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Guidelines made to fit the site

IN her letter (Irish Examiner, April 20), Laura Burke of Indaver is indeed correct in stating that the company used the World Health Organisation (WHO) guidelines in selecting its site at Ringaskiddy for a proposed hazardous waste incinerator.What she did not explain is that the WHO guidelines were applied by Indaver only after Ringaskiddy had already been decided as the most suitable location for this national facility.

The WHO takes a remarkably balanced approach to incineration. It recognises its benefits, while cautioning of its potential health and environmental effects.

These, it advises, can be minimised by appropriate emissions control equipment and proper siting. The guidelines mentioned by Ms Burke were designed to assist with the latter.

The first step in applying the WHO guidelines is to rule out certain areas from the site selection process where exposed populations could be at particular risk from either routine or non-routine emissions.

Such areas include those prone to regular thermal inversions. In a thermal inversion, atmospheric conditions become so stable that the air is virtually motionless and emissions are trapped close to the ground. As anyone familiar with the area can confirm, Cork Harbour experiences regular thermal inversions. Had Indaver gone no further than applying this very first step of the WHO guidelines, nowhere in Cork Harbour would have even been considered, let alone shortlisted, for its proposed incinerator. Indaver contends that because comprehensive modelling presented within the environmental impact statement (EIS) predicts no detrimental impact from emissions, the WHO guidelines are upheld. This is the EIS commissioned only after Indaver had already purchased its favoured site at Ringaskiddy. This is the modelling that relied on climatic input data taken from the top of a hill at Cork airport.

Yet for every one thermal inversion experienced at Cork airport, 25 thermal inversions are experienced in the Cork Harbour valley. This is the model that assumes vertical rise of the plume from Indaver’s proposed facility. Yet in a thermal inversion, vertical rise is impossible. This is the facility for which emissions from major accidents were predicted as being non-problematic. Yet these predictions were made using a model incapable of dealing with thermal inversions and accurate only for flat terrain. Ms Burke is correct in saying that there will “never be a perfect site” for a facility such as that proposed by Indaver for Ringaskiddy.

But by employing such site selection procedures, Indaver has angered even those who might otherwise be supportive of its project. It does not take a “team of engineers” to identify Cork Harbour as one of the basic no-go areas under WHO guidelines. But this team is remarkably useful in confounding with inaccurate science what would otherwise be a simple observation.

Marcia K D’Alton,
4, Castle Terrace,
Co Cork.

Irish Examiner - May 05, 2004


Cork Harbour Alliance for a Safe Environment
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