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Executive Committee Chairman Sir Kenneth Green Kt; BA; MA; DLitt; CIMgt Vice Chairman Mr Jeff Meehan HNC Elect Eng; End Electronics/Computing Secretary Mrs Sue Bowden (Local Government Officer) Treasurer Mr Alan Gory (Company Director (Retired)) Committee Members Dr John Beacham CBE; DSc; FRSC Dr Simon La Frenais MB; ChB; DObstRcog Mrs Debbie Middleton JP Mr Mike Stackpool MSc; Cphys; MIinstP Advisers Professor John S. Dearden BSc; MSc; PhD; ACGI; MRPhrmS Mrs Susan Smith BSc. Hons. MInstP. CPhys.

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Index

Health Impact Assessment

Page Health Impact Assessment Overview 3 Response to Health Impact Assessment from QSTAR Consulting 7 Comments on the HIA 21 HIA - Outstanding issues to be addressed 37

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Health Impact Assessment Overview

1. INTRODUCTION In our “Comments in relation to the HIA to be undertaken by RPS”, we expressed our concern that, in view of the RPS’s past and present client relationship with Ineos, this could not be regarded as an “independent” HIA as identified by the Secretary of State in his letter dated16 September 2008, and further where he acknowledged that there is “concern over the impact on health in the locality, and is satisfied that such concerns can be addressed in the Environmental Permitting process” (Para 3.5a). This was compounded by issues arising out of the original EIS and HHRA, in which omissions and errors leave the impression that they were largely desktop predictions demonstrating little local or empirical knowledge. Thus, the EIS erroneously claimed that there were no ponds or newts on the site, no Japanese Knotweed and no residential properties close to the railway line. As an example, the Environmental Protection Act 1990 classes Japanese Knotweed as ‘controlled waste’ which must be disposed of safely at a licensed landfill site according to the Environmental Protection Act (Duty of Care) Regulations 1991. Soil containing knotweed roots can be regarded as contaminated and, if taken off a site, must be disposed of at a suitably licensed landfill site and buried to a depth of at least 5m. Newts (the great crested variety) are a protected species, and as such, there is a legal requirement to prevent disturbance to the newts’ habitat, arising from the Habitats Directive. These considerations will be dealt with in more detail in the other part of HAGATI’s response to Ineos Chlor Limited’s Application. These, together with errors in the HHRA, were identified by HAGATI. There remain other unresolved issues relating to the original EIS and HHRA, which caused us to be concerned that the proposed HIA would be based on less than sound foundations. In the event, we regard the HIA as not fit for purpose, and set out our reasoning below.

2. EXISTING BURDEN OF HEALTH Designated as a ‘Spearhead’ area, (placing it in the bottom fifth nationally for life expectancy, common causes for death and deprivation), the Borough of Halton has a dreadful health record with exceptionally high rates of cancers, coronary heart disease, circulatory disease, strokes, suicides and infant mortality. The Standardised Mortality Rate (SMR) for Halton is already 23% above the national average. It has the highest early death rate from cancers in the UK, and a higher prevalence of asthma compared with national rates. Compared with national averages, people in Halton are 24% more likely to die from cancers, 39% from coronary heart disease and 21% as a result of an accident. Two recent papers (Hodgsen et al.) highlighted the excess risk of kidney mortality and morbidity in Runcorn that already exists in the population living closest to the site. Within the last ten years, residents of Weston and Weston Point were subjected to frightening health scares in relation to toxicity from HCBD leakage from industrial waste dumped in Weston Quarry. This resulted in the demolition of houses, the rehousing of tenants, and the identification of the land as heavily polluted, fit only for landscaping. Overall, the study suggested that there was an effect on kidney function, which improved when subjects moved house. This densely populated deprived area must be one of the worst possible locations for an Energy from Waste Incinerator.

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The HIA (pages 27-29) purports to present a picture of the existing burden of health, principally in a number of tables with commentary. However, their format is varied and inconsistent, and, regarding certain illnesses, data has been entirely omitted for no obvious reasons. In particular:

i. The time frames vary from 20 years to 1 year, making relevant comparisons or correlations impossible, and therefore raising doubts as to their validity in making any judgements about the exercise;

ii. The formats differ. Tables 3.2, 3.4, 3.5, 3.9, 3.10, 3.11, 3.13, 3.14 and 3.15 present stated comparisons between Halton, the North West and England. Table 3.5 compares individual wards within the North West and England, Table 3.7 wards England only, Table 3.8 wards only, Table 3.12 and 3.4 wards with Halton and the St Helens PCT. No rationale is apparent for these variations and the overall impression is of the amalgamation of available statistics without a coherent rationale, thereby raising issues of soundness;

iii. It is claimed that the average life expectancy for both males and females is “steadily improving”. However, Tables 3.4, 3.5 and 3.9 clearly show that the gap between Halton and England is increasing, and that 15 of the 21 wards have lower life expectancy than national norms (Table 3.6). Paragraph 3.17 claims that “Halton exhibits a significant range of all cause mortality rates compared with national trends” but Table 3.8 shows that SMR’s for 15 of the 21 wards are above the national average;

iv. Though we are told that “heart disease remains the biggest cause of death” we are given no figures at ward, Halton and national levels, or for bronchitis, asthma or respiratory diseases. Nor is there any reference to kidney disease, which previous studies have confirmed to be prevalent in the area.

v. Page 24 states that “There is also a statistically higher rate of colorectal cancer

registrations for women in Halton” but does not comment on the fact that the figures for males is actually higher. The rates for Table 3.10 SSR’s for colorectal cancers 2002 tells us that the respective figures are:

Cancer Registrations England Northwest Halton Borough Males 100 107 117

Colorectal Cancer Females 100 99 103 The HIA deals with mortality but not with morbidity, which is surely a more reliable indicator of the prevalence of illness, and one that matches the perceptions of members of the local community. Therefore, it is not clear, overall, what the information presented is intended to indicate, and in particular why information relating to wards is included at all. It is possible to argue that this is intended to lend substance to the assertion that Halton “exhibits a significant range lower and higher than the national trends” (whatever that means) and the recurring assertion that the said illness “is most closely associated with life style and relative economic deprivation” (by whom, why or with what authority is unstated). Thus, it is interesting to note that, in relation to All Cause Mortality (Table 3.7) Heath Ward,

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which by no stretch of the imagination could be classed as an area where life style or deprivation are issues, has the eighth highest mortality rate in the Borough, 76% higher than the national average. Similarly though Halton has one of the highest cancer rates in the UK, it is noteworthy that it is ranked ‘Average‘ in comparison with the levels of smoking and obesity nationally. Further, Halton and St Helens PCT Cancer Health Equality Audit 2008 highlights the fact that Halton’s “under 75, all cancer all persons mortality” figure ranks first of the 354 local authorities, i.e. the worst in the country. The Audit also states that the relationship between both incidence and mortality with deprivation amongst the under 75’s is less clear, with only weak, slightly positive correlations overall (Page 14 paras 1, 2, 3). This is quite contrary to the assertions made by RPS in the HIA that the existing burden of ill health is attributable to ‘socio-economic factors’, ’lifestyle’ or ‘relative deprivation’ and not consistent with broad environmental factors. The Audit also reveals that the third most common cancer for males across the whole PCT, as well as for Runcorn, is malignant neoplasm of the colon, whereas in Widnes the third most common cancer is malignant neoplasm of the bladder (Pages 108 – 109 paras 8.1.1 to 8.1.3). Bladder cancers are associated with a number of chemicals, and it is not unreasonable to suggest that occupational and environmental factors were important aetiological factors in this instance. It is not a question of dismissing economic deprivation and lifestyle as factors affecting health. Rather, it is to recognise that there are grounds to believe that broad environmental factors make a significant contribution to Halton’s appalling health record. The Lancaster University report (2003) ‘Understanding the Factors Affecting Health in Halton’ provided a more balanced view, addressing environmental factors as well as deprivation and lifestyle. It confirmed that epidemiological studies demonstrated an association between particulate air pollution and adverse health in susceptible parts of the population (particularly the elderly with respiratory or cardiovascular disease). Various health and developmental effects have been linked to the level of PCB’s and dioxins that infants receive from their mothers whilst in the womb, and this can be seen very clearly in the recent Corby litigation (where the Court’s judgment was that the claimant children’s birth defects could be caused by their pregnant mothers’ inhalation of even the smallest amount of dust containing pollution from the old British Steel works at Corby). Childhood leukaemia and some cancers have been linked to environmental hazards. HAGATI drew to RPS’s attention to a number of papers that showed increased infant mortality rates downwind of incinerators. We believe that these are important findings that warrant further analysis. Existing studies of infant mortality rates around incinerators have not so far combined a review of socio-economic and wind effects as well as looking at morbidity and all mortality. In 2006 a highly respected critical review of over five hundred papers relating to the health effects of fine particulates concluded that there was persuasive evidence that exposure to fine particulates has adverse effects on cardio pulmonary health. The World Health Organisation also concluded that fine particulate air pollution has a strong effect on mortality, and that there is no safe threshold below which fine and ultra-fine particulates have no effect on health. The recent Health Impact Assessment for the Mersey Gateway Project (carried out by ERM) reached similar conclusions.

