Latest Flier: November 2024. Thanks to Phil and Haz for the front image and John Davies for the 3 mile radius image.
Garston – The View of an Expert
Below is the view of someone who has worked in the industry and has specialist knowledge.
This is a solvent recovery plant, as you observe. I suggest that its location is all about minimising transport costs by collocating where the Irish waste is delivered and not at all about a precautionary approach to human health. This type of plant is normally located at remote locations already in use for chemical production or petrochem refinery, such as the Runcorn plants or around Bellingham in the NE.
One reason is that these plants always leak a bit and always smell a bit. VOCs are Volatile Organic Compounds and, as the name suggests, they are volatile and difficult to contain completely. A small proportion get through the scrubbers, however good they are. As the plant ages tiny leaks will appear and discharge until found and fixed. Then there are plant outages, e.g. electric or mechanical failures reducing scrubber efficiency etc. Then there are spillages associated with transfer of waste to plant and product to tanker. The comment on wet patches could be telling. Discreet observation of the night shift might be interesting.
For all the reasons above and the constant possibility of human error such plants should be located well away from human habitation, schools etc. The days when we expected people to live in the shadow of the polluting factory, coal mine etc. are supposed to be over.
I don’t know the process in use here or the particular cocktail being refined. But it is likely that the (probably very small) amount of contaminant removed during refinement is pretty nasty and very smelly. It will be long chain organic compounds which are often highly odorous at very tiny concentrations. The long chain also means that they attach and hang around our bodies, clothes, airways, not to mention the washing in the line. These too have to be contained and then disposed of, probably by Veolia’ high temperature incinerator, conveniently located at Ellesmere Port.
I had a look at Veolia’s application and read through the Air Quality Assessment of consulting engineer Fichtner. This is available via the EA website and is a publicly accessible part of the application. Various things struck me:
1. The impact of the development on air quality has to be modelled against the background levels. These are taken from a mix of Government and Local Authority (LA) data plus background monitoring at specific nearby location, undertaken by consultants employed by Fichtner. The data was collected in a period affected by COVID lockdown. Fichtner proposed to take account of the lower level of traffic and other activity in lockdown by adjusting the data. They say “appropriate weight has been given to the monitoring results”. It was all agreed with the LA’s Environmental Health Officer (EHO) and the report includes correspondence on this matter with the EHO as an appendix. I don’t like this: giving yourself a more favourable background than the data you actually collected goes right against the precautionary principle that is supposed to be exercised.
In addition they do not seem to have included in the report any numerical values for the assumption they made, either as ratios or plain figures. The EHO’s email is included saying he/she approves of the “appropriate weight” but I could not spot anywhere in the report what this “weight” was or what background levels Fichtner had actually used.
This info is from Para 2 of the summary and the appropriate chapters of the main report and the appendices.
2. This application is for two new things: a scrubber stack serving new distillation columns and a pair of new steam boilers. The minuscule amounts of very nasty (and highly odorous and noxious) things will be coming out of the scrubber stack rather than the boilers. Fichtner states (Para 3 of the summary but see also the main body of the report) that “the emission rate of pollutants from the new scrubbers is expected to be very small”. They argue that they used the EA’s H1 EIA tool and showed that the predicted concentration is extremely small and the inclusion within the wider dispersion modelling would not significantly the results and “as such, it is not necessary to consider the new scrubbers within the detailed dispersion modelling”. In other words they have excused themselves from using their carefully collected data to run the dispersion modelling for the scrubber emissions. To be clear, in the assessment there is no quantitative modelling of the effect on the identified sensitive receptors of the main potential source of health-affecting emissions. I really don’t like this and neither should the good folks of Garston.
3. I should look at this more closely but I also did not like the methodology for identifying sensitive receptors (Para 3 of the summary). Fichtner quote some EA orthodoxy but I note that this identifies things like the facade of a building facing a road and footpath but excludes, for instance, gardens. I recalled what you said about residents not being able to put their washing out in the garden because of odours.
4. This type of assessment is about effects on human and environmental health and does not consider odour. The odour from the types of VOCs etc emitted despite the action of the scrubbers is noxious and detectable by the human nose at incredibly low levels. Moreover the molecules responsible are long-chain and literally clingy – to your hair, your clothes (both those you are wearing and those on the washing line) and to your very nostril hairs. The smell stays with you. Two points here: somewhere in the application there should be consideration of the odour impact on the amenity of residents. I could not spot any other report considering this but I did not look exhaustively. There is a common sense point here: if it has been established that the plant already causes seriously bad odours that, for instance lead residents to shut up their windows to keep it out and deters them from using their gardens any additional plant can only make it worse.
