€40m project covers only one of several legacy sites on Cork Harbour island
THE PROPOSED €40 million remediation plan for Haulbowline Island i n Cork Harbour will address only a former dump known as the East Tip, and will not address similar, legacy sites containing industrial pollution on the island, it has emerged.
Cork County Council has said it would welcome a “Tier 1” risk assessment of the main steelworks site and another legacy dump, known as the South Tip.
But the council said it did not own the sites and had “no authority to intervene”. Steel was produced on Haulbowline between 1939 and 2001 and waste from the process was dumped first at the South Tip and from the 1960s at a sand bar which became known as the East Tip.
Last week, Cork County Council unveiled an ambitious plan to “cap” the East Tip in a remediation plan which could cost up to €40 million. The council had been asked by Minister Simon Coveney to put together the plan.
However Friends of the Irish Environment expressed dismay that the plan will only cover the East Tip and not address issues of legacy pollution at the South Tip or the steelworks site.
The group quoted from a 2001 report from consultants Enviros Aspinwall to the effect that there was “on the main [steelworks] site, a high risk to humans from PCB spills; a high risk to marine ecosystems from metals from dust; high to moderate risks to humans from wind–blown dust; high to moderate risks to human intruders from radioactive contamination; a moderate risk to site workers from metals in the building interiors; and high risks to groundwater from hydrocarbon process and storage spills . . .”
In response, Cork County Council’s project manager Cormac Ó Súilleabháin said he would welcome a risk assessment at the other sites. But he said the project the Government had asked the council to oversee was site–specific to the East Tip. Dr Ó Súilleabháin said the council was “aware of the contaminant issues pertaining to the site of the former steelworks” and some of these issues had been listed on the project website.
He said the council would welcome the clean–up of the site “but it must be acknowledged that the council does not own the site nor does it have any authority to intervene”.
Dr Ó Súilleabháin said in 2009 the case of the East Tip was joined to a European Court of Justice case which ruled that Ireland had infringed the Waste Framework Directive by persistently failing to fulfil its obligation to fulfil various articles under that directive. He said the South Tip was not included because the dumping there had taken place prior to the 1977 creation of the directive.
Dr Ó Súilleabháin said it was hoped “a Tier I risk assessment of this site could be undertaken at some stage in the near future” but he cautioned that “this would be dependent on the availability of resources”.
22 Oct 2012
The Irish Times
The "International Review of Waste Management Policy", published in 2009 with 65 Annexes, the largest waste policy study ever undertaken in Ireland, at significant cost to the taxpayer, by an international consultancy is effectively ignored in the consultation document.
Also disregarded as is the work done by the Department of the Environment on implementing the 24 Recommendations of the International Review leading to consultation by the Department on a 2010 Draft Statement of Waste Policy only a year ago.
The new document also substantially downgrade references to sustainability. A spokesperson for FIE said: "It appears that sustainability is not considered to be the fundamental conceptual foundation of waste policy. In the context of Ireland's international commitments to sustainable development and the government's stated intention to integrate sustainability into all policy areas this is inexplicable."
Truly astonishing, however, is the absence of any reference in the Discussion Document to human health. The protection and promotion of human health was a key objective of both the International Review and the 2010 Draft Statement of Waste Policy. There is no reference in the new document to human health.
A spokesperson for FIE said: "The impact of waste facilities on public health has been a major public concern in Ireland over recent years. The public concern has been fed and substantiated by instances such as the evacuation of houses due to landfill gas infiltration. The concern was recognised by the Department of the Environment which commissioned a literature review, published in 2003, on the "Health and Environmental Effects of the Landfilling and Incineration of Waste". It is shocking that Minister Hogan apparently thinks that waste policy can ignore the impact of waste facilities on human health."
Consultations on A New National Waste Policy Discussion Document 2011 closed Friday 30th September 2011.
