Although SEPA (the Scottish Environmental Protection Agency) will carry out continual in-stack monitoring of certain emissions, and an uncertain number of spot checks on others, they do not routinely carry out monitoring of ambient/background concentrations of any emissions in the surrounding area.
Guy Seaton, principle SEPA officer with regard to the Binn Farm proposal, told me:
- Councils are responsible for air quality standards and objectives.
- SEPA doesn’t routinely look at particulate emissions.
- Monitoring of ambient concentrations of particulates and other emissions may or may not take place.
It is the second and third of these statements that a most concerning because of the much-publicised concerns over the health effects of ultra-fine respirable particles known as PM2.5s. Sadly, the Environmental Health Manager of Perth and Kinross has stated that it is SEPA's responsibility for monitoring emissions, and therefore the Council should not interfere with monitoring (see his Statement of 30 November 2006). This is an amazing abrogation of responsibility given that SEPA has clearly stated that Councils are responsible for air quality standards and objectives.
Some of the most dangerous emissions from incinerators are dioxins and PM2.5 particles - monitoring of these is completely inadequate.
There are two problems with this kind of intermittent monitoring:
1. Incineration companies know when monitoring is due to take place, and can therefore select clean materials to burn at those times.
2. There are particular times when an incinerator produces much greater quantities of dioxins than normal, namely when being fired up and damped down. This is because the temperature of the incinerator passes through a critical threshold at which dioxins are produced in greater quantities.
The United States Environment Protection Agency states in their Draft Dioxin Reassessment, Chapter 2:2 (Ref 3) of their draft report on dioxins: "Temperatures between 200° and 450° Celsius (C) are most conducive to forming CDD/CDFs, with maximum formation occurring at around 350EC. If temperature falls outside this range in temperature, the amount of CDD/CDFs formed is minimized."
Guy Heaton,SEPA, has stated that the system proposed for Binn Farm would prevent any materials being burnt at temperatures below 800°C. However, as we all know, technology is only as reliable as the human beings who make and run it.
The World Health Organisation (WHO) is so concerned about background levels of PM2.5s that they have issued guidelines this year stating that the annual mean background level of PM2.5s should be no more than 10µg/m³.
Unbelievably there is no air quality objective or standard for PM2.5s in the UK. The only standards are for PM10s, i.e. particles of less than 10 micrometers in size.
In their Environmental Statement Sita has estimated (Note 'estimated', not measured)
the background level of PM10s around Binn Farm to be around 13.6µg/m³.
Unfortunately no-one knows (or at least no-one is telling us) what proportion of these are in the PM2.5 category. If the proportion is high, it is possible that the concentration of PM2.5s in the area has already breached the new WHO limit of 10µg/m³, especially near busy roads where background levels may be considerably higher than average.
This last point was put to SEPA (the Scottish Environmental Protection Agency) on 20.11.06. They have promised to respond as soon as possible - I'll let you know when / if they do.
Incidentally the new WHO guidelines say that PM2.5s can be harmful in concentrations of just 3-5µg/m³. The same guidelines also say that PM2.5s travel from 100s to 1000s of kilometres.
References:
1.Memorandum from Environmental Health Manager to Head of Development Control - 30 November 2006, Perth & Kinross Council
2. Waste Incineration (Scotland) Regulations 2003 - Practical Guidance: Edition 2
3. Draft Dioxin Reassessment,2003, The United States Environment Protection Agency, National Centre for Environmental Assessment
4. World Health Organisation Air Quality Guidelines - Executive Summary
5. Environmental Statement, Sita - Scroll down to the bottom of PKC's Binn Farm Case File and click on the link to ENVIRONMENTAL STATEMENT VOL. 2 : (SECTIONS 8 - 15).