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A DEFRA report (2003), concerning deformities found in herons at a site in Nottinghamshire, identified dioxin contamination at two heronries in Runcorn, with five times higher TEQ than that at the Nottinghamshire site. The “Toxic Equivalent” (TEQ) scheme weighs the toxicity of compounds less toxic than arsenic (which is taken as the base level measurement) as fractions of the toxicity of the most toxic TCDD. Each compound is attributed a specific “Toxic Equivalency Factor” (TEF). This factor indicates the degree of toxicity compared to 2,3,7,8 TCDD (tetrachlorodibenzodioxin), which is given a reference value of 1. The source of this dioxin has still not been identified in the Halton area. In the original planning application from Ineos the fly ash and Flue Gas Residues (FGR) were to be transported to Randle Island by lorry. The local Primary Care Trust expressed concern and Ineos, at the Council meeting where this was discussed, stated that they had now decided to convert the fly ash to ‘wet cake’ before leaving the site. This treatment could be the cause of other problems. At the incinerator itself the ash is obviously still hot when it exits, damping it down to form the wet cake could have the effect of cooling the surface to form a crust but leave the centre still hot. On arrival at Randle Island the wet cake could rapidly dry out resulting in the toxic materials being liberated as dust. We have seen no amendment to the original planning application to cater for the facility at the incinerator that turns the ash into wet cake so it is reasonable to ask questions such as, what happens to any surplus water that is added, does it run off into the drainage system directly? The same concern exists at Randle Island in that any water added to the wet cake, either artificially or by rain for example, should be classed as leachate and as such need to be collected and treated and certainly not allowed to find its way into the River Mersey or the Ship Canal. We believe that there are studies relating to ill health and the proximity of toxic waste sites, yet there is no mention of Randle Island in the HIA, or to the substantial numbers of sheep and cattle that graze on the nearby Frodsham Score and thereby provide a link to the human food chain. A major source of concern has been noise caused by trains on the Folly Lane rail link running parallel to homes on Picow Farm Road and Percival Lane and consequent sleep deprivation. Page 75 para 7.25 of the Application states ‘The use of independent axles and pivoting bogies on all RDF wagons in conjunction with strict day and nighttime restrictions are anticipated to be sufficient to reduce community annoyance and sleep disturbance.' So there will be sleep disturbance, but we are not told what these ‘strict day and nighttime restrictions are’ are, nor are we able to assess the extent to which ‘The use of independent axles and pivoting bogies’ will reduce the said noise (Para 7.25). Further, it conflicts with the Secretary of State’s letter dated 16 September 2008 granting planning permission, which included the phrase ‘So far as reasonably practicable the transport of RDF to the site shall not take place between 23:00 and 07:00 hours’ We believe, therefore, that these and other issues identified in Professor Dearden’s report need to be addressed, and that, as recommended in the Lancaster Report, by the Committee on Medical Effects of Air Pollutants and by the PCT, the Precautionary Principle should be applied. Since, for the reasons identified above, the RPS HIA is not fit for purpose, we cannot see how the Environment Agency can use it as the basis for appraisal and decision.

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Response to Health Impact Assessment (HIA) by RPS for Ineos Chlor dated October 2009

Professor J. C. Dearden, QSTAR Consulting The previous Human Health Risk Assessment prepared by RPS for Ineos Chlor contained numerous errors and omissions. The present Health Impact Assessment (HIA) also contains inconsistencies and mistakes that have serious implications for the determination of the permit application. References to Paragraph and Table numbers are to relevant parts of the HIA.

1. Clarity There are no graphs of ward rates of hospital admissions or mortality versus index of multiple deprivation, which would have shown very clearly whether wards closer to polluting industries showed higher than expected morbidity/mortality. Table 3.12 gives data for circulatory diseases hospital admissions for all 21 Halton wards, whereas Table 3.15, (entitled “Emergency hospital admissions for children with lower respiratory tract infections”), gives no ward data at all, but simply a comparison of Halton with England and the North-West. There appears to be an error in this table, since the first column heading says that the figures given relate to mortality rates. Para. 3.29 states that the biggest single cause of premature death in Halton is heart disease, but no figures are given to substantiate this assertion. It would have been useful to have figures for other causes, and to have figures for England, the North-West, and for individual Halton wards, otherwise comparisons are impossible. In Table 3.16, no comparison with England is given. Heath is a prosperous ward (compared with, say, Castlefields), and this is shown by the average life expectancy (Heath 80.2 years, Castlefields 74.1 years) and the standardised mortality ratios (SMRs): Heath 85, Castlefields 135. However, there is an anomaly, which the HIA has failed to comment on - Table 3.7 gives the all age all cause mortality rates as: Heath 1075, Castlefields 970. This surely cannot be explained by socio-economic factors, and may reflect the fact that Heath ward is close to heavy chemical industry. It is believed that Halton is not the borough with the highest smoking rate nationally, and yet it is the borough with the highest national lung cancer rate. Since smoking is generally acknowledged to be the prime cause of lung cancer, this suggests that some other cause (industrial pollution?) is contributing to lung cancer in Halton. The HIA should have commented on this. In para. 2.19 states that “it is expected that a proportion of freight (train) movements will be at night”. It is my understanding that planning approval for the Ineos Chlor incinerator specified that there were to be no night-time train movements, so there is a discrepancy that the HIA should have dealt with.

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In para. 2.24, it is stated that “bottom ash will be suitable for use in building materials, road aggregates etc”. However, it now seems likely that the Environment Agency will classify incinerator bottom ash (IBA) as hazardous waste, in which case it will have to go to landfill. Since there would be a large amount of IBA from the Ineos Chlor incinerator (approximately 205,000 tonnes per year) this raises two questions:

(a) Can Ineos Chlor afford the vastly increased cost of landfilling IBA (perhaps £70 per tonne)?

(b) Has the Randle Island Landfill Site the capacity to take that quantity of waste?

In RPS’s previous Human Health Risk Assessment, modelling predictions were made for increased mortality from the proposed Ineos Chlor incinerator, at a number of sensitive receptors. The data provided were readily understandable, although the HHRA used an incorrect lifetime acceptable mortality rate of 1 in 100,000 instead of 1 in 1 million. The only mortality data provided in the recent HIA are for the effects of PM10 and PM2.5 particulates, and the presentation of those data in Appendix D is unclear. One can assume, although it is not certain, that the figures given relate to increases in the standardised mortality rate, so that, for example, for Super Output Area 010B (no name given) a figure of 1.04 x 10-4 in the contour range 0.016-0.024 exposure to PM10 means that the predicted effect of the incinerator would be to increase the standardised mortality rate from 1531 to 1531.000104. These figures are useless without similar figures for all other incinerator-emitted pollutants, or at least overall figures for all pollutants. It may be noted here that Roberts and Chen [2006] found that the greatest mortality risk from incinerator emissions came from cadmium (vide infra Section 3). Recommendation: (1) that mortality data are provided in the same format as in the original HHRA, for the original sensitive receptors plus additional ones in Frodsham and Helsby. These should be either overall mortality data (including the effects of cadmium, as highlighted by Roberts and Chen [2006]) or as mortality data for a range of the most important individual pollutants. (2) that the presentation of data is standardised and is consistent across tables, so that meaningful comparisons can be made.

2. Total Dust There is a minor error in Appendix C, where it is stated that one class of pollutants is “Total Dust (including PM10 that constitutes the PM2.5 fraction)”. That designation is incorrect. The PM2.5 fraction is that fraction that passes through a 2.5 micron (µm) sieve and it constitutes part of the PM10 fraction. Recommendation: that the above class of pollutants should read “Total Dust (including PM2.5 that constitutes part of the PM10 fraction)”.

