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Whistleblower: Bolton incinerator should close

A whistleblower who contacted UKWIN about the Bolton incinerator has received national coverage in ENDS. We reproduce the article (below) with the kind permission of ENDS.

cems cheatsheet

Click on the link above to view a note that was passed on to UKWIN by whistleblower, Patrick Sudlow. The document shows the operators of the Bolton incinerator which is operated by Greater Manchester Waste (now Viridor) how to switch off the CEMS (continuous emissions monitoring) whilst making it look as though it is still switched on. There is no legitimate reason for doing that.

Note “Enty” in the last line refers to Steve Entwistle the plants “Business Manager”.

The ENDS Report
ENDS Report 411, April 2009, pp 21-22
© 2009 Haymarket Business Media

Bolton incinerator should close: whistleblower

A UK waste incinerator has operated under a management regime that falsified emissions monitoring data in breach of its environmental permit, a former employee at the site has alleged. The operator rejects the claims but the Environment Agency has pledged to investigate.

A former employee at Greater Manchester Waste’s Raikes Lane incinerator in Bolton has made allegations of malpractice and environmental failures at the plant to ENDS and UKWIN, a network of campaign groups opposed to waste incineration.

A culture of poor management, he said, has seen routine falsification of pollution-monitoring records and logbook data, illicit effluent discharges to sewer and engineering problems which have endangered the health of operators. The malpractice, he said, has escaped the Environment Agency’s attention.

Patrick Sudlow was a process controller with Greater Manchester Waste, the former council waste company that ran the incinerator, for more than seven years. The company became part of Viridor in April with the long-awaited signing of Greater Manchester’s private finance initiative (PFI) contract (see p 22). The same site management remains in place.

Mr Sudlow left the company in March 2008. He told ENDS he resigned after long-standing differences with the management over the running of the site.

“Family problems have stopped me coming forward before now,” he said, “but I left because of the plant’s continued breaches of the Environment Protection Act, the site licence and other legislation.”

He has an engineering background running high-pressure steam boilers in the Royal Navy, but said he was appalled by the incinerator’s poor mechanical condition, improper maintenance and the covering up of the plant’s poor performance.

“I originally supported incineration thinking if it is monitored and managed properly, there should not be a problem. But the Environment Agency and Greater Manchester Waste (GMW) have proved themselves incapable of supervising the waste management side of the plant, let alone the incinerator,” Mr Sudlow said.

One of his most serious allegations is that the plant’s continuous emissions monitoring system was regularly turned off during start-up and shutdown, and when the plant was operating abnormally. This means no accurate record of emissions would be made at these times and the flue gas treatment system was also not in use. The consequences of this would be that emissions of acid gases and organic pollutants such as dioxins would not be effectively abated – a breach of the site’s environmental permit.

The allegations come as the agency published a research report showing that well-run incinerators do not produce excessive dioxin emissions on start-up and shutdown (see p 22 ).

Normally abatement and emissions monitoring would be required at all times when waste was on the incinerator’s grate, but Mr Sudlow said there was an established procedure for turning off the monitoring and abatement system to make it appear the plant was shut down when it was still burning waste.

Mr Sudlow also alleged the management rewrote the incinerator logbooks which he said were bound in a plastic comb binder, allowing pages to be replaced at will. Changes were made to make it appear all waste was burnt off before shutdown, he said, when in fact it had not been. The aim, he said, was to obtain maximum throughput of waste and to ensure the logbook agreed with emissions-monitoring data.

In 2000, the incinerator was upgraded to meet Waste Incineration Directive standards but kept the old grate system. Mr Sudlow said this was in poor condition and led to an inefficient burn. The bottom ash often contained a lot of unburnt material and batches had been rejected for use as an additive to concrete block manufacture.

“The plant is still run with the mentality of the 1970s and the management has been misleading the agency about the plant’s operation and its emissions,” Mr Sudlow said. Burn-through of the incinerator’s refractory wall has occurred on occasion, he said, resulting in untreated flue gases and dust entering the control room, posing a health and safety concern for the staff.

Quench water for the bottom ash was also routinely discharged to sewer, Mr Sudlow said. Effluent was supposed to be recycled in the process or tankered off-site for disposal, but he alleged the liquid – likely to be high in dissolved metals – had been discharged to sewer at night following shutdown and maintenance.

