Carcinogenic Dioxins and Biomass Wood Combustion - Letter to Lewis Williamson of the Guardian from a concerned resident, 21 June 2011 (plus follow-up correspondence).

To: Lewis Williamson, Production editor, Guardian politics

Dear Mr Williamson,

I live on the west coast of Scotland in the shadow of the UPM-Kymmene Caledonian paper mill and biomass power plant in Shewalton, Irvine. I recently read with interest your Guardian article "Why is the UK backing biomass power?" and this led me to look more closely at the effects that the operation of this 50 megawatt plant has had on the environment and local community since it started operating in May 2009 and subsequently to write to you with what I uncovered.

Each day the local population have to live with the noise and pollution caused by huge amounts of wood being transported in a fleet of very large sub-contracted lorries along unsuitable B class roads through residential areas, often within feet of sheltered elderly housing and a local primary school. Although this aspect of the biomass plant is of enormous immediate concern to me and many other local people my primary concern is the emissions from the plant and at the weekend I found some information about emissions from this plant that alarms me greatly and, I believe, is possibly the largest single argument against biomass power generation.

Although the UPM plant is supposed to be a highly efficient, low emission design, I and many other locals have noted that often it emits large quantities of thick black smoke. I decided at the weekend to check online and discover if any SEPA returns in the Pollutant Release Inventory were available for this plant since the biomass power plant started operating in May of 2009 and I was very surprised by what I discovered.

Although the plant emits many toxic substances to air and water including arsenic, mercury, etc. it is the dioxin emissions that concern me the most. Until the power plant opened the Dioxin WHO TEQ (toxic equivalency) emissions for UPM's paper manufacturing operations were included in the Scottish Environment Protection Agency (SEPA) online pollutant releases to the air figures for UPM but they were below the SEPA required reporting threshold, which is actually only 0.000001 Kilograms per annum or 1 hundredth of a gram. This was to be expected as although all paper production produces some dioxin the UPM Irvine plant has gradually shifted to a low chlorine process, which produces less dioxin. However, after the Irvine biomass plant started operating in May 2009 the dioxin emissions to air figures for UPM suddenly jumped to 0.00227 kilograms per annum or 2.27 grams. This is not information that was provided when UPM first proposed this plant or even more questions would have been asked locally.

2.27 grams may seem a surprisingly small amount to be concerned about until one reads on page 4 of the June 2008 SEPA paper entitled "Dioxin Emissions from Regulated Processes" that total dioxin emissions from all sources including industrial, landfill, cremation, etc. , etc. is a mere 29 grams per annum. In fact the amount of dioxin emissions to air from all sources for the whole of the UK is only around 1 gram per day.

The UPM plant only operated for a part of 2009 (2010s figures are not yet agreed or released) yet a search of the SEPA site by pollutant revealed that the UPM plant released the highest amounts of dioxins into the air of any source in Scotland. Not only were they the highest in Scotland (SEPA only reports on Scotland) they were 47 times the next highest emissions and these were from Logannet power station in Fife, which produces 2.3 gigawatts compared to 50 megawatts at UPM. In fact Logannet's dioxin emissions for the whole of 2009 are only 0.0000514 kilograms or 5 hundredths of a gram, which is only 5 times the SEPA reporting threshold. In fact, if extrapolated over the whole of 2009 and not only from May of that year the UPM plant would have produced more than 1/10th of Scotland's total dioxin emissions as reported by SEPA document in 2008.

As you are no doubt aware, Dioxin's are highly toxic, persistent, cumulative, compounds that are carcinogenic at nanogram (1000 millionth of a gram) levels (around 5 nanograms per kilo of body weight) and can cause severe reproductive and developmental problems at levels 100 times lower than the carcinogenic levels, so picogram amounts (million millionths of a gram). This explains the apparently extremely low SEPA reporting threshold. In fact the US EPA has states that there appears to be safe level for exposure to dioxins. This is backed up by many studies, the most noted from Princeton university's environmental institute. Dioxin is fat-soluble, it bioaccumulates, climbing up the food chain and builds up in the human body through consumption of local meat, dairy, etc until it reaches levels affecting reproduction, triggering cancer, etc.

