Representation by Michael Anthony Hopgood
- Date submitted
- 12 November 2022
- Submitted by
- Members of the public/businesses
Having been the technical manager of a large environmental analytical chemistry laboratory with over 35 years experience in the waste sector, I have been in a position to assess the MVV documentation and the associated responses Traffic During early construction, all traffic would access the site from Wessingham Lane and along Algores Way, resulting in disruption for businesses and local traffic. There would be large numbers of vehicle movements, notably for removal of the material excavated from the site and delivery of construction materials to the site. Traffic may be re-routed via New Bridge Lane as construction proceeds resulting in increased congestion on Cromwell Road. Once the facility is operational, the number of vehicle movements per day is expected to average 350 and would take place between 7:00a.m. and 8:00p.m. MVV propose that delivery vehicles would only enter the site via the A47 and Cromwell Road and would ‘be instructed’ to avoid the centre of Wisbech. This does not address the problem of the huge increase in overall traffic to an area with an already inadequate road infrastructure. The A47, running just to the south of Wisbech is a single carriageway road, always busy and often congested, and with no published plans to upgrade this area other than in the form of possible future junction improvements. In the event of any problems such as local road works or accidents, (see transportation of bottom and fly ash below) vehicles would be instructed to follow designated detours resulting in traffic travelling along local roads many of which are unsuitable for heavy vehicles. No comments have been made of the risk that the increase of heavy lorries on Cromwell Road may pose to the ACES eye clinic, just 350m away from the site, despite concerns having been raised during initial consultations due to the high precision instruments used and the number of delicate surgical procedures carried out for NHS patients across the region. Given the uncontrolled and heterogeneous nature of domestic waste in the UK, it is likely that both the fly ash and bottom ash will contain a wide range of contaminants such as heavy metal oxides and asbestos thus creating hazardous materials where none existed in the feedstock. The ash, some 165,600 tonnes of bottom ash waste / year and 31,280 tonnes / year of APC waste (fly ash), would be transported by road for disposal at facilities licensed to take hazardous waste, or to docks for disposal abroad. Any accidents involving transportation of these materials would be a serious incident which could risk harm to human health. MVV have not made known there preferred route of disposal for the large amount of hazardous and possibly special waste. Greenhouse Gas Emissions The process will produce huge quantities of carbon dioxide which will be pumped into the atmosphere. Carbon capture and storage, which the 6th Climate Budget assumes will be incorporated on all Energy from Waste projects, will not be adopted as part of the project when operations begin. The MVV proposals state that an area of land has been aside for future carbon capture and storage but are not currently considering including it in the project. The large number of transport movements to and from the site over long distances will also create a huge carbon footprint which is incompatible with UK emissions targets. Air and surface pollution Some contaminants such as PFOA and PFAS (forever chemicals) used in water proofing clothing and as a fire retardant in household fabrics and together with persistent organic pollutants (POPs), such as halogenated POPs need considerably higher temperatures (up to 1400°C) for destruction than the minimum working temperature of 850°C. Work done by the EPA has indicated that even at these higher temperatures, PFOA and PFAS can break down to form small chained organic molecules, because of the highly reactive nature of the fluorine radical. Some of these molecules are known to be carcinogens and could be emitted to the atmosphere by the plume. While MVV will carry out testing for pollutants in the flue gas as required by current EA guidelines, no consideration has been given to checking for breakdown products in from pollutants such as PFOA. Three of the nine schools in Wisbech would be close to the incinerator which is of particular concern as children are considered to be the most vulnerable receptors to air and surface borne contaminants. The rural areas surrounding the incinerator are given over mainly to food production with a large number of drainage ditches and water courses of varying sizes and types close by. The construction of the incinerator and its subsequent operation could present a risk of pollution to the food chain and to nearby bodies of surface water, which could harm the environment and human health. Light and noise pollution As the site is to be operational 24 hours a day, there will be both noise and light pollution which will affect residents day and night across a large area of Wisbech and surrounding villages.