Sewerage undertaker United Utilities said it takes samples from the site 20 times a year and has no record of consent breaches. It would not say whether any of these samples were taken at night.

Viridor is aware of the plant’s alleged problems. Mr Sudlow said he contacted them in the past but there was no response.

The company told ENDS the allegations were “nothing more than the individual perceptions of a disgruntled former employee” and the site has “an excellent compliance record”. It said the emissions monitoring system is audited and verified by both themselves and the Environment Agency. The system is only turned off during maintenance, while start-up and shutdown procedures have been agreed with the regulator.

Viridor denies processed water has been discharged to sewer and that the grate performs badly. It maintains bottom ash from the plant contains less that 1% unburnt carbon.

Refractory wall failures have occurred on a very small number of occasions, Viridor said, but the failures were immediately repaired. Because the incineration chamber runs on negative pressure, gaps would result in air being sucked into the incinerator.

But Mr Sudlow describes regular breaches of the refractory wall and rock wool padding being used to plug the holes which he saw glowing red with the heat from the incinerator. Although the incinerator was designed to be under constant negative pressure, he said this was not the case because management insisted that waste cover the intake filters and the fans struggled to operate. There was also a leak in the chamber’s roof which had been present since the plant was built.

The Environment Agency said it was investigating Mr Sudlow’s claims. In a statement to ENDS it said: “All significant emissions to air are continuously monitored and reported… monthly. We also carry out regular inspections including unannounced spot checks.”

Viridor said Mr Sudlow failed to bring these issues to the management’s attention either informally or using established grievance procedures. Mr Sudlow said his manager’s attitude was: “You are management, not the staff’s union representative.”

“I tried to bring about improvements but I was banging my head against a brick wall,” Mr Sudlow told ENDS. “I am reluctant to say anything because of the staff, but really the whole plant needs shutting down.”

ENDS has forwarded Mr Sudlow’s information the regulator.

ENDS Report 411, April 2009, pp 21-22
© 2009 Haymarket Business Media


  1. Christy O'Reilly

    I am chairman of a community group called North East Against Incineration, in Ireland. We are opposing the construction of an incinerator to burn Cat1 meat and bone meal (MBM). The company behind this project process Cat1, Cat2 and Cat3 together. This means that all becomes Cat1 and under present EU law, has to be Incinerated. Food Safety experts agree that in less than three years EU law will change and CAt1 will not be Incinerated. At the moment Cat2 and Cat3 do not need to be incinerated. The facts are this company are falsly inflating the amount of Cat1 and using it as an excuse to build an Incinerator.

  2. Shlomo

    Römbke, J., T. Moser, et al. (2009). “Ecotoxicological characterisation of 12 incineration ashes using 6 laboratory tests.” Waste Management In Press, Corrected Proof.

    In the European Waste List (2000/532/EC as amended) the ash of municipal waste incineration is defined as a so called mirror entry. This waste can be classified as hazardous or non-hazardous depending on the content of hazardous substances and other risk properties. For the assignment of waste in mirror entries, 14 criteria are defined. One of the criteria is H14 “ecotoxic”. In the presented study, the ecotoxicological potential of 12 ashes from different incineration plants has been assessed using biological test systems. The test battery included aquatic tests with eluates (algae, daphnids, and luminescent bacteria) and terrestrial tests with solid waste (plants, earthworms and bacteria). The test results revealed a clear ecotoxicological hazard potential for some of the MWI ashes. Despite the fact that fresh ashes were several times more toxic than aged ashes both groups did not differ consistently in terms of toxicity. The results show also that there is no correlation between the biological effects and the analyzed chemical compounds of the ash samples.

    [from body of text:] In total, 12 incineration (MWI) ashes from German combustor plants of municipal solid wastes were tested. According to the outcome of the expert program HAZARD CHECK, provided by the State Environmental Agency of Nordrhine-Westphalia and performed by the owners of the waste plants, all MWI ash samples studied were not classified as hazardous according to one of the other 13 criteria. However, when using concentrations of relevant compounds (mainly heavy metals) as a substitute for biological testing as criteria for H14, as done by German guidelines ( BMU, 2001 ), all MWI samples would be classified as hazardous.

    [Note: The authors do not specifically identify these samples as bottom ash. However, certain text in the paper implies that these are indeed bottom ash samples. I have asked the first author to confirm that this is the case. Also note that the authors did not determine the concentrations of dioxins or other organic contaminants that commonly occur in bottom ash.]



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