To be fair, dioxins occur naturally in forest fires and volcanic eruptions but UPM and soon Forth Energy in Leith, Helius Energy in Southhampton, etc, by chopping down forests in many locations and shipping them to one location, where they are burnt, day after day, year after year, expose people in that location to a constant drip feed of one of the most toxic, persistent and cumulative chemicals known to man.

The area of Scotland that I live in already has incredibly high levels of cancer, one of the worlds highest rates of MS and numerous other health problems. Yet the Scottish government funded UPM with 10 million pounds of taxpayers money and continue to fund them through renewable obligation payments to burn wood and add to the environmental risks faced by the local population.

I am not an environmental scientist, my background is in software and electronics and although I am interested in all science I am reaching my limits in assessing this data and its relevance to public health, the environment, etc. I have emailed you in order to see if you can use this data and possibly take it further, perhaps resulting in an article that would help to make people aware of some of the risks associated with biomass power, even CHP plants, and to ensure that potentially huge environmental time bombs are not built on their doorsteps. Currently many people in both Leith and Southhampton are fighting against plans to build biomass plants in their areas and although I considered emailing this information directly to them I felt that it could be more effective to contact you first. If you are unable to make use of this information I would appreciate it if you could email me and let me know and I will find a way to get the information to the protesters.

Yours faithfully, Richard

http://apps.sepa.org.uk/SPRIPA/Search/ViewReturn.aspx?returnId=20555 

http://apps.sepa.org.uk/SPRIPA/Search/ByPollutant/Results.aspx?Media=air&Pollutant=116&Year=2009 

http://www.ejnet.org/dioxin/ 

http://www.epa.gov/tri/lawsandregs/teq/teqprule.html 

http://www.ejnet.org/dioxin/nosafedose.pdf 

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Hi everyone,

My name is Louise Burgess and I am part of the Breathe Clean Air Group, fighting a Biomass Plant proposal by Peel Energy in west Manchester. 

My thanks must go to Richard for sharing his experiences. The email makes quite shocking reading, although I guess none of it is really 'news' to any of us - just confirmation of some of our main concerns. Although we are fighting a Biomass Plant proposal in our immediate town, a Paper Mill is nearing completion just a few miles along the Manchester Ship Canal from here, so the email is of even more relevance and even more concerning for us. Where is the joined-up thinking that considers the cumulative impact of these plants and learns from the existing examples around the country? 

We have been focused on fighting our local proposal but have considered the need to join up with other groups around the country and tackle this head on, as there seems to be such a huge lack of awareness. We need to join and strengthen in order to raise the issue nationally. 

We will support in any way we can and would be keen to provide information to other groups or to get the issue in the national press.

Best wishes,
Louise 
www.BreatheCleanAirGroup.co.uk

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On Wed, Jun 22, 2011 at 1:05 AM, <projects@gmx.org> wrote:

Hi everyone,

thank you for your email Louise. The original email that I sent is rather long winded, in an attempt to relay as much information as possible about a subject matter that is probably not familiar to many people, including myself. However, I suspect from your email and the mention of its relevance to both the Peel Energy Biomass Plant and the proposed new paper mill opening along the Manchester ship canal, that I may not have explained something as clearly as I should have and should now do so.

Until May 2009 the UPM-Kymmene Caledonian facilty in Irvine operated purely as a paper manufacturing plant, producing mainly high quality magazine quality paper. In May 2009 a 50 megawatt combined heat and power biomass plant started operating within the same facility in a large building adjacent to the paper mill. This can be seen in the 2009 SEPA report that I attached to my email where, under section B "Economic and Process Activities" for the first time in UPMs annual returns a sub activity "Thermal power stations and other combustion installations" is included. If you check reports prior to 2008 only paper manufacture is mentioned and there is no mention of the power plant as it was still being constructed.

Although the paper manufacturing process could never be called environmentally friendly, using vast quantities of water and producing large quantities of pollutant releases to air and water, due to a continued reduction in the use of chlorine for bleaching the paper, until the biomass plant came online the dioxin release to air from paper manufacturing was below the SEPA reporting threshold of 0.00001 Kg/yr. In 2009, after the biomass plant started operations in May of that year, the SEPA return listed the dioxin WHO TEQ emissions to air as 0.00224 Kg/yr or 224 times the SEPA reporting threshold. This leads to the conclusion that the huge increase in dioxin emissions is almost certainly due to the biomass plant coming online and nothing to do with paper manufacturing. It is a pity that the SEPA return for 2009 does not separate the emissions from the paper manufacturing and biomass plant activities.