3. Cancer In Appendix C, several sources are quoted to support RPS’s contention that there is little or no convincing evidence that incinerator gaseous emissions lead to cancer. The problem is that such studies fail to consider the 360º distribution of cancers around incinerators. Almost

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all locations have a non-uniform distribution of wind directions, which means that some areas will be largely downwind of an incinerator, and some areas will be largely upwind. Clearly those that are largely downwind will receive much more pollution than will those that are largely upwind. If wind direction is ignored, then the average effect of the pollution will be much less, and may even be statistically insignificant. The wind-rose for Ellesmere Port, shown below, illustrates the point:

0

100

200

300

400

500

600

700

800

900

515

25

35

45

55

65

75

85

95

105

115

125

135

145

155

165175195

205

215

225

235

245

255

265

275

285

295

305

315

325

335

345355

1999

1998

1997

2000

2001

N

S

W

E

It can be seen that the majority of directions receive little or no wind. The main winds come from the WNW and just E of S, each encompassing a sector of about 60º, which together is 1/3 of the total 360º. Suppose, for the sake of argument (and exaggerating numbers to illustrate the effect), that the cancer risk in that sector is twice that of the remaining 300º because of emissions from an incinerator, e.g. 1:100. If this was compared directly with the 1:200 for the rest of the residents who are relatively unaffected the difference would be obvious. However if all the residents risks are considered in total (1:100 + 1:200 + 1:200) = 1.33:100. So although the downwind residents are at twice the risk than those upwind by considering everyone in the circle, this statistic is masked. If now we consider the (thankfully very low) statistical occurrence of infant mortality with a frequency in single figures per thousand of births, it can be appreciated why the conclusion that there is no measurable effect is arrived at. One of the main studies on which DEFRA and others have relied for their assertion that the cancer risk from incinerators is negligible is that of Elliott et al. [1996]. They nevertheless reported a 37% excess incidence of liver cancer for people living within 1km of an

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incinerator, but put this down to possible misdiagnosis and residual confounding. The Elliott et al. paper is thus fatally flawed, as are all others that have not taken account of wind direction. It may be noted that Professor Jim Bridges, in his Proof of Evidence on behalf of Peel at the Public Inquiry on the proposed Ince incinerator in 2008, said ”One of the best conducted studies on possible adult cancer risks was that of Elliott et al. [1996]”. When Professor Bridges was challenged on the flaws in the Elliott paper, his reply was that it was not his job to analyse such papers. However, in essence it was his job, as an expert witness, to assess the validity of publications with which he was supporting his case. This casts doubt on the value of expert witnesses on health in connection with planning applications for waste incinerators. A recent paper by Roberts and Chen [2006] has derived a quantitative measure of risk from a modern waste incinerator, based on current allowed emission levels. The authors calculate that the overall risk of dying in any one year from incinerator emissions is 2.49x10-7. Interestingly, they found that the main contributors to that risk were cadmium (72%), dioxins (17%), arsenic (10%) and polyaromatic hydrocarbons (1%). The risk of dying from incinerator emissions over the 25-year operating life of an incinerator is 25 times the annual risk, or 6.23 x 10-6, and the 70-year lifetime risk is 1.74 x 10-5. Both of these values are well above the de minimis acceptable lifetime target level of 10-6 (i.e. 1 in a million) used by the U.S. Environmental Protection Agency [Castorina & Woodruff 2003]. It should be noted here that the U.S. E.P.A. target level is for cancer risk alone; however, the four toxins found by Roberts and Chen [2006] to contribute most to mortality from incinerator emissions are all known carcinogens, so the comparison is valid. It appears that RPS has relied largely on Government documentation to claim that incinerators pose little or no cancer or other health risks. There appears to have been no critical examination of the original studies. This is, of course, disappointing in the context of the nature of the permit application. Recommendation: that a critical assessment of the original literature on adverse health effects from incinerators be carried out, in particular to establish which studies (if any) have considered wind direction and confounding effects.

4. Respiratory function and disease The HIA states that “Available studies have typically examined respiratory health around the older generation of incinerators, which were subject to less stringent levels of control than the modern plant regulated under the Waste Incineration Directive (2000). Overall, there is little evidence to suggest that thermal waste treatment facilities are associated with increased prevalence of respiratory symptoms in the surrounding population”. There is, however, a clue in figures quoted in the HIA that is very revealing. It is stated that for every 10 µg.m-3 increase in PM10, there is a 0.75% increased risk of all-cause mortality, whereas for every 10 µg.m-3 increase in PM2.5 there is a 6% increased risk of all-cause mortality. Clearly, the smaller the particulate matter the greater the risk. This is a well known phenomenon, and the reasons are threefold. Firstly, smaller particles can penetrate more deeply into the lung, and cause greater problems. Secondly, a given weight of smaller particles contains many more particles than does the same weight of larger particles. Livingston [2003] has estimated that one pound of very fine particles emitted from an incinerator will consist of 140 quadrillion (1,000,000,000,000,000) particles. Another way of appreciating this is to note that about 26,500 PM2.5s would fit on the dot of the letter ‘i’ in

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normal print; for PM0.001s the figure would be 160 billion. Thirdly, for a given weight concentration, smaller particles have greater surface area. Even assuming sphericity, a given weight of PM0.1s will have 100 times the surface area of the same weight of PM10s; in fact, because of surface roughness, ash particles can have surface areas 20-30 times the surface area of equivalent spheres [Rose et al. 2003]. Howard [2003] cited U.S. E.P.A. figures showing that for typical particulate incinerator emissions 48.8% of the surface area is provided by particles of < 0.7 µm diameter. The significance of this for toxicity is that toxic chemicals such as dioxins and heavy metals can be sorbed on to the surfaces of particulate matter and taken into sensitive areas of the body. Gómez-Moreno et al. [2003] found, for a pilot-scale incinerator, that no particles above 1 µm diameter were emitted. Howard [2003] also quoted figures from Onyx showing that baghouse filter collection efficiency was 95-99% for PM10s, 65-70% for PM2.5s, and only 5-30% for particles smaller than 2.5 µm, even before the filters become coated with lime and activated carbon. Brown et al [2000] have pointed out that long-term exposure to even low concentrations of fine particles may be associated with reduced life expectancy. Very fine particles from incinerators are likely to be highly toxic because of the sorbed chemicals such as dioxins on their surfaces. They therefore probably have much greater toxicity than do very fine particles from other sources.

Cormier et al. [2006] have reviewed the evidence for potential health effects of incinerator particulate emissions. They posed a series of questions that require answers:

1. How are combustion-generated fine PM and ultra-fine PM formed? 2. How do their chemical properties differ from larger PM?

3. What is the nature of association of chemicals with these particles?

4. How is the chemical and biological reactivity of these chemicals changed by

association with the particles?

5. What is the role of PM-associated persistent free radicals in the environmental impacts of fine and ultra-fine PM?

6. What is the role of PM on cell/organ functioning at initial sites of exposure?

7. What is the bioavailability of these particles to other tissues?

8. How are these particles translocated to these secondary sites, and do their

chemical properties change en route?

9. How does acute/chronic exposure lead to adverse organ pathophysiology? Is developmental timing of exposure important?

10. What effect does exposure have on predisposing to disease states or on

disease progression?

11. Most important, what are the specific cellular and molecular mechanisms associated with airborne exposures?

It is clear from the above that medical science has only very recently started to recognise the

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serious problems that particulate emissions can cause, and it will be many years before the answers to the questions posed are available. Meanwhile it is essential that particulate emissions, especially those produced in conjunction with toxic chemicals, are reduced. The HIA argues that the proposed Ineos Chlor incinerator would emit low quantities of particulates, and as a result, it should be stressed here that cumulative effects on health due to continual exposure to environmental pollutants can be very serious even at levels below the national ambient air quality standards of America [Xia & Tong 2006]. Incineration is therefore a dangerous option for waste treatment. There is no evidence that RPS have critically examined the important recent work in this area. Recommendation: that RPS critically examines the work done on particulate emissions from incinerators. They should in particular study whether the series of questions raised by Cormier et al. [2006] have yet been answered.

5. Infant mortality The HIA regrettably gives a rather perfunctory treatment to this important topic. As with studies of cancer incidence around incinerators, no peer-reviewed studies of the effect of incinerator emissions on infant mortality consider wind direction. The only studies that do take account of wind direction are those of Ryan. These showed clear directional effects, but unfortunately did not take into account possible confounding factors, and they have not to date been peer-reviewed. They are nevertheless the only studies on the effects of incinerators on health that deal with wind direction. They need to be confirmed, but they should not be ignored. An example of the Ryan work, relating to the Kirklees incinerator, is shown below [Ryan 2009]:

An earlier version of this map showed the main wind direction to be south-westerly. The highest infant mortality rates are thus largely downwind. As the Ryan work has not taken

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possible confounding factors (e.g. other industry and socio-economic aspects) into account, additional studies are needed. Recommendation: that additional work be carried out by a third party organisation (i.e. not by Ineos Chlor, RPS or HAGATI) to establish the level of adverse health effects (including infant mortality) from incinerators. It is recognised that some health effects such as cancer which often take years to appear, will be difficult to quantify in the short term.

