18 February 2005
Planning Officer
Wrexham County Borough Council
Lambpit Street
PO Box 1290
Wrexham
LL11 1WL
Dear Mr
On behalf of Tilston Parish Council and the residents of Tilston I am writing to ask you to oppose the
proposed change of use to materials recovery and energy centre including treatment by pyrolysis and
gasification and combustion to generate electricity and erection of 1 x 30m and 2 x 15m stacks at the former
site of Owens Corning, Bryn Lane, Wrexham Industrial Estate Wrexham.
I believe that the siting of such a facility would be to the detriment of the residents of Tilston and those in a
substantial area surrounding the proposed facility for many reasons including the possibility of emission to
atmosphere of dioxins and other pollutants which may be produced by the burning process. Although the
Pyrolisis process which may be used at the facility is claimed to produce the lowest amount of emissions, I
would like to emphasise that Pyrolisis, for all its claimed benefits, is regarded by expert opinion as an untried
and untested method and that it really should be should be subject to independent testing and verification in
practice before being located near to a resident population, given that there could be a health risk, however
slight that may be and slight health risks are acknowledged by environmental health officers. Any other form
of incineration should be ruled out because harmful emissions are higher. This matters to residents of Tilston
because we are downwind of the proposed site and being on rising ground in relation to the proposed site,
Tilston could be in the area of fall out of harmful pollutants. As an agricultural community, particularly dairy
agriculture, the worry is that dioxins which are bio-accumulative could enter the food chain. Also particularly
at risk from dioxins would be pregnant mothers-to-be and their unborn children. Once dioxins enter the body
they never leave. The emission of Dioxins has a particularly profound effect on foetus/embryos of unborn
babies. There were 17% more spina bifida rates and 12% more heart defects in babies living near an
incinerator. On top of the dioxin output other nasties such as polycyclic aromatic hydrocarbons (PHC's) and
one of the worst, hexavalent chromium can be released as by-products from incineration.
Listed below are several other points we would ask you to consider;
1. Several villages within Chester District are close to the proposed plant and the
health of their residents and the safety of its agricultural output could be affected
by its environmental impact. Although wind direction varies and a wide area could be
affected the prevailing wind is towards these villages, where there is a significant
resident population, some 3000 children are educated here and some 60 dairy farms
and firms operate. We are concerned that data exists in relation to existing incineration
plants to show an increased incidence of serious adverse human health impacts in
areas close to incinerators and that dairy units downwind have had to be closed on
safety grounds, while it is claimed by others that such impacts would be slight. What are
we to believe? We are further concerned that this proposal might blight the Wrexham
Industrial Estate leading to the eventual departure of its food processing firms and
perhaps their replacement by dirtier industry, which would make the problem of pollution
worse.
2. We question whether the solution proposed is the best practicable environmental
option. Incineration appears to form a high proportion of the method of dealing with the
waste input to this scheme and it includes a significant amount of paper, plastics and
textiles, which might otherwise be recyclable. We are therefore concerned that the
proposed Thermal Treatment Unit may be larger and emissions of toxic pollutants to air
and water greater than they could reasonably be limited to if greater priority had been
given to both minimising waste and re-using and recycling it. We are also concerned
that the creation of this plant will at a stroke freeze planned recycling levels and remove
the possibility of increasing them at a later date when markets for recyclables may have
developed and the public’s participation may have otherwise increased.
3. We cannot rely on the environmental data that have been submitted. We believe
the data should be subject to impartial, independent, expert assessment in practice
before being accepted. While the process of Pyrolisis and gasification may offer some
environmental benefits it is relatively new and is considered by experts to be untried
and untested. Much of the data presented is theoretical rather than based on
experience in practice. Much of the technology for monitoring and measuring critical
elements of the emissions is not yet in existence or can only be carried out occasionally
– such as that for dioxins. If the plant were to be approved and that data were
acceptable it would be necessary to have continuous, real-time monitoring of all
elements of emissions, publicly available at all times, in order to satisfy residents that all
is safe. The meteorological data on which air quality forecasts have been modelled are
based on Shawbury, many miles from the proposed plant, whose local climate and local
terrain may vary significantly. Furthermore we cannot be sure that Compact Power and
the system of Pyrolisis and gasification will be the system finally chosen for the site or
that some other system, including the possibility of mass burn incineration, will be used.
HLC have indicated that they will select from three alternative firms who are being
considered for this part of the plant.
4. We are concerned that the risks of mechanical, system or human failure or the
loss of performance over time have not been taken into account. The figures
appear to have been based on optimal working throughout the plant’s lifetime. However
we know that HLC have suffered a major plant failure causing a fire at their Neat Port
Talbot plant, over which the Environment Agency have had to initiate punitive action.
We are aware that other failures have occurred at other operators’ plants and that as
plant gets older and more worn its efficiency declines. Thus we are concerned that
there might be an emergency causing a sudden increase of pollution and that there
might be a gradual worsening of pollution over time, losing any claimed advantages of
Pyrolisis and causing worse health impacts and environmental harm than might be
claimed.
5. We are concerned that although benefits are claimed by using waste to generate
electricity truly renewable energy technology is not being pursued. Much of the
energy generated will be used to run the plant and much energy will be created by
burning otherwise recyclable paper and plastic. Other more renewable sources such as
wave power offer better prospects for reducing the impact of CO2 emissions.
6. We are concerned that the plant may, both initially and in due course, serve a
wider area than Wrexham. Not only would this contradict the proximity principle in
relation to the management of waste but it could lead to greater use of roads in our area
for heavy goods vehicles. There appear to be no proposals for dealing with the extra
traffic serving the plant, either in the form of adequate access roads to the Industrial
Estate or in a traffic management plan. We consider it essential to prevent additional
HGV’s using the A534 through Cheshire in view of its inadequate nature and its
accident rate as one of the most unsafe roads in the country and that that this would
have to be enforced by a traffic management plan which would also ensure that only
waste sources in the Wrexham district are accessed.
The Tilston Parish Council therefore recommends that Wrexham County Borough Council objects to the
planning application for the proposed Wrexham Waste Resources Centre.