This plant burns 400,000 tonnes or 400 million kilograms of wood per year and although it's combustion process tries to reduce emissions as much as possible the figures for dioxin WHO TEQ to air are now, according to SEPAs website, the highest by factor of about 44, the highest in Scotland. In my original email I included URLs to the SEPA reports I mentioned and also attached PDF files that had been generated by the SEPA website from the reports. The relevance of the dioxin emissions being expressed in WHO TEQ quantities is that their are numerous dioxin and dioxin like compounds. The most toxic is 2,3,7,8-tetrachlorodibenzodioxin (2,3,7,8-TCDD) and this Group 1 carcinogen is the reference point for all other dioxins. It is given a toxicity weighting of 1 by the WHO, while other dioxins have weightings down to as low as 0.0001 (PCB 77). Thus one gram of 2,3,7,8-TCDD is expressed as one gram of WHO TEQ dioxin while one gram of PCB 77 is expressed as 0.0001 grams of WHO TEQ dioxin.

The WHO TEQ refers only to adverse effects (e.g. cancer) following interactions with the cellular Ah receptors. My concerns in my email focus primarily on the sudden increase in 2009 of dioxins and of the amount of emissions as detailed in the SEPA reports. SEPA had reported in the paper dated June 2008 that total solid fuel combustion for electricity generation in Scotland was between 0.05 – 1.3 grams ITEQ dioxin and furans per year. ITEQ is the old standard before of toxic equivalence before WHO TEQ and is typically 10% higher than WHO TEQ figures. The SEPA figures for the Irvine Biomass plant emissions in 2009 are 2.27 grams.

Given that the paper production produced low dioxin emissions in all returns up to 2009 this means that the biomass burning produced around double the dioxin emissions between May to December 2009 than the total emissions from all other solid fuel electricity generation in Scotland and this is released in Ayrshire, which has many livestock farms and thus a direct route up for fat soluble dioxin to bioaccumulate, climbing up the food chain through meat and dairy into the human population, where it has a half life of 30 years. 90 percent of human dioxin exposure comes from food, particularly meat, fish, poultry, cheese, milk, butter.

A detailed UK study has determined that 2 pg/kg/bw/day to be a safe level which equates to 120pg or 0.12ng (0.00000000012 grams for a 60 kg person) and although people now consume far less than this over 2 million consume 50% more (mainly children and adults with higher fat content diets) and my fear is that biomass power plants will increase dioxin intake in years to come..

I strongly feel that more research is required into the potential health dangers of increased airborn dioxin due to biomass combustion before any more of these plants are built. The SEPA data that I have found is only a small part of the picture and its relevance needs to be checked by someone with far greater domain knowledge than I have. I also hope that the 2010 SEPA report for UPM Caledonian is agreed between SEPA and the company as this will allow us to see what is released from one full years operation of the biomass plant, yet once again separating this from paper manufacturing emissions will require referring back to SEPA reports prior to 2009.

Best regards,

Richard

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22 June

Hi Richard,
I have sent your emails to the rest of our committee this morning. 
Someone has just got back to me saying that the Paper Mill that is being built by the Manchester Ship Canal actually includes a biomass boiler as well and is of a similar design to the UPM plant in Deeside (although I'm not sure how similar that is to your UPM site). So, that, along with the Peel Energy biomass plant may mean we have double problems. I am going to do some digging into this to see what I can find out about the Paper Mill. Thank you for bringing it to our attention as a potential issue.
Best wishes,
Louise

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22 June 2011

Hi Louise,

it sounds as though the plan is to build a similar facility as we have here in Irvine. It makes sense for the plant owners as they can use the steam from the biomass boiler in the paper production and power it from the generated electricity. For the locals however it will mean greater pollution, traffic, etc, etc. and this is what we are currently having to live with here on the west coast of Ayrshire.