6. Pollution mapping In the HIA, RPS states that there is no need to use a grid size smaller than 300 meters to model pollution in Runcorn (the computer modellers’ rationale for using this grid size was that increasing grid size to 300 meters the first point away from the chimney would only be on the gently rising ground, the second beyond the summit and the third back down the other side, so that in effect Runcorn Hill was ‘averaged out’ by just these three points). However, a study by Lancaster University [2003], using a grid size of 50 meters, showed “complex pollution surfaces with substantial variations from one part of the borough (i.e. Halton) to another”. This clearly casts doubt on RPS’s assertion that the health effects found in Runcorn are socio-economic in origin. The Lancaster University report also commented that Halton “experiences a heavier total pollution load and especially, a heavier load of air pollution”. Recommendation: that RPS repeats its pollution-modelling work, using a grid size of 50 meters.

7. Perceived risk The HIA appears not to have considered at all the importance of perceived risk of the proposed Ineos Chlor facility on health in the area. In their “Rapid Health Impact Assessment of the proposed Ince Resource Recovery Park”, Western Cheshire Primary Care Trust [2006] drew attention to the importance of risk perception by the public relating to the siting and presence of facilities that might be construed as posing a threat to health or amenity. Starr and Whipple [1980] developed a quantitative approach to perceived risk assessment, based on the assumption that society achieves, by trial and error, a reasonable balance between risk and benefit. They drew the following conclusions:

(a) The acceptability of risk is roughly proportional to the real and perceived benefits;

(b) Voluntary risks are some 1000 times more acceptable than are involuntary risks; (c) The tolerable level of risk is inversely related to the number of involved persons.

Starr and Whipple also proposed that risk perception is not directly related to damage level and probability of occurrence, but increases when the likelihood of occurrence is relatively low and the magnitude of potential damage is high. This is now well-established and accepted (Western Cheshire Primary Care Trust [2006]).

According to the Department of Health [1997], risks are generally more worrying and less

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acceptable if perceived:

(a) To be involuntary (e.g. exposure to pollution) rather than voluntary (e.g. dangerous sports or smoking);

(b) As inequitably distributed (some benefit whilst others suffer the consequences); (c) As inescapable by taking personal precautions; (d) To arise from an unfamiliar or novel source; (e) To result from man-made rather than natural sources; (f) To cause hidden and irreversible damage (e.g. through onset of illness many

years after exposure); (g) To pose some particular danger to small children or pregnant women or more

generally to future generations; (h) To threaten a form of death (or illness/injury) arousing particular dread; (i) To damage identifiable rather than anonymous victims; (j) To be poorly understood by science; (k) As subject to contradictory statements from responsible sources.

All of these perceptions apply to the proposed Ineos Chlor facility. The work of Slovic [1987], who developed the psychometric paradigm of risk perception, showed that perceived risk is associated with qualitative aspects of a hazard, such as the degree of knowledge (whether the risk is new, whether its consequences are visible or not), and the nature of the devastation it can cause (e.g. catastrophic, a danger to future generations). Wilkinson [2001] has interpreted the risk-anxiety relationship in terms of the social and cultural attributes of meaning to the environment. Lima [2006] has shown that the risks associated with incineration are perceived as unknown, dread risks and they have the potential to affect people’s quality of life (health, environment, income). Lima [2004] has pointed out that “incinerators represent a solution to urban waste problems in which most of the beneficiaries (those who produce the waste) are not exposed to the risks and to the inconveniences of the facility; on the (other hand), those who live near the site face all the problems during construction and (during) normal functioning of the station. They have to deal with the unpleasant changes to their environment and the uncertainty about the health consequences of the facility, and they consider this situation to be unfair”. Gregory et al. [1996] have pointed out that incineration is a hazard with characteristics such as dread consequences and involuntary exposure, its effects are perceived to be inequitably distributed, and its effects are unbounded in the sense that their magnitude or persistence over time is not well known. Lima [2004], in a 5-year assessment of the effect of risk perception on the mental health of people living near an incinerator, found that:

(i) risk perception is more acute for residents living closer to the site, who also have a less favourable attitude;

(ii) there is an habituation effect for those living closer to the incinerator; (iii) psychological symptoms are associated with socio-economic variables (sex and

education), but also with environmental annoyance; (iv) for those living close to the site, risk perception and the interaction between risk

perception and environmental annoyance significantly increase the prediction of psychological symptoms such as stress, anxiety and depression.

This was after the confounding effects of other environmental stressors such as noise and

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traffic had been allowed for. Lima’s results confirm the Lazarus and Folkman [1984] proposal that the health consequences of an environmental stressor depend on the appraisal of the threat and of the personal resources to deal with it. That is, risk perception per se can modify the quality of life of those living under suspicion of objective risk [Spedden 1998]. Stress effects can persist for many years, as was shown by Matthies et al. [2000] in a study of people living in an area with contaminated soil. Applied Environmental Research Centre Ltd. [2003] carried out a health impact assessment for the South East Wales Regional Waste Plan, and sought the views of many residents regarding different methods of waste treatment. Of 1006 responses to a questionnaire, residents’ preferences were: (1) recycling (2) composting (3) MBT (4) thermal (5) landfill. The report stated: “Participants with experience of living near an incinerator expressed concerns about dioxins, smells, ash residue and emissions of carbon dioxide. Participants who did not feel informed about incineration were nevertheless intuitively against it as can be seen from the statement: ‘I don’t know anything about it but it sounds to me as though incineration would be more costly and damaging. I don’t know whether it is or not but that is my instinct’ ”. Wandersman and Hallman [1993] states: “Risk perceptions that do not match scientific estimates of risk are not necessarily irrational. For example, if one believes that regulators cannot be trusted, experts are not well trained, and accidents can easily be caused by human error, then it is rational to view that risk as unacceptable”. Maynard [2001], of the UK Government’s Department of Health, pointed out that “a risk can only be described as acceptable if the public regard it as acceptable. The role of the scientist is to provide the public with the best possible basis for reaching their decision: it is not for scientists to decide whether a risk is acceptable though they will have their own views on this. It is clear that the acceptability of a risk will depend on the confidence that the public has in the process that leads to this risk assessment”. Maynard summarised the public’s attitude to risk as: worry = risk x fear. Another factor related to risk perception is environmental justice, to which the Western Cheshire Primary Care Trust [2006] drew attention. Their report pointed out that “There is a perception amongst the local communities that the area is already overdeveloped and the community is being ‘dumped on again’ by industry”. This area indeed has far more than its fair share of heavy and polluting industry: the huge Shell oil refinery (including a waste incinerator), Kemira GrowHow, Quinn Glass, Cabot Carbon, Air Products, Veolia (ES) Cleanaway (with high temperature incinerator), Electrical Oil Services (with commercial waste oil recovery), approval for a 600,000 tonne/year waste incinerator and a resource recovery park on Ince Marshes, IneosChlor, IneosFluor and others. The Scottish Executive [2005] has stated that, for environmental justice to be done, “deprived communities which may be more vulnerable to the pressures of poor environmental conditions should not bear a disproportionate burden of negative environmental impacts”. It should be noted here that a report by Burgess et al. of Lancaster University [2003] stated “ten of the wards in Halton (are) amongst the most deprived 10% of wards in England and Wales. Highest levels of material deprivation are experienced in Castlefields, Riverside and Kingsway, with the

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lowest levels in Heath, Daresbury and Birchfield”. In summary, there is considerable evidence that the presence or proposed presence of facilities that might be construed as posing a threat to health or amenity can cause mental health problems in populations. Hence it is likely that perception of risk from the proposed Ineos Chlor incinerator is likely to lead to an increase in stress-related disorders in the local population, and thereby place an additional burden on local medical services. RPS has been most remiss in not considering this important aspect of the proposed Ineos Chlor incinerator. Recommendation: that RPS rectifies this omission, and incorporates a detailed consideration of perception of risk in the HIA.