If a bad record of odour nuisance has not been established the residents need to get complaining. If the residents are serious they should (1) request a local liaison committee is set up, with attendance by the company, residents and ideally a councillor and the EHO, to meet regularly and review performance. If it is bad they should get the EHO and company reps prepared to be called out to come and stand in their garden (or wherever) when things are bad and experience it for themselves. 2. Complain, complain, complain to the EHO and company. 3. Keep odour diary – especially useful if there is pattern of bad times that can be associated to certain plant operations, such as cleaning or start-up after maintenance.
Odour impact is another reason why Fichtner should not have been allowed to excuse themselves form modelling the dispersion of the scrubber emissions. It would give a quantitative prediction of VOC concentration at the sensitive receptors. There is no simple reaction between odour and molecular concentration but at least you would have something to refer back to if odour problems arise and, for instance, get monitoring instigated to check whether the real-life concentration are anything like what was modelled.
5. The accepted methodology of this type of report is to consider modelling against both an annual average concentration and a peak (I think one-hour) concentration. This sounds sensible and after all you have to have a framework. But it has at least two disadvantages. Firstly, the annual value is a kind of pollution allowance and statistically you can keep inside that allowance with an awful lot of one-hour higher blips that are below the peak value allowed, so exposure to quite high concentrations might be frequent. Secondly, this is all just modelling to consider a theoretical impact. What if in practice, as dictating by real-life plant operations, the blips are ten or a hundred times the concentration represented by the allowed peak value in the modelling? This can of course only be detected by monitoring during operations but if such monitoring shows that real life is nothing like the impacts modelled the plant should be subject to EA or EHO enforcement to improve, if it can. I guess all I am saying here is that we can be seduced by the modelling assumptions to treat them as if they are what is actually happening or likely to happen and overlook the fact that in real life operations can be many, many times worse than what has been modelled.
That was a bit long-winded but hey! I feel sorry for the residents because as I said before I believe that such a plant should not be in that location at all. I can imagine that on a murky, misty still morning by the Mersey there, with a an atmospheric temperature inversion fully developed, the concentrations of nasties at ground level could be considerable.
Campaign pack PDF download
POLITICS & PREJUDICE
Supporting material from the L19 Action Group
L19 Action Group is a local residents and supporters group campaigning for better health in Garston through cleaner air and water.
Garston has some of the worst health in Liverpool. We are local residents and supporters, and are campaigning to make it better. We call on other residents, Councillors, Environmental Health and Public Health to work with us.
Contents:
1) Maps: 3 mile radius from Veolia’s Chemical processing works + detail of Garston from the Liverpool Local Plan policy map (2013-2033)
2) Increased Risks to our Community: Hazardous chemical waste
3) Health Statistics in Liverpool
4) Increased Risks to our Community: PFAS – ‘Forever Chemicals’
campaign pack front cover PDF download
3 Mile radius from Veolia’s Chemical processing works Garston in South Liverpool
campaign pack p2 PDF download
campaign pack p4 PDF download
Increased Risks to our Community: PFAS – ‘Forever Chemicals’
‘Forever Chemicals’ in the River Mersey are amongst the highest in the world.
“We know PFAS are everywhere” says Patrick Byrne, a researcher in hydrology and environmental pollution at Liverpool John Moores University, who published his study in February 2024 showing cancer causing PFAS in the River Mersey had one of the worst levels recorded globally for a river basin. On the 6 March the Financial Times published an extensive article on the LJMU study.
A separate study at the University of Birmingham confirms PFAS are absorbed through human skin. Published in June 2024 the research of 17 commonly used synthetic ‘forever chemicals’ showed these toxic substances can readily be absorbed through human skin.
Effects of PFAS on Human Health source: Royal Society of Chemistry
This diagram shows the variety of serious health hazards associated with PFAS exposure. These chemicals have been found in human bodies around the world and given that PFAS take so long to degrade, this could lead to intergenerational problems.
Image from European Environment Agency: Emerging chemical risks in Europe – ‘PFAS’
Acceptable levels of PFAS in drinking water
The Royal Society of Chemistry (RSC) are calling on the UK Government to overhaul its drinking water standards after new analysis reveals more than a third of water courses tested in England and Wales contain medium or high-risk levels of PFAS.
While ‘Forever Chemicals’ can be filtered out of drinking water, UK water companies are not required by law to reduce them until they are deemed ‘high-risk’.
New PFAS limits in drinking water are needed to protect our health – write to your MP.
campaign pack p5 PDF download