In 2008 an international consultancy was contracted by the Department of the Environment, Heritage and Local Government (as it then was) by open competition to carry out a review of Irish waste policy. It was a major study at significant cost to the taxpayer and is by far the most detailed piece of waste policy research carried out in Ireland. It involved detailed analysis and consultation with stakeholders and interested parties. The results were published in September 2009 as a voluminous"International Review of Waste Management Policy", made up of a Summary Report and 65 Annexes. It made 24 key Recommendations.
In Autumn 2010 a Draft Statement of Waste Policy was published for consultation, based on that Review and setting out how most of the Recommendations found in the Review would be implemented. It appears from the departmental website that 72 submissions were received, many of which were quite detailed.
The Policy-making Process
The current consultation document "Towards a new National Waste Policy Discussion Document" deals with the above process as follows:
Existing waste policy was the subject of review over the past number of years, including the preparation of a report by international consultants. Many in the waste and resource management sector have indicated that the review process has led to a level of uncertainty which in turn has hampered investment in the sector.
A previous public consultation on a draft statement of waste policy received over 70 contributions from a wide range of stakeholders on an equally wide range of waste management issues; those views have been considered in the development of this paper.
Surprisingly while 9 other documents are referenced in footnotes to the Discussion Document, no reference is given for either the International Review or the Draft Statement of Waste Policy.
Rational and successsful policy-making requires that all relevant matters are taken into account. The significant Recommendations made by the Review deserve to be the subject of explicit decisions. If the Department/Minister/Government is now rejecting them, it should tell us why. Respondents to this consultation are likely to recommend, for example, the setting of residual waste targets or a residual waste levy. However, these recommendations have already been made to the Department by its' consultants and we have no idea why they are not mentioned in the current document. Proper consultation in this context requires a dialogue wherein the results of previous policy development work and previous consultations are made clear to all concerned.
The versions are strikingly different.
The first fundamental change which is evident is a reduction in clarity. We urge tha tguiding principles should be set out as clearly and discretely as possible. To state that "[t]he policy will be consistent with the cornerstones of National and European policy, including the waste hierarchy, the principle that the polluter pays, sustainable materials management and the urgent imperative to reduce greenhouse gas emissions" is to run a number of distinct considerations together and, worse, to effectively state that there are further guiding principles which are unenunciated; if the policy is indeed to be consistent with the cornerstones of policy, it has to be possible to state what those cornerstones are.
Aside from the reduction in clarity there are two changes which jump out.
The first is the absence of any reference in the Discussion Document to human health. This is truly astonishing. The impact of waste facilities on public health has been a major public concern in Ireland over recent years. The public concern has been fed and substantiated by instances such as the evacuation of houses due to landfill gas infiltration. The concern was recognised by the Department of the Environment which commissoned a literature review, published in 2003, on the "Health and Environmental Effects of the Landfilling and Incineration of Waste". In addition, the recent EPA Review recognises the inadequacy of the EPA's handling of human health issues, including in relation to waste licensing, and the EPA is now seeking to remedy this acknowledged defect. In that context it is astonishing that a Discussion Document on waste policy should now seek to disregard human health issues.
We believe both of these to be grave mistakes. We strongly urge that the Government puts sustainability at the heart of waste policy and that it fully integrates the protection and promotion of human health as fundamental objective of environmental policy including waste policy.
We also urge that the guiding principles be set out as clearly and discretely as possible. To state that "[t]he policy will be consistent with the cornerstones of National and European policy, including the waste hierarchy, the principle that the polluter pays, sustainable materials management and the urgent imperative to reduce greenhouse gas emissions" is to run a number of distinct considerations together and, worse, to effectively state that there are further guiding principles which are unenunciated; if the policy is indeed to be consistent with the cornerstones of policy, it has to be possible to state what those cornerstones are.
Policy initiatives/ recommendations
We cannot improve on the 24 recommendations from the International Review. The Department has already considered the practial aspects of the implementation of these recommendations in preparing the Draft Statement of Policy issued last year.
Democracy and Accountability
Some additional issues are raised in the Discussion Document, in relation to accountability and democratic control. We strongly urge that the administration of waste management be subject to full democratic accountability and full transparency. This has been far from the case in the recent past. Local authorities have hidden behind claims of commercial secrecy and have not acted in accordance with the wishes of local people and their elected representatives.