8. Property values Another effect of perceived risk is that it affects property values [McCluskey & Rausser 2001], and this has been shown to be the case with incinerators [Kiel & McClain 1995, Defra 2003], despite the HIA’s claiming that the proposed Ineos Chlor incinerator would have no effect on property values. Farber [1998] has pointed out that “undesirable land uses are expected to impose health or amenity risks on surrounding communities. These risks are expected to be translated economically into negative effects on adjacent property values. These negative effects may be present even when such uses possess offsetting advantages of proximity, such as employment opportunities”. McClain [1999] carried out a detailed analysis of property values around an incinerator, and “the results of this analysis add to the evidence that the costs associated with an unwanted facility are far more complex and varied than previously perceived. Not only are the costs more prolonged, but they reach out to encompass neighbouring communities in addition to the host community. The results also show that while neighbouring communities are affected by an undesirable facility, the host community bears a larger, uneven burden when selected as the site of an undesirable regional facility”. In parenthesis, it may be noted that in a news release on 17 July 2007 [Western Isles 2007], it was stated that “As the Western Isles relies very heavily on tourism, and in turn its positive environmental credentials, a non-incineration form of waste treatment was preferred. Accordingly, the client identified anaerobic digestion as a likely alternative”. It may be inferred that incineration is considered to equate to negative environmental credentials. Most studies of undesirable facilities have been concerned with landfill sites [Defra 2003], so there is little information on the effects of incinerators, other than that cited above. Because of this, a study of property values around eleven incinerators in Great Britain was carried out [Centre for Economics and Business Research (CEBR) 2003], which found a mean of 18% lowering of property values adjacent to an incinerator, rising to 0% at 2.8km from the incinerator. However, this study may be flawed, in that it assumed that there was no effect on property values at 2.8km (1¾ miles) and beyond, and so selected comparison locations at around that distance. However, the Defra study [2003] makes it clear that disamenity effects can persist up to 4 miles (6.4 km) from the undesirable facility. Whilst this would suggest that the CEBR study underestimated the disamenity effect, which could thus be well over 20% close to an incinerator, I believe that it is preferable to use the Kiel and McClain [1995] results, which show disamenity persisting up to 3½ miles, as being reliable. Defra [2003] interpreted the Kiel and McClain data to yield a rectilinear correlation, which they

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depicted graphically (their Figure 2.1). From their graph the equation can be derived: Percentage Reduction in property value = 12.0 – 3.43 x (distance in miles) There are a significant number of houses within 3½ miles of the proposed Ineos Chlor facility, and there will undoubtedly be a marked adverse effect on the value of those houses. RPS is clearly incorrect in claiming that the proposed Ineos Chlor facility would not adversely affect property values in the area. Recommendation: that RPS looks closely at the available literature on disamenity effects of incinerators, and gives reasoned arguments for any conclusions that they draw.

9. Summary The HIA prepared by RPS is deficient in a number of respects. (i) It lacks clarity and consistency in numerous aspects, and is not written to aid

comprehension. Recommendation: rewrite in a concise, clear and consistent manner. (ii) An incorrect statement regarding total dust needs to be corrected. Recommendation: corrections are made to the relevant statement and

conclusions adjusted accordingly. (iii) The section on cancer risk does not take into account the wide range of data

available. Recommendation: rewrite in an objective and critical manner. It is also

recommended that an independent study be made of health effects of incinerators, taking particular account of wind directions.

(iv) The section on respiratory function and disease lacks assessment in depth, and

takes no account of a number of recent publications on the subject. Recommendation: RPS should critically examine the work done on particulate

emissions from incinerators. In particular, they should examine whether the series of questions raised by Cormier et al. [2006] have yet been answered.

(v) The HIA gives insufficient space and weight to the treatment of infant mortality. Recommendation: additional work be carried out by a third party group (i.e. not by Ineos Chlor, RPS or HAGATI) to establish the level of adverse health effects (including infant mortality) from incinerators. (vi) The HIA appears not to consider the perception of risk in any way. Recommendation: RPS should incorporate a detailed consideration of

perception of risk, and its consequences, in the HIA. (vii) The HIA maintains that the grid size that they used for pollution modelling was adequate. However, Lancaster University work appears to show otherwise. Recommendation: RPS should repeat the modelling studies using a 50 meter grid size.

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(viii) The HIA dismisses any effect on property values. Recommendation: RPS should include a detailed consideration of the effects

of the proposed Ineos Chlor incinerator on property values in the area, taking into account the published work on the effects of disamenity sites on property values.

10. References Applied Environmental Research Centre Ltd. Health Impact Assessment, prepared for South East Wales Regional Waste Group. AERC Ref: E9502 (2003). Bridges J. Health impact assessment of chemicals that may be emitted from the proposed Ince refuse derived fuel plant. Proof of Evidence to Public Inquiry on proposed Peel waste incinerator on Ince Marshes, March 2008. Brown L.M., Collings N., Harrison R.M., Maynard A.D. and Maynard R.L. Ultrafine particles in the atmosphere: introduction. Philosophical Transactions of the Royal Society of London A 358 (2000) 2563-2565. Burgess C., Crutchley A., Clark G., Davies G., Gatrell T., Pooley C., Stelfox M., Watson N., Welshman J. and Whyatt D. Understanding the factors affecting health in Halton. Report prepared by Lancaster University for Halton Borough Council, August 2003. Castorina R. and Woodruff T.J. Assessment of potential risk levels associated with U.S. Environmental Protection Agency reference values. Environmental Health Perspectives 111 (2003) 1318-1325. Centre for Economics and Business Research. The economic impact of an EfW incinerator in Newhaven. Proof of evidence submitted as part of an objection by Lewes District Council to the East Sussex and Brighton and Hove Waste Local Plan, 2003. Cormier S.A., Lomnicki S., Backes W. and Dellinger B. Origin and health impacts of emissions of toxic by-products and fine particles from combustion and thermal treatment of hazardous wastes and materials. Environmental Health Perspectives 114 (2006) 810-817. Defra. A study to estimate the disamenity costs of landfill in Great Britain. 2003. (Report prepared by Cambridge Econometrics in association with EFTEC and WRc). Department of Health. Communicating about risks to public health: pointers to good practice. 1997. www.dh.gov.uk/PolicyAnd Guidance/HealthAndSocialCareTopics/ RiskResearch/fs/en Elliott P., Shaddick G., Kleinschmidt I., Jolley D., Walls P., Beresford J. and Grundy C. Cancer incidence near municipal solid waste incinerators in Great Britain. British Journal of Cancer 73 (1996) 702-710. Farber S. Undesirable facilities and property values: a summary of empirical studies. Ecological Economics 24 (1998) 1-14. Gómez-Moreno F.J., Sanz-Rivera D., Martin-Espigares M., Papameletiou D., De Santi G. and Kasper G. Characterization of particulate emissions during pyrolysis and incineration of refuse derived fuel. Aerosol Science 34 (2003) 1267-1275.

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Gregory R., Slovic P. and Flynn J. Risk perceptions, stigma, and health policy. Health & Place 2 (1996) 213-220. Howard C.V. The health impacts of incineration, with particular reference to the toxicological effects of ultrafine particulate aerosols, organo-chlorines and other emissions. Proof of Evidence submitted to East Sussex and Brighton and Hove Local Plan Public Inquiry, 2003. Kiel K.A. and McClain K.T. House prices during siting decision stages: the case of an incinerator from rumor through operation. Journal of Environmental Economics and Management 28 (1995) 241-255. Lancaster University, Dept. of Geography & Institute for Health Research, 2003. Understanding the factors affecting health in Halton. www2.halton.gov.uk/pdfs/socialcareandhealth/healthreportfull Lazarus R.S. and Folkman S. Stress, Appraisal and Coping. Springer, New York, 1984. Lima M.L. On the influence of risk perception on mental health: living near an incinerator. Journal of Environmental Psychology 24 (2004) 71-84. Lima M.L. Predictors of attitudes towards the construction of a waste incinerator: two case studies. Journal of Applied Social Psychology 36 (2006) 441-466. Livingston J. Particulate air pollution and the RRR application. Evidence given to Belvedere Incinerator Public Inquiry, July 2003. Matthies E., Höger R. and Guski R. Living on polluted soil: determinants of stress symptoms. Environment and Behavior 32 (2000) 270-286. Maynard R.L. Acceptable risk of air pollution. International Journal of Hygiene and Environmental Health 204 (2001) 203-206. McClain K.T. Undesirable facilities and non-host community effects. Paper presented at a workshop sponsored by the U.S. Environmental Protection Agency’s Office of Economy and Environment and National Center for Environmental Research and Quality Assurance, entitled “Economic Analysis and Land Use Policy”, Washington D.C., 2 December 1999. McCluskey J.J. and Rausser G.C. Estimation of perceived risk and its effect on property values. Land Economics 77 (2001) 42-55. Roberts R.J. and Chen M. Waste incineration – how big is the health risk? A quantitative method to allow comparison with other health risks. Journal of Public Health 28 (2006) 261-266. Rose W.I., Riley C.M. and Dartevelle S. Sizes and shapes of 10-Ma distal fall pyroclasts in Ogallala Group, Nebraska. Journal of Geology 111 (2003) 115-124. Ryan M. Infant mortality around the Kirklees incinerator for 2004-2008; www.ukhr.org/incineration/kirklees.pdf. Scottish Executive, 2005. Review of progress on environmental justice. Paper 2005/37. www.scotland.gov.uk/Resource/Doc/47121/0020653.pdf Slovic P. Perception of risk. Science 236 (1987) 280-285.

