Warrington Clinical Waste Treatment Centre Appeal Proposed Outline Evidence of Alan Watson

33.Anxiety as a health impacts:

410. 
     Health has been defined in the constitution of the World Health Organisation since 1948 as:
     

“a state of complete physical, mental and social well-being and not merely the absence of disease or infirmity”

1. 
   In turn, the World Health Organisation’s view of health promotion is underpinned by a number of key principles including:
   

2. 
   a clear focus on the promotion of positive health, or well-being, alongside the prevention of ill health
   
3. 
   addressing the structural issues such as discrimination, poverty and unemployment, that affect our health and the choices we make, as well as focusing on the knowledge and behaviour of individuals or groups of people.
   

412. 
     The WHO holistic definition means, of course, that health affects may arise either from exposure to harmful emissions or by anxiety caused by the perception that such exposure would be harmful. This is important because even if that perception was unfounded then there could still be a health impact within the WHO definition. This sits comfortably with the conclusions of Newport discussed above.
     
413. 
     The WHO definition is the appropriate basis for establishing health impacts and has been accepted as such by the Court of Appeal¹³² subject only to the caveat that “trivial risks to a person's health should be disregarded”¹³³.
     
414. 
     Accordingly if any non-trivial risks follow from the concerns associated with the application then the concerns of the public in relation to health impact would be objectively justified. In order to assess the effects of risk perception on health a review of some of the published literature has been undertaken. Some of the salient papers are briefly summarised below.
     
415. 
     McCarron et al¹³⁴ compared the self reported health of a group of individuals living in an area contaminated by chromium (chromium group) with a group living in an uncontaminated area (control group). Their study assesses the effects of perception of risk from exposure to chromium on health and they concluded:
     

Despite the overall negative findings [i.e. that there was no direct risk to health from the chromium], the lower scores in participants who believe that chromium is harmful raises the possibility that knowledge of the history of land use may reduce generic quality of life in the absence of any documented adverse health effects.

1. 
   Roht et al¹³⁵ raised similar issues. In that study hypochondriasis (health anxiety) scores were associated with symptom reports regardless of location of residence while an individual's opinion about the hazardous site showed a different pattern by area of residence. Respondents living near one of the waste disposal sites who answered "yes" to an opinion question about their beliefs that the site was having an impact on the environment were 2-3 times more likely to report some types of symptoms than residents of the comparison community. In contrast, there was little difference in symptom reports between the exposed and comparison communities for those answering "no" to the opinion question.
   
2. 
   Shusterman¹³⁶ reviewed retrospective symptom prevalence data, collected from over 2000 adult respondents living near three different hazardous waste sites, and analysed the data with respect to both self-reported "environmental worry" and frequency of perceiving environmental (particularly petrochemical) odours.
   
3. 
   He observed significant positive relationships between the prevalence of several symptoms (headache, nausea, eye and throat irritation) and both frequency of odour perception and degree of worry. Headaches, for example, showed a prevalence odds ratio of 5.0 comparing respondents who reported noticing environmental odours frequently versus those noticing no such odours and 10.8 comparing those who described themselves as "very worried" versus "not worried" about environmental conditions in their neighbourhood.
   
4. 
   Elimination of respondents who ascribed their environmental worry to illness in themselves or in family members did not materially affect the strength of the observed associations.
   
5. 
   In addition to their independent effects, “odour perception and environmental worry exhibited positive interaction as determinants of symptom prevalence, as evidenced by a prevalence odds ratio of 38.1 comparing headaches among the high worry/frequent-odour group and the no-worry/no-odour group”. In comparison to neighbourhoods with no nearby waste sites, environmental worry has been found to be associated with symptom occurrence as well.
   
6. 
   Similarly, following the Camelford incident, where the water supply in North Cornwall was contaminated by aluminium sulphate, David and Wessley¹³⁷ suggested that the perception of normal and benign physical and mental symptoms may have been heightened by litigation, community action, self appointed experts, consumer opinion polls, media attention etc. This indicates that particular controversy in the process of an application may turn that application into a process which increases the perceived risks.
   
7. 
   McCarron¹³⁸ commented that risk is a social construct, and to reduce concern it is important to introduce more public participation into both risk assessment and risk decision making. “This makes the decision making process more democratic, improving the relevance and quality of scientific investigation and enhancing the legitimacy and public acceptance of the resulting decisions”.
   
