On hearing that the Environment Agency in Nottingham had decided to grant a licence for the third line at Eastcroft Incinerator I wrote asking the Agency to confirm that measures were in place to ensure that this would not pose a risk to air quality. Here’s their reply.
My original letter is attached together with the reply to it I received last week. You should read the Agencies’ response within the context of the “Standard Notice for the Supply of Agency Information” which was attached to their response. In particular you should note para 4 of these notes, which states: -
“The Environment Agency cannot ensure and therefore gives no promise that the Data in its possession will always be accurate, complete, up to data or valid”
I leave you to make your own interpretations…….
15th December 2005
Dear Sir/Madam
In light of your recent decision to grant a licence for the third incinerator at Eastcroft in Nottingham can you please confirm on what basis the Environment Agency is certain that this plant will never exceed prescribed limits for the emission of airborne pollutants. Could you please also provide me with details of the measures that the Agency has agreed with the operators, WRG, have and will be taken to prevent repetitions of the plant’s previous breeching of pollution limits.
With thanks for your cooperation in this matter.
Yours faithfully
12 January 06
Dear Sir,
Request for information - Eastcroft incinerator.
I refer to your fax received on 15th December 05 requesting information relating to the above.
The frequency of breaches of emission limit values at Eastcroft is not high. In 2005, there were six hourly periods (out of over 6000 operating hours in the year) when the emission limit for carbon monoxide was exceeded, with a negligible environmental impact. The majority of these breaches arose as a result of modifications to the combustion control system undertaken by the Operator in anticipation of the more stringent controls applicable under the new permit. Two breaches arose as a result of separate boiler tube leaks on either incineration line.
The only other breach of limits recorded in 2005 was an exceedance of the dioxin limit recorded on Line 2 by the Agency's monitoring contractors, which showed a reading of 0.9 ng/m3 compared to a limit of 0.1 ng/m3. This result was entirely out of step with the recent history of dioxin measurements at Eastcroft which usually records concentrations comfortably below the limit. This breach is considered to have caused no significant effect since in the case of dioxins we are interested in long term build up of dioxins in the body (lifetime average intake) and as such short term fluctuations in emission concentrations have little or no effect on the dioxin uptake assessment.
The new permit contains stringent emission limit values which all incinerators across Europe are now expected to achieve. Eastcroft incinerator is considered to be capable of achieving these emission limit values, otherwise the Agency would not have granted a permit to WRG for this plant.
The Agency does not expect the plants it regulates to routinely breach their emission limit values and would take firm enforcement action if this were the case. However, occasionally exceedances can occur for a range of reasons. The Agency makes an assessment of each and every breach of limits recorded by the plant and determines the appropriate course of action in accordance with our published Enforcement and Prosecution Policy. This includes agreeing or imposing appropriate measures on the Operator to prevent a recurrence of the circumstances which led to the breach.
It must be understood that the information provided above is based on records and files from varying sources and of varying reliability. Consequently, we are not able to offer any warranty as to the accuracy or completeness of the information provided nor can we accept any liability whatsoever for any loss or damage arising from the interpretation and/or use of the information.
A site investigation has not been carried out in relation to your request for information. This information is provided subject to the enclosed notice.
Yours sincerely,
Keith Tivey
Team Leader, External Relations
Direct dial 0115 846 3691
Direct fax 0115 846 2681
Direct e-mail
LTCCandA@environment-agency.gov.uk
Environment Agency, Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5FA Customer services line: 08708 506 506
Email: enquiries@environment-agency.gov.uk www,environment-agency.gov.uk
“The Environment Agency cannot ensure and therefore gives no promise that the Data in its possession will always be accurate, complete, up to data or valid”
I leave you to make your own interpretations…….
15th December 2005
Dear Sir/Madam
In light of your recent decision to grant a licence for the third incinerator at Eastcroft in Nottingham can you please confirm on what basis the Environment Agency is certain that this plant will never exceed prescribed limits for the emission of airborne pollutants. Could you please also provide me with details of the measures that the Agency has agreed with the operators, WRG, have and will be taken to prevent repetitions of the plant’s previous breeching of pollution limits.
With thanks for your cooperation in this matter.
Yours faithfully
12 January 06
Dear Sir,
Request for information - Eastcroft incinerator.
I refer to your fax received on 15th December 05 requesting information relating to the above.
The frequency of breaches of emission limit values at Eastcroft is not high. In 2005, there were six hourly periods (out of over 6000 operating hours in the year) when the emission limit for carbon monoxide was exceeded, with a negligible environmental impact. The majority of these breaches arose as a result of modifications to the combustion control system undertaken by the Operator in anticipation of the more stringent controls applicable under the new permit. Two breaches arose as a result of separate boiler tube leaks on either incineration line.
The only other breach of limits recorded in 2005 was an exceedance of the dioxin limit recorded on Line 2 by the Agency's monitoring contractors, which showed a reading of 0.9 ng/m3 compared to a limit of 0.1 ng/m3. This result was entirely out of step with the recent history of dioxin measurements at Eastcroft which usually records concentrations comfortably below the limit. This breach is considered to have caused no significant effect since in the case of dioxins we are interested in long term build up of dioxins in the body (lifetime average intake) and as such short term fluctuations in emission concentrations have little or no effect on the dioxin uptake assessment.
The new permit contains stringent emission limit values which all incinerators across Europe are now expected to achieve. Eastcroft incinerator is considered to be capable of achieving these emission limit values, otherwise the Agency would not have granted a permit to WRG for this plant.
The Agency does not expect the plants it regulates to routinely breach their emission limit values and would take firm enforcement action if this were the case. However, occasionally exceedances can occur for a range of reasons. The Agency makes an assessment of each and every breach of limits recorded by the plant and determines the appropriate course of action in accordance with our published Enforcement and Prosecution Policy. This includes agreeing or imposing appropriate measures on the Operator to prevent a recurrence of the circumstances which led to the breach.
It must be understood that the information provided above is based on records and files from varying sources and of varying reliability. Consequently, we are not able to offer any warranty as to the accuracy or completeness of the information provided nor can we accept any liability whatsoever for any loss or damage arising from the interpretation and/or use of the information.
A site investigation has not been carried out in relation to your request for information. This information is provided subject to the enclosed notice.
Yours sincerely,
Keith Tivey
Team Leader, External Relations
Direct dial 0115 846 3691
Direct fax 0115 846 2681
Direct e-mail
LTCCandA@environment-agency.gov.uk Environment Agency, Trentside Offices, Scarrington Road, West Bridgford, Nottingham, NG2 5FA Customer services line: 08708 506 506
Email:
enquiries@environment-agency.gov.uk www,environment-agency.gov.uk