Lock-in and "no regrets" policy-making
Excessively high waste generation predictions, based on assumptions that waste generation increases infinitely and that prevention and minimisation is impossible, risk leading to over-investment in waste infrastructure. In the worst scenarios, as with over-sized incinerators such as that proposed for Dublin, they risk leading to a lock-in to inferior waste management options, low on the hierarchy, contrary to the requirements of the waste hierarchy. National waste policy must recognise this and set out to prevent it. The residual waste targets and levy recommended in the International Review are good policy responses. If they aren't being adopted, it would be important to know why and to set out alternative policies
We welcome the statements in the discussion document about increased producer responsibility. However this needs to extend to fundamental changes to the sustainability of production and consumption patterns.
DoEHLG, 2010, Draft Statement of Waste Policy http://www.environ.ie/en/Publications/Environment/Waste/WasteManagement/FileDownLoad,23397,en.pdf
Hogg, D, et al., 2009, International Review of Waste Management Policy: Summary Report and Annexes
FIE is publishing a Report commissioned by the Department of the Environment about Haulbwline Island which the Department received in September 2008 - belying the Minister's promise ‘to be as transparent as possible' and to place ‘relevant and accurate information in the public domain to counter the misinformation being circulated'.
A spokesman said ‘White Young Green's conclusion was the ‘concentrations of contaminates' was not high enough ‘to transport to potential receptors'. This report shows that in fact some concentrations of heavy metals analysed exceed the recent White Young Green Report by more than 1,000,000%.
FIE is today publishing a Report about the industrial legacy of contamination at Haulbowline with more than 20 photographs, including those of waste being buried on the island during the 1990s.
A companion ‘Briefing Document' contains analysis of Reports, documents, and emails relating to dumping on the island 1974 - 2008. The Briefing Document includes the laboratory results from testing of the surface of the site during 2008 and of the hazardous waste exported to Germany 2007 - 2008.
The results in these tests make it clear that the levels of heavy metals on the East Tip of Haulbowline Island are many times the DIV [Dutch Intervention Values] and far, far, far in excess of what Irish law permits or what the Department of the Environment has revealed.
The Department of the Environment told the Irish Examiner last week that ‘The contractor may have sent them but we cannot locate them [NRGE Report]'.
We add to our BRIEFING DOCUMENT a 28 August 2008 letter from the Department acknowledging the delivery of the Safety File confirming ‘Section 4 contains a report by a NRGE Engineer'. It also refers to section 5, ‘Shipping Analysis Reports by Ships.'
The Department must stop the cover-up now and release these test results, which show levels of contamination far far far beyond anything suggested by the figures released to date by the Minister.
Cork County Council has used ‘cabinet confidentiality' to refuse FIE their technical reports and in internal communications relating to the ongoing clean up of the Irish Steel site on Haulbowline Island, County Cork.
The steelworks occupied 11 ha of the central portion of the island and 9 ha known as the East Tip. Almost all has been created by infill and is subject to tidal influence. While 100,000 tons of contaminated soil has been exported in 41 shiploads to Germany for treatment to date, almost 500,000 tons remain.
However, documents released to FIE by the EPA show that ‘emergency response activity' was triggered when a contractor's machinery sank into a toxic ‘sludge pit' on 2 February 2008. The contractor was given ‘no knowledge that there were oil sludge pits at surface level'. It is now alleged that Reports held by the Irish authorities show they knew of the dangers to which the workers would be exposed but these documents were not disclosed.
Contaminants includes heavy metals such as mercury, zinc and lead as well as hydrocarbons, PCBs and Chromium 6, highly toxic carcinogens. Radioactive material is also present.The latest report seem by FIE last month spoke of ‘contaminated mud under the constant influence of tidal movements and percolating rain water which we would deem necessitating emergency treatment immediately.’
Every indication is that this is the largest and most extensive pollution incident in the history of the state.
Read our view in the Irish Examiner