On of the recipients of my original email expressed very valid surprise at the very high WHO TEQ dioxin emissions to air of this UPM biomass facility, given that it is only a 50 megawatt plant. To be honest, the SEPA figures also surprised me and before emailing Lewis Williamson with my original email I spent some time double checking them and cross referencing them against emissions from sources such as Logannet, etc. I did this directly on the SEPA website and included the URLs in my email. It is also worth noting that the SEPA WHO TEQ dioxin figures for UPM Caledonian in Irvine are measured amounts and not estimated and that there is a review process before being published on the SEPA website so I would assume that they must be accurate.

However, I realised that such unusually high figures warranted more examination so in the past day or so I took some time to look at how much dioxin could be produced from this 50 megawatt plant given that UPM states that it burns 400,000 tonnes or 4000 million kilograms of wood per year. I performed my calculations assuming that the wood is perfectly clean, virgin, wood with no preservatives, etc. I have included my calculations below and, as I am no domain expert, I would greatly appreciate any feedback. It is important to note that the if these calculations can be checked and refined they could also be applied to all the proposed biomass plants and provide estimates of how much dioxin will be produced from each.


I tracked down studies looking at the dioxin emissions resulting from burning fresh untreated wood in biomass combustion boilers and although I found a number of studies I decided to use the lowest figures that I could find and these were provided in paper from Princeton university "An Estimation of Dioxin Emissions in the US" (attached) where on page 13 table 9 they provide the dioxin TEQ emissions from biomass combustion of wood burned in different types of boilers. 

The UPM Caledinian boiler was supplied by Metso of France (see URL below) and uses a technology that I cannot match to the types shown in table 9 of the Princeton paper so again I have been charitable and assumed emissions at the low end of those shown in the table. Note that in the text at the foot of page 12 of this paper the average figure they give for dioxin emissions from controlled biomass combustion of wood is 0.05 micrograms per kilogram of dry weight wood. However, this is the emission figure for all types of dioxins and the figures in table 9 are weighted TEQ values (weighted to express in terms of the most toxic compound) and are much lower due to the TEQ weighting applied. These TEQ values lie in the range of about one nanogram TEQ per kilogram of wood burned. As the SEPA returns use WHO TEQ weightings for dioxins I used the table 9 figures and added 10% as TEQ figures are typically 10% lower than WHO TEQ 

Assuming the UPM Metso boiler is a very efficient boiler type with good pollution control and using clean wood I assumed emissions of 1 nanogram TEQ per kilogram of wood burned (table ranges from 0.7 to 1.6). This would result in an output of 0.4 grams TEQ or 0.44 WHO TEQ per year. This is 0.00044 kilograms WHO TEQ per year and would still be the highest recorded in Scotland as the SEPA 2009 Logannet figure is only 0.0000514 or 0.0514 grams so even best case calculated emissions from UPMs plant are almost 10 times higher. 

If however the boiler at UPM does not have efficient pollution control at all times (remember many locals including myself have noticed thick black smoke often pouring from the boiler stack) the emissions rise considerably. I have also read research that states that wet wood also raises the amount of dioxin and when the water is salt water it is much higher as chlorines in the salt raise the dioxin levels. It is interesting to note that a lot of the wood to UPM is transported by sea and is very wet (locals can see the transporters and view the wood being unloaded from the ship). These factors could explain the fact that the figures shown on the SEPA site is around 5 times higher than my best case calculated figure given a highly efficient boiler, 400 million kilos of perfectly clean wood, etc. In addition, there is no guarantee that they are only burning 400 million kilos as the amount of transports of wood indicates larger amounts.

This area of Scotland is a centre for livestock farming, meat and dairy and this is means that bio-accumulation of these highly toxic, persistent compounds is a greater risk here that almost anywhere else. In addition, mainly westerly winds ensure almost all pollutants will be transported either to area of population or farmland. 

These calculations can be scaled for all new biomass plants and as many of them are far larger than the 50 megawatt UPM plant even the best case dioxin emissions will also be far higher.

I hope that this helps

Best regards

Richard

see related article - Metso supplies power boiler to UPM Caledonian for green energy production in Scotland, 3 July 2007, and

Princeton - An Estimation of Dioxin Emissions in the US.pdf

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