Memorandum submitted by Mrs Mary Horner
1. I am willing to present oral evidence
to the Committee if that would be helpful, to illustrate the experiences
of the stakeholders deliberately silenced by the work of the Environment
Agency—the effects on the health and well being of the local
population.
INTRODUCTION
2. In 1995 and in 1996 I wrote to you in
respect of the two Inquiries your Committee held into the Impact
of Cement Manufacture. That correspondence was prompted by my
family's health problems associated with near-by Castle Cement,
and the failure of the Environment Agency to stop the harm. Despite
your excellent reports, which were both critical of waste burning
at Clitheroe, due to the local topography and meteorology, nothing
has improved.
SINCE THE
1997 REPORT INTO
IMPACT OF
CEMENT MANUFACTURE
3. Hundreds of thousands of tonnes of hazardous
chemical wastes have been burnt in the two wet kilns. They have
just been shut down, but the third kiln has now been transformed
from burning coal only to 100% waste burning. The dispersion of
emissions from kiln 7 is worse than ever, both from the top of
the stack, the low level stacks, and the fugitive releases. It
is about to be licensed by the Environment Agency to burn 100%
wastes, allegedly in accordance with the EC Waste Incineration
Directive. . .
DEATHS
4. Five out of the dozen of us who objected
strongly to the burning of chemical wastes at Castle Cement 10
years ago have since died of cancer. Others are ill. They, like
myself, objected because we personally experienced at first hand
the odours and the health effects, such as sore throat, wheeziness
etc, when the plumes visibly came through our homes and gardens.
The National Physical Lab scientists in 1995 suffered eye and
throat irritation and asthma attack under Castle Cement's plumes.
The LIDAR machine proved that the plume was NOT visibly grounding
at the time the NPL suffered the same odours and health effects
as residents; the plume was at least 50 metres above the ground
at the time. The NPL scientists proved that the odours were not
sulphur dioxide. The true causes of the odours in the gases have
never been admitted. £5 million was allegedly spent on a
scrubber to remove sulphur dioxide, which was never at a level
to cause the odour. The scrubber was used as an excuse for the
Environment Agency to increase the sulphur content of waste fuels.
Demisters removed the moisture, so that the plume was not visible,
but it appears they are no longer working.
5. Most of those five who have already died
met with the MPs when the Environment Select Committee came to
Clitheroe. They and the rest of us fought for the health and future
of our children and grandchildren. Since 1997 everything has gone
backwards.
Since 1996 and to this day, my family have continued
to leave our home when conditions mean the risk of the undiluted
emissions drifting through our hill top farm. Castle Cement's
own Report (May 1996) showed our sparsely populated hill top suffered
the highest risk. Our next door neighbour has now started chemotherapy
for cancer.
6. We fear for our childrens' future, and
for their childrens' future
The Environment Agency refused to listen to medical
advice 12 years ago:
(a) Dr Irving Spurr at Weardale stood up
at a public meeting in Weardale and said that if they burnt chemical
wastes in cement kilns, there would be:
(a) brain tumours;
(b) Damage to unborn foetuses.
(b) Keith Harrison, ex BP Technical Director,
told a local meeting that toxic metals which are carcinogenic,
in emissions, would cause cancers.
(c) Dr Dick van Steenis prophesised 12 years
ago, that unless toxic waste burning in cement kilns was stopped
there would be a mushrooming of:
(a) cancers in eight to 12 years time;
(b) birth defects;
(c) deaths from heart failure.
7. Dr van Steenis visited the expert toxicologists
in the USA. They gave him the research findings which proved that
waste burning caused a change in particle size, so that the majority
were now less than PM2.5, with an unbelievable increase in surface
area on which the toxic metals were carried deep into the lungs.
Literally dozens of research studies since confirm the increase
in death and disease from waste burning and pollution.
8. Dr Irving-Spurr and Dr van Steenis were
both heavily criticised by those with vested interests.
It is time the UK Government also brought in
the limit on PM 2.5's. A rudimentary analysis of the ages considered
premature in the Obituary column of our local paper, and of the
numbers of children carrying inhalers to local schools would show
just how accurate their knowledge was.
90% of particulates from Tyre burning emissions
at Clitheroe were less than PM2.5, compared to 16% with coal only.
9. This huge change into PM 2.5's and the
huge increase in environmental harm was never evaluated, by the
Environment Agency, nor was the cost to the UK economy from the
National Health Service bill.
