17 August 2008

No Minister! Some things you should know

This entry was orginally posted on 28 July 2008 on the Irish Military Online (IMO) Discussion Board for the Navy & Naval Reserve in the Irish Steel Mill thread by "Boffin Island" Recruit.

As a civilian employee at the naval base: How dare he? The Minister’s strident assertion that “There is currently no indication that the situation at the former Ispat site represents any risk to the health of Naval Service personnel or civilian employees at the naval base” is untrue and unacceptable.

There is plenty that currently indicates high risk to health and Willie O’Dea does and should know it. If he lacks the relevant reports, he could ask his cabinet colleague John Gormley for copies! For example:

2002 Enviros Aspinwall report to DCMNR

According to the qualitative risk assessment contained in the October 2002 report (‘Phase One Investigation and Assessment at Haulbowline Island, Cork Harbour, Cork’) by Enviros Aspinwall to the then Department of Communications, Marine and Natural Resources:

The East Tip (i.e. the area covered by slag, mill scale, bag house dust and other waste that was subject to intensive dust-creating work between November 2007 and April 2008) posed “high risks to humans, groundwater, surface water, marine ecosystem from leached metals, hydrocarbons and PCBs” and “high risks to humans from windblown dust” (p3).

The Main Site (i.e. where the now demolished former Irish Steel/Ispat steelworks buildings stood, adjoining the Naval Base) posed “high risk to humans from PCBs spills; high risk to marine ecosystem from metals from dust; high/moderate risks to humans from windblown dust” among others (p4).

The report specifically identifies “People – Naval personnel and other site neighbours” as being at risk from “Direct contact/ingestion of wind blown dust” (p32).

Table 6.2 Risk Assessment matrix for Irish Ispat is detailed and includes: “Human residents (neighbours sited on Naval base and Cobh)” are at risk from “Windblown dust” with associated hazard of “Long term health risks [Severe]” with likelihood of occurrence described as “Likely. The tip is unvegetated, dusts present on the tip may be mobilised and blown by the wind” which may or may not blow towards human residents. The potential significance is rated as “High Risk” (p33).

Also, the marine ecosystem was at “High Risk” and any humans without personal protective equipment on the East Tip were at “High Risk” with “High Likelihood” of “Direct contact, ingestion of soil, inhalation of particulates” with associated “Health risk [Medium]” (p33).

* The term “high risk” is used to mean “Harm is likely to arise to a designated receptor [i.e. human] from an identified hazard at the site without appropriate remedial action” (p29).

The 2002 report for DCMNR clearly points to heavy metals in the bag house furnace dust “including zinc and lead” which was “deposited on the East Tip until 1980 as a dust” (p22).

“This material comprises a fine dust which will require some form of treatment to facilitate handling and disposal or recycling on or off site” (p69).

2003 Bord na Móna report to Naval Service

The November 2003 report (‘An ambient air quality survey for selected parameters at the Naval Service Base, Haulbowline Island on behalf of the Naval Service undertaken over a six month period’ from March 2003 to September 2003) by Bord na Móna Environmental Ltd Technical Services is considered a baseline survey as “All of the results were obtained during a period of inactivity at both the east tip and the steel works” (p41).

Nevertheless, sampling of airborne dust (particulate matter or PM10) carried out at the football pitch (location PM-01) exceeded the standard 50 μg/m³ limit value on seven occasions over a 10 day period in March 2003. The report states that “any breach of the 50 μg/m³ daily limit value may be considered significant” (p2).

“The most obvious source of PM10 particles is the material located to the east of the sampling location on the east tip… during an easterly wind there is a significant probability of increased particulate levels impacting on the basin area” (p37).

“The exceedences correspond to a high number of recorded easterly wind hours during that time and significant machinery activity on the east tip. After this period, activity on the east tip reduced” (p2).

