unintended periods of high emissions and then steps would never be taken to deal with the consequences?
Unannounced visits are necessary. Levels of emissions achieved under test conditions or when inspections occur by prior arrangements are likely to be far lower than under real life conditions. The US Environmental Protection Agency and Occupational Safety and Health Administration conducted 62 unannounced visits and no less than 69% of inspections led to summons for violations of regulations (In the UK inspections are by prior arrangement).
Monitoring data can be misleading about the risks involved. Our concerns include the quality and nature of monitoring covering the way that it is done (too infrequently, as with dioxins and heavy metals, no checking of start-ups and shut-downs, few unannounced checks), too few compounds monitored with some of the most serious hazards (e.g. ultrafine particles PM2.5 and smaller) not measured at all.
The levels of pollutants deemed acceptable are too high – some health risks have no lower threshold or have low-dose toxicity – while some pollutants are bio-accumulative. This occurs when the rate of discharge of pollutants into the environment exceeds the ability of the ecosystems to break them down and many do not break down for centuries
There is a lack of monitoring of body burdens in the local population or the build-up of pollutants in the locality. There should be regular monitoring of dioxins in cattle and other farm animals, together with checks for pollutants in dust, vegetation and in the bodies of local inhabitants.
Only a tiny fraction of the hundreds of chemicals released from an incinerator are measured. Important pollutants like dioxins, heavy metals and PM2.5 particulates are virtually unmonitored. Usually, only half a dozen pollutants are measured continuously in the stack and about another half dozen are measured occasionally (usually 6 monthly for the first year and then yearly) by spot monitoring – these include heavy metals and dioxins. Accidental by-passing of pollution control devices by incinerators put people living in the vicinity of incinerators at risk.
Would you really trust monitoring that can miss the dangers it does measure and omits to measure significant risks? Why expect your fellow citizens to accept them?