10. It is frightening to realise just what
is going on locally—and nationally. MP's must realise that
without a change in behaviour by our Government the health of
our families will not prevail over the greed of foreign owned,
hazardous-waste burning cement businesses, and the weaknesses
of those in responsible positions who succumb to the powerful
lobbying of corporate interests.
11. The Environment Agency have been emasculated.
They are lap-dogs to Central Government. They have no power to
overturn central Government policies, instead they are left to
put on a public display pretending that there is no harm to health
or the environment—to justify the impossible. All they do
is licence the levels of pollution which big industry says it
can profitably reach—repeatedly ignoring the known, and
entirely predictable, health effects.
12. The imminent "decision" by
the Environment Agency in respect of the Waste Incineration Directive
permit for Castle Cement, Clitheroe is a graphic example of the
corruption in the Central Government system. In order to be able
to justify a "YES" decision, apparently already made
by Central Government/DTI, the Environment Agency have:
(a) refused to accept or acknowledge objections
by fax, by e-mail, and by recorded letter, as in my own case.
(b) refused to put decisions out to public
consultation, despite the need to treat them as a "Substantial
Change" eg because of:
(i) the doubling of quantities of animal wastes,
from 55,000 tpa to 97,500 tpa
(ii) the extra quantity—10,000 tonnes
per annum-and toxicity—unevaluated-of BY-PASS DUST. BY-PASS
DUST is purely a result of waste burning, since none is produced
when burning coal only.
(iii) the building of a vessel in which to mix
BY-PASS DUST with water, and leach out phosphates, nitrates, chlorine,
water soluble metals etc, which are then to be disposed of to
a secret destination, later to the public sewer!
(iv) use of 100% waste fuel in kiln 7, with
no need to burn any coal, despite the national average being just
6% waste as fuel.
(c) Ignored the lack of after-burners, an
essential safeguard in the WID.
(d) Refused to accept or investigate complaints
from residents—so there is no response to reports of chemical
odours which in the past have been confirmed as leaks of chemical
wastes—it appears Castle Cement are self regulating, with
no way that they can be investigated only by prior appointment—there
is no safety protection for us at nights, week-ends, bank holidays
etc.
(e) in relation to "AWDF" publicly
claimed the opposite to what Ben Bradshaw, DEFRA Minister, has
confirmed in writing. In reply to my MP, the Minister stated that
"AWDF" does contain Category 1 Specified Risk Material
which are the parts most likely to carry BSE infection and which
are removed by law from all bovine animals over six months old
(brains, spinal cords etc). He also confirmed that AWDF does contain
fallen stock -dead and diseased animals picked up off farms for
incineration. Despite these written admissions at Cabinet level,
the Environment Agency reduced objections to the proposed burning
of animal waste by
(i) assuring the public that "AWDF"
did NOT contain any risk of BSE (from which comes the risk of
vCJD) at the public exhibitions
(ii) assuring the public that AWDF was only
from animals fit for human consumption ie no dead or diseased
stock from farms. This was in order to fulfil Government policy,
the supply contracts between the renderers, Pointons, and Castle
Cement having apparently been agreed before the "trial"
to show it was safe began, according to the DTI web-site.
(f) accepted as valid, the Application to
burn Agricultural Waste Derived Fuel (AWDF), despite the Planning
Permission approval being restricted solely to ANIMAL Waste Derived
Fuel (also AWDF!). (Agricultural waste is to be banned from on
farm burning and burial, so extra incineration capacity will be
needed, which the Government does not appear to have made extra
provision for except—in cement kilns. According to the European
Waste Catalogue, agricultural waste covers plastics, pesticides,
heavy metals etc, as well as animal wastes etc—a much wider
spectrum of wastes than the planning permission allows.)
Latest
13. As I write this, at the end of November
2005, Castle Cement is still officially waiting for a Decision
by the Environment Agency on whether it will be granted a permit
to operate their Clitheroe works under the EC Waste Incineration
Directive. Those MP's who were on the Environment Select Committee
in 1996 may remember that there were two wet kilns burning chemical
wastes, and one more modern one which was not. Despite the severe
criticisms, waste burning in the two wet kilns continued during
the intervening nine years, and have only just stopped this last
month.
14. Meanwhile, the third kiln has been permitted
to burn chemical wastes, then tyres, and recently trialled "AWDF",
variously described as "animal waste derived fuel",
"Agricultural WDF" etc. The decision following the trial
has not yet been released. The "success" was to be measured
without any reference or analysis of the extra phosphates and
nitrogen in animal waste. Apparently burning animal waste for
the high "gate fees" ie disposal charge is only viable
if the phosphates can be extracted part way through the kiln system—hence
the importance of the By-Pass Duct, from which the volatile gases
are extracted, condensed—onto the fine dust particles, then
disposed of as waste dust, which is high in the toxic elements.