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Spedden S.E. Risk perception and coping. In The Environment and Mental Health: a Guide for Clinicians (ed. Lundberg A.), Laurence Erlbaum, Hillside, NJ, 1998, pp. 103-114. Starr C. and Whipple C. Risks of risk decision. Science 208 (1980) 1114-1119. Wandersman A.H. and HallmanW.K. Are people acting irrationally? Understanding public concerns about environmental threats. American Psychologist 48 (1993) 681-686. Western Cheshire Primary Care Trust. Rapid health impact assessment of the proposed Ince Resource Recovery Park. August 2006. Western Isles news release 17.7.07. The Western Isles – a unique environment. www.edie.net/news/news_story.asp?id=13301 Wilkinson I. Anxiety in a Risk Society: Health, Risk and Society. Routledge, London, 2001 (available in electronic format only). Xia Y. and Tong H. Cumulative effects of air pollution on public health. Statistics in Medicine 25 (2006) 3548-3559.

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COMMENTS ON THE HIA HAGATI comments in italics. Reference in HIA Issue and HAGATI Comments Page 2 1.5 A key aspect of the HIA approach has been to build upon the

technical information already provided in the Environmental Statement (ES) submitted as part of the Section 36 application for the proposed Development, supported by additional work to inform the Environmental Permitting Regulations application to be made by INEOS Chlor to the Environment Agency.

The choice of data by RPS raises questions of an ‘Independent HIA’ as required by DBERR.

Page 8 2.8 Along with the main facility, the proposed Development will also

include a new dedicated service road. Map in Noise assessment shows HGV accessing from south of site

NOT from Picow Farm Road. Figure D3 and Figure D4 do not show the new service road.

Page 10 Operation Overview 2.17 Core operational activities include fuel delivery, energy recovery and

transportation of residual waste materials. Additional activities are associated with the transportation of staff to the proposed facility.

As delivery of fuel is a ‘Core operational activity’ it can be addressed

by way of an ‘Off Site’ permit condition. Page 10 2.19 Under this assumption (85,000 tonnes per year by HGV) it is

expected that in total (for both phases of the proposed development) a maximum of six trains will serve the site each day, although due to restrictions on the main line capacity, it is expected that a proportion of these freight movements would be at night time.

Six trains per day equates to twelve movements per day and

therefore eighty-four per week. Restrictions on West Coast Main Line are acknowledged and state that some train movements would be scheduled at night. This is contrary to the planning permission granted to Ineos.

Page 11 Residual Waste Management 2.23 Following the recycling and recovery process, the resultant residues

from full operation of both phases of the Development are anticipated to comprise:

Bottom Ash – approximately 205,000 tonnes per year (tpa) FGT Residues – approximately 60,000 tonnes per year (tpa)

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265,000 tpa = 744 tonnes per day (265,000 divided by 365). As each

lorry can carry approximately 18 tonnes, dividing 744 by 18 gives 41 lorries per day.

Below is a table and references from the HIA in which it quotes two completely different figures for HGV movements. Remembering that the toxic waste lorries are only taking out the fly ash to Randle Island, and the lorries bringing in waste that has not come by train are limited to 10% of the total being burnt, this is not only confusing, it also indicates that RPS have erred in their calculations of the number of lorries required. This raises doubts about the reliance that can be placed on the conclusions RPS (and thus Ineos) draw from the more complex calculations performed elsewhere in the report.

P12 2.31 On this basis, the assessment stage will concentrate on

investigating:

o potential exposure and health response to emissions from the proposed Development;

o potential exposure and health response from changes in road traffic emissions;

FUEL DELIVERIES

P10 HIA states P63 HIA States 216 HGV per day (I.e 432 trips). BUT:

TPA 85000.00 85000.00 Tonne per

18.30 18.50

Loads p.a. 4644.81 Days in year 365.00 Load per day 12.73 trips per HGV 2.00 Trips per day 25.45 36.00

TOXIC WASTE TPA 265000.00 Tonne per

18.30

Loads p.a. 14480.87 Days in year 365.00 Load per day 39.67 41 quoted in objection trips per HGV 2.00 Trips per day 79.35 Should Quote No of TRIPS

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o potential change in health risk from road traffic accidents; o Potential noise effects from changes in road and rail traffic

movements o socio-economic benefits from employment opportunities; and o community perceived health risk

The change in activity on the spur line is dramatic with rail traffic increasing from six daytime movements per week to eighty-four movements per week (some at night) an increase of fourteen times more traffic.

P13 3.4 The closest residential properties are located immediately to the

south of the site on Clarks Terrace (approximately 50m from the southern boundary of the site). Other residential receptors are located 240m to the east of the proposed site beyond the playing fields (including a football field and bowling greens) and the A557 Weston Point Expressway (including residents of Westfield and Weston Village). Along with residential areas in proximity to the proposed site, there are also a number of properties parallel to the rail link that serves the facility (i.e. Percival Lane and Picow Farm Road).

No mention is made of the new Evolution housing development adjacent to Folly Lane spur line. This estate contains over one hundred houses and apartments and in total has more occupancy than Picow Farm Road. The houses below the level crossing in Sandy Lane back directly onto the Ineos site but are not referred to. All the houses in Baker Road plus the houses in Sandy Lane between the level crossing and the Expressway are all closer than those considered.

P24 There is also a statistically significant higher rate of colorectal cancer

registrations for women in Halton. There are wide number of risk factors for such cancers ranging from genetic predisposition through to lifestyle (smoking, diet, sedentary lifestyles etc) and typically higher rates in areas of socio-economic deprivation.

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Values highlighted in orange are not the highest e.g. 100/103 for females but 117/100 for males is ignored.

Page 56 5.32 Since any possible health effects are likely to be very small, if

detectable, studies of public health around modern, well-managed municipal waste incinerators are not recommended. (UK HPA 2009).

Given the available evidence for actual and potential effects on

health, some of which are only starting to be understood, this comment illustrates a particular attitude from an official body such as a public health authority, which is worrying in the context of the siting of incineration or Energy from Waste facilities.

P58 Noise. No mention of noise from cooling towers P59 Text & map omits the new Evolution housing development. 5.46 Currently the rail link off the West Coast Main Line is in use

approximately three times per week, is of a similar elevation to the gardens in Picow Farm Road and elevated by approximately 8-9m above the rear gardens of the Percival Lane (with the rail link head typically above the overall height of the dwellings).

Note that at some houses in Picow Farm Road the gardens are 8m

below the embankment.

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Page 60 Existing train noise lasting 1 to 1.5 minutes. Does not take into account trains waiting on line as evidenced by

HAGATI recordings (available if required). Acknowledges the current peak of 85.3dB LA max, which is well above the recommended maximum decibel level of 10dB LA max more than the ambient levels of 40dB LA max at night and 50dB LA max in the daytime, therefore the current peak level would constitute a nuisance

5.51 In this instance, in keeping with operator guidance, it is understood

that all wagons used to deliver RDF will employ independent axles and pivoting bodies, which will effectively prevent the occurrence of wheel screech and subsequent risk of sleep disturbance along Percival Lane and Picow Farm Road.

Having acknowledged the risk of sleep disturbance through wheel

screech there is no mention of the overall high noise level well above that considered to be capable of causing nuisance or the vibrational effects of the trains (to which no mitigation can be applied).

‘Not transport RDF ‘at night time & ‘as far as reasonably practical’. There is no mention of returning empty trains. What is “reasonably

practical” in this sense? It should mean that no trains should be scheduled during night-time, that Ineos should not be allowed to accept deliveries during the night time and the night time should be defined as ‘dusk to dawn’. To allow deliveries up to 23:00 hrs and call it ‘Day Time’ is misleading.

5.55 …. offsets more diffuse and significant health risks associated with

the transportation of RDF by road. Neither way is acceptable if either causes nuisance. 5.68 ‘However, the limit of 85,000 tpa of RDF delivered’ Indicates they think 85,000 is the limit but it is limited to 10% of

usage not 85,000 which is 10% of capacity. 5.69 Mitigation re HGV risks is the ‘provision of a new service road to the

site off the existing Picow Farm Road’ map showing HGV route from south i.e. via South Road / South

Parade / Sandy Lane 5.83 A number of concerns have been raised over the potential impact

that proposed Development may have upon the value of housing in the local area. There are a number of case studies in dense urban areas that do not provide substantive evidence that well managed Energy from Waste facilities have had a measurable impact on property values, the volume of transactions or the ability of an area to attract inward investment. (Onyx 2005) (Hunt 2007).

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There are counter studies (Kiel & McClain 1995, DEFRA 2003) referred to in the earlier Qstar report.

5.84 When further considering the location of the proposed Development,

it is not anticipated there will be any discernible long-term influence upon property value.

This indicates a short / medium term effect - which is also

unacceptable. 6.1 The proposed Development has a number of features that might be

considered to have implications for the health of neighbouring communities. This HIA has examined the extent of these implications in a manner that considers local circumstance and the best-available scientific evidence. In particular, this HIA has been applied to test the previous and current UK Health Protection Position Papers on Municipal Waste Incineration (UK HPA 2008, UK HPA 2009), to establish the relative risk to local communities from the construction and operation of the proposed Development.