8. 
   An issue in this case has been that the public has not felt engaged in the process of determining what is proposed for the site. This in turn will tend to amplify the concerns and anxieties.
   
9. 
   Another important aspect of anxiety is whether, and how effectively, the concerns of the public have been addressed by the developer. In this case one key example relates to dioxin monitoring where the use of an AMESA type continuous dioxin sampler, such as is used on the much smaller incinerators on the Isle of Man and in Exeter, and is required by law in Flanders, would have helped to reassure the public that the emissions of dioxins were not increased between the bi-annual 6-hour monitoring campaigns. Instead they would have seen results averaged over every two-week period. Notwithstanding this reassurance UBB has not offered to use this relatively cheap equipment for the Javelin Park incinerator. The public therefore assume that there is something to hide and their concern is increased.
   

34.

35.Non-Standard Operating Conditions

425. 
     The WRATE assessment by Fichtner¹³⁹ for the Environmental Permit Application states: “the ERF will have 10 start-ups and shut-downs per annum. Each start up will take 16 hours, and each period of shut-down will take 1 hour. The auxiliary burners will operate for 170 hours per annum”. During this time the supplementary burners will use “approximately 6,100 MWh of fuel oil per annum”.
     
426. 
     It has been clear for many years that even when no waste is loaded into the plant the emissions from combustion plants and incinerators during start-up, and to a lesser extent shut-down, are very much higher than during steady state operations.
     
427. 
     In 1986, for example, Colmsio¹⁴⁰ reported finding low levels of emitted polycyclic aromatic hydrocarbons around an incinerator during days of normal operation, in contrast to the day when cold start-up of the plant occurred. During the start-up days the polycyclic aromatic hydrocarbons levels being increased by more than a 1000-fold.
     
428. 
     There has been a range of research reviewing the dioxin emissions from incinerators during start-up periods published in the last few years¹⁴¹. It is notable that start-up periods, although a time when it would be anticipated that dioxins could be formed within incinerators from previously deposited carbonaceous deposits are never monitored with spot dioxin tests.
     
429. 
     Tejima tested a modern Japanese incinerator equipped with better dioxin abatement than UK incinerators¹⁴². It was found that even a single incinerator start-up released more dioxins to air than operating the incinerator in steady state conditions non-stop for over 2 months. Contamination levels of ash were also increased. If an incinerator was started more than four times a year the majority of the dioxin emissions are likely to come from the unregulated start-up emissions.
     
430. 
     The results from Wang are perhaps more pertinent to the technology used in the UK – such as this plant – and are more worrying. To verify the PCDD/F characteristics of incinerators during start-up a continuous MSW incinerator was investigated for two years. The elevated PCDD/F emissions of the MSWI during start-up could reach 96.9 ng I-TEQ N m³ (nearly 1,000 times the EU limit of 0.1 ng/m³) and still maintained a high PCDD/F emission (40 times higher than the Taiwan emission limit) even 18 h after the injection of activated carbon. The emissions that are released in these circumstances depends on the plant configuration – those with filter by-passes are likely to release more dioxin to air. Plants without, like this one, can have more contaminated ashes.
     
431. 
     From the four MSW incinerators they studied the estimated annual PCDD/F emission from normal operational conditions was 0.112 g I-TEQ. However they calculated that one start-up procedure can generate 60% of the PCDD/F emissions for one whole year of normal operations. Furthermore the PCDD/F emission from the start-ups of some incinerators was at least two times larger than that of a whole year’s normal operations. This was even without consideration for the PCDD/F emission contributed by the long lasting memory effect.
     
432. 
     High emissions have also been reported for other combustion upsets¹⁴³.
     
433. 
     The Application and Environmental Statement for this proposal are silent about the impacts of emissions during such abnormal operating periods. There are concerns, however, that Article 13 of the Waste Incineration Directive¹⁴⁴ allows the plant to continue operating for a total of up to 60 hours/year with abnormally high emissions¹⁴⁵.
     
434. 
     It normal continuous mode operations start-ups and shut downs would be relatively infrequent events but the Supporting statement suggests that one advantage of biomass is that plants can be used flexibly to match electricity loads. This envisages that this operation could become more common in the future with many more potential start-ups and shut-downs with more periods of unstable combustion.