This is completely separate and distinct from the dust extracted
at the end of the kiln system-normal cement kiln dust, which is
fed back to the kiln on kiln 7. Phosphates weaken cement.
15. Just like all the previous "trials",
the outcome of the AWDF trial is not in doubt. since it appears
the DTI (Department of Trade and Industry) were involved in a
Press Release dated May 2005, which boasted of a re-use for animal
waste in a contract between Pointons, animal renderers, and Castle
Cement, involving 70,000 tonnes per annum animal waste being burnt
in the cement process. The 6 month "trial" began about
the same time as the DTI Press Release about the contract was
issued!
16. Again, there is little doubt but what
the WID application will be passed: firstly because it was never
advertised, nor put out for consultation, despite it being a Substantial
Change (due to the doubling of both the quantities of AWDF and
Cemfuel applied for, compared to those used and quoted as maximum
in the trials): secondly because the Environment Agency appears
to refuse to acknowledge receipt of objections, both sent by e-mail,
fax, and by recorded letter; thirdly because it appears £millions
are at stake, in the form of Carbon Tax rebates, based on legally
binding agreements between the UK government and cement works
owners in return for the increased burning/disposal of wastes
year on year in cement kilns.
17. Since 1997, it appears that Central
Government have dictated what permits are issued. They, and the
DTI, apparently decide what are granted, not the Environment Agency.
18. It appears this has to happen since
the DTI has, I believe, entered into contracts with the polluters,
upon which £millions are at stake.
19. Indeed, the Government's own "recycling"
targets are based on contractual agreements between Government
and the cement industry. These depend on a year on year increase
in cement kilns being used to "co-incinerate" all manner
of wastes. These arrangements seem independent of whether they
can do so safely or not.
20. The Government was fore-warned of the
major increases in waste disposal, due to many new EC Directives
eg Landfill Directive, ban on on-farm burial of dead and diseased
animals, ban on on-farm burning and burial of agricultural waste
etc etc. The Government's forward planning seems non-existent—beyond
the use of cement kilns.
21. So it was that when a local boy sought
leave for a Judicial Review of the Environment Agency's decision
to permit chemical waste burning in the third kiln at Castle Cement,
Clitheroe, in 1999, he was opposed not only by the Environment
Agency and Castle Cement, but also by Central Government. In fact
not one, but TWO Secretaries of State were represented by barristers
in Court, in addition to those from the Environment Agency and
Castle Cement.
How can this strength of intervention/dictatorship,
at public expense, be justified?
22. The signal was clear—no individual
could afford another Judicial Review of an Environment Agency
decision. To do so would risk exposure to the full costs of all
Interested Parties on losing, as well as one's own—three
paid to the Treasury, one to a global multi-national. What chance
had my son?
23. These tactics illustrate why the UK
Government has not ratified the European "AARHUS CONVENTION",
whereby it should be within any individual's means to be able
to successfully challenge a decision of the state.
24. Perhaps the intervention of TWO SECRETARIES
of STATE, in addition to the Environment Agency, and (Castle Cement,)
sums up the current worth of the Environment Agency.
(a) Health and the cost of ill-health, to
an individual, or to the NHS, are not a consideration, whatever
the evidence.
(b) The Government does not think the Environment
Agency is up to the job . . . at least not up to the job they
are demanding of them—they are treated as lap-dogs to administer
Government Policy.
(c) Central Government is willing to spend
whatever tax payers money it takes, to prevent its reliance on
cement kiln incineration being interfered with.
(d) Central Government threatens to bankrupt
any private individual or firm who risks challenging a decision
and losing in a Court of Law. By fielding any number of Secretaries
of State as Interested Parties, their combined costs could be
awarded against the applicant.
25. It is not a good time to be a conscientious
Inspector in the Environment Agency.
It is not a good time to be a pregnant mother—not
for the foetus or the mother.
It is not a good time to live near a polluting process,
especially a waste burning cement kiln, whatever your current
health status.
It is not a good time to dare to oppose the
State in a Court of law.
It is not a good time to be seen to publicly
expose the apparently criminal actions of the State, in granting
permits under the Waste Incineration Directive to cement kilns
which have inadequate dispersion, have no after-burners, which
cannot meet industry standards on emissions, which apparently
have pre-signed contracts for £millions of Carbon Tax refunds
dependent on increased waste disposal. Please, help us, and the
conscientious ones in the Environment Agency.
Mrs Mary Horner
December 2005
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