This ‘test’ runs counter to HPA advice and is impossible to perform if

only data from the previous RPS exercises is used. Page 70 6.7 Based upon a review of the original modelling to the ES and the

Human Health Risk Assessment together with the application of exposure response mechanisms developed by the Department of Health's Committee on the Medical Effects of Air Pollutants (COMEAP), it is concluded that the proposed Development does not constitute a significant risk to health from emissions to atmosphere during construction or operation.

If the data from the original ES and HHRA is flawed any subsequent

conclusions drawn will be flawed. This is the very nub of the question of ‘independent’ as required by the DBERR planning permission.

P71 Where the potential for an effect on air quality exists ‘Best Practical

Means’ will be used to reduce the impact, including the following control measures as appropriate.

This should be Best Available Technology (BAT) as this has replaced

BATNEEC where the cost to the operator was a previously a consideration, protection of the health and environment now takes precedence.

7.15 Understandably, the provision of a new waste management facility

engenders a number of perceived health impacts and associated community concerns. However, as outlined in the HIA and according to the available evidence base, once operational, the proposed Development is not anticipated to present a significant risk to health.

Perceived concerns are valid and must be properly addressed. The

application is not for a waste management facility - it is a privately owned power station run on RDF.

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7.16 Addressing such perceptions can only be achieved by raising

awareness as to how community health is implicitly considered through the design of the plant, and through stringent environmental regulations and standards set to protect health at both the planning and permitting stage.

These reassurances rely heavily on the regulations being applied yet

there is no evidence of incinerator closure due to non-compliance, the fines set are minimal and the standard procedure appears to be that the Environment Agency sends a letter to the operator.

P74 Have Ineos formally committed to recommendations re publication of

Health / Emission monitoring, etc. We would expect that all these assurances to form part of any permit

granted. 7.22 It is recommended that such mapping be discussed with the PCT to

account for wider socio-economic factors that may have a greater influence upon health and well-being, and be presented to the INEOS Site Community Forum, the Local Liaison Forum and be made available to the general public alongside planned engagement programmes and through the INEOS complaint management

Why can’t this be done around existing Incinerators as per Michael

Ryan BEFORE the Environmental Permit is granted? 7.25 The use of rail to transport RDF will significantly reduce the potential

risk of road traffic accidents and reduce community disruption. Although this will increase the use of the rail link running parallel to residents on Picow Farm Road and Percival Lane, the use of independent axles and pivoting bogies on all RDF wagons, in conjunction with strict day and night-time noise restrictions, are anticipated to be sufficient to reduce community annoyance and prevent sleep disturbance.

Reduction of annoyance is insufficient if either the noise or vibrational

effects do cause sleep disturbance. The figures provided by Ineos confirm that noise nuisance will occur and vibrational effects cannot be mitigated.

7.32 It is the case that INEOS will provide an Environment Fund to the

Council on a per tonne basis. It is understood that the allocation of such funding will be at the Council’s discretion. However, it is recommended that at least a proportion of this funding be allocated locally and applied to address local circumstance and the existing burden of poor health identified during the community profile.

What is the definition of ‘local’? Shouldn’t it ALL be allocated for the

area immediately around the Incinerator and not used to subsidise the Council’s EXISTING responsibilities?

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www.haltonandsthelenspct.nhs.uk/library/documents/healthconsultationineoschlorfinal.pdf Page 10 Report prepared by: Helen Castles Kevin O’Brien Centre for Public Health Liverpool John Moores University Castle House North Street Liverpool L3 2AY 4/6/07 for Halton PCT Table 1: Health indicators Indicator

Halton LA

Life expectancy (compared to national)

LOWER

Deprivation (compared to national) HIGHER

Deaths and hospital admissions (13 indicators – compared to North West Average)

Deaths from all causes HIGHER

Deaths from circulatory disease (Heart Disease/Stroke)

HIGHER

Deaths from cancer HIGHER

Elective (pre-planned) admissions to hospital HIGHER

Emergency admissions to hospital HIGHER

Hospital admissions for road traffic accidents HIGHER

Hospital admissions for stroke AVERAGE

Hospital admissions for acute respiratory conditions HIGHER

Hospital admissions for cardiovascular conditions HIGHER

Hospital admissions where asthma was a factor HIGHER

Hospital admissions where Chronic Obstructive Pulmonary Disease (COPD) was a factor

HIGHER

Hospital admissions where lung cancer was a factor HIGHER

Hospital admissions where a mental health condition was a factor

HIGHER

Perception of General Health – (compared to national average)

Percentage of people having a long-term limiting illness

HIGHER

Feeling “in poor health” HIGHER

Lifestyle – (compared to national average)

Smoking AVERAGE

Obesity AVERAGE

Alcohol (binge drinking) HIGHER

Healthy eating LOWER

It is extremely interesting that the two major factors that are supposed to be the largest self inflicted contributors in Halton smoking and obesity are both shown as ‘Average’. This would

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seem to contradict the argument proposed in the HIA.

Page 10 2.21 Sensitive ecological receptors.

The HIA does not mention the DEFRA report identifying this area as one with ‘existing dioxin pollution’. Especially important as the source and effects of this contamination are as yet unknown therefore it is impossible to calculate any cumulative effects or know how close local conditions are to the danger of allowing dioxins to enter the food chain by the ingestion of contaminated grazing by cows and sheep on the meadows at Frodsham Score, which area is shown on the map above.

3.2 The key air quality issues associated with waste receiving activities

include emissions of dust and PM10.

Incorrect PM2.5s are more dangerous c.f. Para. 4.1.4 of Ineos Air

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Quality Assessment - ‘the evidence that particles with a mean aerodynamic diameter of less than 2.5µm, PM2.5, are potentially more hazardous than larger particles’.

Page 12 3.4 Mentions the Stockholm Convention.

Does not mention the fact that by using RDF as fuel this power station will be a source of Unintentional Persistent Organic Pollutants (UPOP’s)

Page 14 3.19 In contrast to the pollutants described above, potential effects from

odours relate to the possibility of nuisance effects rather than health effects.

Odours indicate the presence of chemical concentrations which may be benign or harmful - they cannot be dismissed as just a ‘nuisance’. The products of incomplete combustion can contain many substances.

Page 16 4.6 To obtain a permit, Operators have to demonstrate in their

Applications, that the techniques they are using or are proposing to use are the Best Available Techniques (BAT) for their installation.

BAT has not been demonstrated and cost should not be a factor regarding health hazards

Page 16 4.7 The essence of BAT is that the techniques selected to protect the

environment should achieve an appropriate balance between environmental benefits, which go beyond legal requirements (for example, the Air Quality Strategy) and the costs incurred by Operators.

The Environmental Agency’s principle that all new plant should be built and operated using Best Available Technology (BAT), which relates to best health, safety and pollution practices. Previously BATNEEC (Best Available Technology Not Entailing Excessive Cost) was employed. As cost should have a lower priority than health, the emphasis on BAT over BATNEEC is seen as a positive move towards waste treatment plant design.

Page 17 4.14 The evidence that fine particulates are more dangerous.

Makes no mention that ultra-fine are even more dangerous and that the World Health Organisation states that there is no safe lower limit for them..

Page 17 4.14 The current limit value requires Member States to reduce levels of

pollutants in a relatively small number of localised ‘hot spots’.

Surely all the reports which have led to initiatives on health improvements in Halton and an Environmental Justice audit would identify Halton as qualifying as one of the worst hot spots in the UK.

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Page 18 4.15 This series of measures to reduce particulates in the atmosphere, especially in polluted areas run counter to the siting of an incinerator which will emit fine and ultra-fine particulates.

Page 28 5.29 Two Osiris particulate monitors have been located at Deacon Road

and Hale Road by HBC, where traffic is thought to be a problem, since road traffic is also a significant contributor of particulate matter.

Note that 24 exceedences of >50 µg/m^3 were detected at Hale Road from June 2005 to Feb 2006 (3.1km from EfW site) indicating a transport particulate problem already exists in HBC without the HGV’s or the significant increase in diesel trains serving the EfW facility.

Page 29 Table 5.6 This shows that there are already a number of exceedences in

particulates in Halton. Page 33 5.38 The effect of mercury releases from the existing Ineos operations at

the Runcorn Site has been monitored for a number of years by measuring concentrations of mercury in the atmosphere at a monitoring station located at Sydney Street, in a nearby residential area. Monitoring is continuous, and measures weekly mean mercury concentrations. Table 5.12 presents data for this site, showing the annual averages for the period from 1987. The data clearly indicate that INEOS has significantly reduced ambient concentrations of mercury following process improvements in 1997.

