Guildford Labour Party submitted objections to the Environment Agency and to Surrey County Council Planning Committee. Our reports discussed the issues of site suitability, waste screening, transfer of toxic pollutants, inadequacy of emissions monitoring, location of the waste arisings and the proximity principle, the building size, the sustainability of the waste supply with increased recycling, the traffic impact, the economic viability, and viable alternatives.
Some of the key points in our submissions are listed below.
- Municipal Solid
Waste (MSW) is an unknown mixture and could contain hazardous materials
leading to unpredictable high levels of toxic emissions at certain
times without the operators' knowledge. No waste screening is proposed
or is practical.
- Deposition on particulate
material is an important pathway for transferring toxic pollutants to the
surrounding population. It is not clear that the dispersion modelling takes
account of this mode of deposition especially in wet weather conditions.
- Ash particles can
adsorb and stabilise volatile species formed during combustion including
dioxins, furans, PAHs, VOCs, and heavy metals. Respirable size particles
carry a higher burden of pollutants and are more dangerous than larger particles.
- Respirable size
particles are at the lower limit of the bag filter capability. Many of these
particles will pass through the filter during normal operation and as a
result of filter cleaning.
- There is insufficient
knowledge about low level cumulative uptake into body tissue of dioxins
and furans and of the effects on health.
- The proposed emission
monitoring is very unsatisfactory. Only the acid gases will be measured
continuously. The occasional analyses proposed for the most toxic pollutants
(dioxins, furans and heavy metals) and the absence of any analysis of the
respirable size dust particles is unacceptable. The failure to propose continuous
monitoring in the adjacent residential areas is also unsatisfactory.
- The upper limits for dioxins and furans refer to gaseous emissions only. No limit has been specified for dioxins adsorbed on solid particles and these concentrations will not be measured.
- The proposed
site in Guildford is not the optimum position in Surrey for an incinerator
of this size, generating unnecessary traffic, with accompanying pollution,
noise and congestion.
- Its location here
and its size contravenes the proximity principle.
- Insufficient weight
has been given, in consideration of access roads, that Stoke Ward is predominantly
a residential area like most of Guildford.
- The application
does not take into account Guildford Borough Council's planning brief for
the Slyfield Industrial Estate.
- The plant building
is far too big for its purpose, particularly its roof height.
- We do not accept
'economy of scale' as an argument to justify a large incinerator.
- There is inadequate
attention given to recycling in the application. As recycling targets are
met, over the next 5-10 years, this plant could require import of waste
from outside Surrey to keep it financially viable.
- Projections for
electricity generation appear ambitious and out of line with similar plants.
This could lead to waste importation to meet power generation targets.
- An alternative
access route through the Thames Water sewage works has not been thoroughly
investigated.
- There appear to
be no safeguards to prevent any non-domestic or hazardous waste entering
the feed stream to the incinerator.
- No decision should be taken until Surrey County Council's waste plan is settled.
Much more information is available in our reports
READ
THE FULL REPORTS OF OUR
OBJECTIONS
SUBMITTED IN SEPTEMBER 2000
Both
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