Preferred Options consultation document

Object

Representation ID: 98319

Received: 30/10/2019

Respondent: Kings Lynn Without Incineration (KLWIN)

Kings Lynn Without Incineration (KLWIN) was formed as a broad-based organisation dedicated to the defeat of the Willows waste incineration plant proposal at Saddlebow Kings Lynn. Notwithstanding the victory over that scheme, KLWIN remains an active organisation to this day and retains its opposition to incineration at any location in Norfolk.
KLWIN wishes to express its opposition to the inclusion of incineration in the relevant residual waste sections of the Preferred Options Document. (W10,WP10). In acknowledgement of the human and other resources demands upon the Authority of taking the Minerals and Waste Plan to completion and approval KLWIN has chosen not to activate its membership base to inundate the consultation process with repetitive versions of our case. We hope that our case rests on its technical merits rather than in force of numbers.
Incineration
KLWIN takes incineration to include all processes, technologies, and plant designs which thermally 'treat' residual waste and require a stack for the discharge of some or all of the thermal treatment by-products. The term stack is used in the normal understanding of the word as being a structure raised above the level of the surroundings and intended to emit and disperse solids, vapours and gases (in this case some or all of the by-products of the thermal treatment of residual waste). KLWINs definition of incineration therefore includes processes which may be referred to by other names including but not restricted to gasification, pyrolysis, advanced thermal treatment, CHP etc.
The need for a stack is the defining feature of those approaches to residual waste treatment that KLWIN does not wish to see adopted in the M&W Plan.
KLWINs Objections
It should be noted that a full, referenced technical discourse on the dangers posed by thermal treatments of waste is not possible or appropriate in such a consultation opportunity. KLWIN has set out a few key issues to illustrate the rational of its objections to thermal treatment.
It is KLWINS position that any process of thermal waste treatment that employs a stack will be producing particulates especially pm 2.5s which are increasingly recognised as of clinical concern over a wide range of health issues which are almost daily attracting attention as being of public health concern. Currently vehicles and wood burning stoves are the pm 2.5 sources attracting the most attention.

What is unique about thermal treatment however is that the pm 2.5s attract dangerous contaminants from the waste e.g. cadmium, arsenic, lead, dioxins, furans etc. The benchmark study of incineration particulates by London University intended by the Public Health England to provide reassurance to the public only studied the larger pm 10 particles which are medically of little concern. Assurances by operators and filter manufacturers regarding their efficiency for retaining pm 2.5s is based upon the mass of particulates captured not the numbers of particles. The results are therefore biased by the disproportionate capture rate of the much larger higher mass pm 10s!
Stacks also emit CO2 with its well-established capacity to contribute to global warming and the myriad problems associated with it and its risk to our legal and moral obligations to reduce such risks. Oxides of Nitrogen are invariably generated by combustion processes and figure repeatedly as key components in air quality control zone problems. The impact of these gases upon human health are well documented and are growing in the UK. While public health concerns do not carry much weight in planning decision making the Minerals and Waste Plan provides the opportunity to avoid these issues by omitting their causes at this formative stage. Residual waste thermal treatment plants are point sources of atmospheric pollution which impact downwind populations and environments. KLWIN does not think that any communities should be exposed to the unique, complex mixtures of dangerous gases, particles, compounds or elements they produce regardless of the efforts to filter or neutralise them.
These effects are not restricted to human residents, agricultural crops & livestock the vegetation and wildlife of our countryside and nature reserves are not immune from damage. Some of the contaminants are as dangerous as they are chemically stable. Dioxins have no safe minimum expose level for humans yet can remain and accumulate in the soil and living tissues for years.
Thermal treatments compete with recycling technologies for resources. Advocates of thermal treatments may claim it is only for waste that cannot be recycled but in practice recyclable materials are often subjected to thermal treatments. Long contracts linked to a minimum tonnage of waste for treatment is a typical scenario which can put pressure on parties to use recyclable materials to avoid contractual penalties.
Conclusion
KLWIN oppose the inclusion in the Minerals and Waste Preferred Options Document of any thermal residual waste treatment approaches that include a stack or stacks in the facilities design and operation. Such treatments pose unacceptable risks to human and environmental health and wellbeing and can compete with recycling.