Table 5.12 does show a decline in mercury (Hg) to 2005 at the Ineos monitoring site, BUT, the Annual Mean Concentration of Metals Table 5.9 indicates that the mercury concentration in Runcorn is up to 10 times higher at the Castner Avenue monitoring site than any of the other 17 sites studied throughout the UK, i.e. 2 ng/m^3 .

This data clearly indicates that Weston is a ‘hot spot’ for mercury, and any additional mercury emissions from, for example high energy bulb incineration, could increase this to even more dangerous levels in this area of Halton.

Page 33 5.38 The emissions measured at Sydney Street are of mercury released

as emissions to atmosphere from the old carbon/mercury cell rooms process not from any chimney. We accept that the modern membrane cells have dramatically reduced this effect. However, all previous readings prior to 1997 exceeded the limits, and this has two obvious consequences. First all the surrounding areas close to the main Ineos site have for many years been exposed to mercurial contaminated atmosphere which renders them a ‘Vulnerable Group’ to any further exposure. Also the emissions of mercury from the incinerator are likely to be more reactive mercury hydrides and under calm conditions will fall on this area with minimum dilution.

Page 35 5.45 The background concentrations of dioxins and furans have been

derived from the highest measurements taken in Manchester (the nearest TOMPS site).

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As Halton has nineteen sites licensed to emit dioxins to air (Fiddlers Ferry being the largest), could the Manchester measurements be the results of emission in Halton? How can any believable cumulative assessment be made when the immediate area surrounding the incinerator has already been identified by DEFRA as contaminated by dioxins but no research has been carried out to establish the source and extent of this contamination?

Page 35 5.44 Background metal concentrations assumed for the purposes of this

assessment have been derived from the closest major urban area to the INEOS Runcorn Site. Levels recorded at an urban location are likely to be higher than those that would be representative of the more rural study area. In the case of the UK Lead and Multi-Element Networks, the closest urban monitoring location is Castner Avenue, Runcorn. The data from this urban site has, therefore, conservatively been assumed as the background metal concentrations.

The mercury concentrations given in Table 5.9 could be very much higher at a large number of houses next to the EfW plant as they are also closer than Castner Avenue to the mercury electrolysis plant.

See photo below

Page 37 6.3 Establishing of Ambient Concentrations.

Only four of the twenty values used in Table 5.13 are ‘local’ measurements. Given the concentrations of road and air traffic, the

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emissions from industry and manufacturing plus the unmeasured or accounted for contributions from the many areas of contaminated land and toxic waste site, can this be classed as the ‘ambient concentration’?

Page 40 6.19 Atmospheric Stability is a measure of the turbulence of the air, and

particularly its vertical motion.

The horizontal motion (ideally laminar flow or turbulent) is the important factor.

Pages 42 & 43 Windroses.

The charts all indicate a majority direction in two sectors, the quadrants south and west. There is practically no wind from the Northeast and the claim that the prevailing wind direction should be considered as Southwesterly is therefore valid.

Page 44 6.25 Runcorn Hill (approximately 75m AOD) is located 1km to the East of

the proposed EfW facility.

The highest point of the hill is only 750m distant with the residential properties at an elevation of 55m that are only 522m from the stack, and are downwind of the prevailing Westerly wind direction identified in the wind rose calculations.

Page 44 6.26 Terrain data have therefore been included into the atmospheric

modelling data.

In which direction?

See illustration below which indicates the variations in terrain dependent on direction. The worst case scenarios should be in direction of prevailing wind and in direction of most vulnerable properties.

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Page 46 Table 6.2 Previously the chimney was stated as having four flues Page 47 6.37 Table 6.3 to Table 6.4 summarises the mass emissions used in this

assessment corresponding to each scenario and averaging period. Table 6.3 shows particle emissions of 6g/sec and Scenario 2 of 2 g/sec.

This translates to daily particle emissions of 518kg per day and 172kg per day respectively.

0 3 6 9 12 15 180

20

40

60

80

Distance From Incinerator ( km)

He

igh

t A

bo

ve

Sea

le

ve

l(m

)

Land Due East Land Due North Land N.east

Land Height in Various Directions from Incinerator

2 4 6 8 10 12

East

North

N.East

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South and West are the Prevailing Wind Directions Why is maximum concentration not in direction of prevailing wind? Page 51 6.39 Nitrous oxides. Nitrous oxide is a Green House Gas (GHG) which is 310 times as

potent in terms of radiative forcing (though this depends upon the time horizon adopted). It is believed to be more of an issue where combustion temperatures fall below 850C and where the control of NOx is through use of SNCR, especially with urea as the reagent. This is similar to the proposed method for this incinerator, has this issue been properly addressed?

Page 73 7.19 Source emissions monitoring data indicate that PM2.5 may form

approximately 7.3% of the total particulate emissions following treatment using bag filters, although this is based on a single dataset.

If this data refers to emissions AFTER filtration, then from the total

particle emissions of 172kg/day (Scenario 2), the equivalent of 12.5kg of PM2.5 will be emitted each day i.e. millions of PM2.5 particles per day.

This Air Quality data presented by Ineos needs clarification as this

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proportion of harmful PM2.5 emissions pose a considerable threat to the community. The World Health Organisation states that ‘There is no safe lower limit at which concentrations of fine particulates are considered safe.’ Given the attenuated height of the stack (which could result in insufficient dilution) this is an essential application for the Precautionary Principle.

Page 30 Table 5.9 The nearest site listed is 39km away with the furthest 231km. Where

is the area described by the DEFRA report which identified Halton as ‘A contaminated dioxin site’?

Pages 42 & 43 Windroses. There are no figures provided for the amount of days classed as calm

although each windrose diagram shows that these periods exist. Given our concern that the proximity of residential properties and sensitive areas has always been known why was this specific condition not addressed?

In our previous submissions we have quoted the figure obtained from

local wind statistics of 12% calm this equates to thirty days per year of episodes of minimum dilution and must be a factor in any calculations.

�

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Health Impact Assessment Outstanding issues to be addressed A reliable picture of the existing burden of health is fundamental to any appraisal of the perceived threats to health associated with the proposed EfW facility. The Health Impact Assessment (HIA), in its present form is unfit for that purpose, for the reasons outlined above. It is therefore recommended that;

1. The HIA be rewritten, taking account of the comments made above, and the need to provide a comprehensive picture of ill health in Halton, with standardised and consistent comparisons and evidence based conclusions.

2. The data in the HIA should be presented in a form which facilitates comparison with

the Human Health Risk Assessment (HHRA).

3. Mortality data to be provided in the same format as in the original HHRA, for the original sensitive receptors, plus additional ones in Frodsham and Helsby. There should be either overall mortality data (including the effects of cadmium as highlighted by Roberts and Chen (2006) or as mortality data for a range of the most important individual pollutants.

4. A critical assessment of the original literature on adverse effects from incinerators to

be undertaken, particularly to establish which studies (if any) have considered wind direction and confounding factors.

5. RPS should critically examine studies relating to particulate emission from

incinerators, and, in particular, whether the issues raised by Dormier et al. (2006) have been addressed and answered.

6. The HIA provided a cursory account of infant mortality. Further evaluation should be

undertaken to establish the levels of adverse effects (including infant mortality) from incinerators.

7. RPS should justify its assertion that Halton’s ill health is attributable to socio-

economic factors in the light of the findings of the Halton and St Helens Cancer Health audit (2008) that such a correlation is weak.

8. The HIA should be revised to include the adverse psychological and mental health

impact of the proposed incinerator on the people of Halton.

9. RPS should provide a comprehensive account of the contributory factors in Halton’s appalling cancer rate with reference to the specific cancers and their likely causes (e.g. bladder cancer and occupational environmental chemical pollution).

10. RPS should justify their refusal to recognise that Halton’s pre-existing poor health

record makes it a vulnerable community or the cumulative effects of long-term exposure to fine and ultrafine particulates.

11. DEFRA should undertake a study of the high levels of dioxins found in heronries in

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Runcorn to identify their origins in the area, if any.

12. RPS should rectify the omission of any reference to the Randle Island toxic waste site and the transportation of toxic waste in the HIA. In particular it should provide more information on the conversion of fly ash to ‘wet cake’ and safeguards against its deterioration in transit and at the dump.

13. The HIA appears not to consider perception of risk associated with incinerators. A

detailed consideration of the perceptions of risk, and its consequences, should be provided.

14. In view of the criticisms of the grid size used in pollution modelling RPS should

repeat the study using the 50 meter grid size recommended by the Entec report or, as recommended by the designers of the software used.

15. The HIA dismisses any possible effect on property values in the Area. RPS should

provide a detailed consideration of the effects of the proposed incinerator on property values in the area, taking into account the published work on the effects of disamenity sites on property values.