The implications are, of course, that when there is significant machinery activity on East Tip –- such as when the site was being cleared recently by contractors, especially between November 2007 and April 2008 –- and the wind is from the East (and presumably it is dry weather), then dust levels over the Naval Base are likely to be significantly higher than the daily limit.

On page 3 the Bord na Móna report states: “The level of activity at the east tip and the steel works during the sampling period was generally low apart from a period of machinery movement and scrap steel recovery on the east tip during the early phase of the sampling period. The results obtained from the selected parameters reflect this low level of activity. Therefore, the levels recorded for each of the parameters would be considered baseline levels.”

It then concludes: “Based on these results and comparison to the appropriate standards, there is no significant impact on ambient air quality in the basin and headquarters area of the island arising from the steel works and the east tip.”

If this conclusion is quoted out of context by a politician, it would sound like everything is hunky-dory. But it also means that there is a significant impact on ambient air quality in the basin and headquarters area when there is a high level of activity of the East Tip. Which the 2002 report goes on to warn:

“However, should the level of activity in these areas change due to removal of material on the east tip or structural alteration/remediation of the steel works area, it is probable that ambient air quality in the area will suffer a significant impact, particularly with regard to PM10 levels. This would be based on the impact of machinery movement on the recorded PM10 levels during the early phase of the sampling period” (p3).

Oh, and it says this about why “PM10” is so important, regardless of any chemical heavy metal cocktail it may be made of:

“PM10 is defined as particulate matter with an aerodynamic diameter less than 10 μm. This description is restricted to this physical characteristic and no particular chemical composition is implied. The size is of importance because it is this that determines where in the human respiratory tract a particle deposits when inhaled. Most concern is given to particles small enough to penetrate into the lungs to reach the alveoli. When inhaled almost all particles larger than 7 μm are deposited in the nose and throat, and only 20-30% of particles between 1 and 7 μm are deposited in the alveoli. The measurement of PM10 relies on the use of a size-selective instrument, which collects small particles preferentially” (p6).

2008 AWN Consulting report to Cork County Council

If the Minister isn’t satisfied yet, he can look at the 30 May 2008 report (‘Dust deposition monitoring in the region of the former Irish ISPAT plant, Haulbowline, Co. Cork (01/04/08 – 01/05/08)’) by AWN Consulting Ltd for Cork County Council.

Since July 2005, continuous monitoring of dust deposition has taken place at four locations: on Haulbowline Island (A) Naval Base Dockyard and (B) Naval Base Church, and at (C) Ringaskiddy (until 5/6/07) and (D) Cobh Town Centre. The AWN report “details the results of monitoring over the period 01/04/08 – 01/05/08 (i.e. April 2008)”. The standard daily limit of dust deposited is 350 mg/m²/day.

During April 2008, the average monthly levels of deposited dust per day were:

(A) Dockyard ------ 114 mg/m²/day

(B) Church --------- 1267 mg/m²/day

(D) Cobh ----------- 47 mg/m²/day

“The dustfall levels at one of the three measured locations for the April 2008 period exceeded the TA Luft annual limit of 350 mg/m²/day, reaching 362% of the limit at the Naval Base Church on Haulbowline Island. The monthly deposition level at the Naval base dockyard and at Cobh reached 33% and 13% of the TA Luft limit vales respectively” (p2).

TA Luft is an international limit for air pollution. Clearly there was a huge amount of dust in the air over the Base in April when the contractors were removing heaps from the East Tip. From the 2005 White Young Green report (see below) released by the Dept. of Environment, we know that the ‘soil’ they were digging up and shaking to separate dust for shipping to Germany was a cocktail of heavy metals and other toxic substances. The other thing for sure is that if it was in the air, it was capable of being breathed in by anyone on the Base in April.

And it’s not just April 2008 that had high dust levels. At the Church on the Base (location B) the 350 mg/m²/day limit (monthly average) was exceeded in March 2007, February 2008 and March 2008 as well:

6/3/07 to 2/4/07 ----- 494 mg/m²/day

4/2/08 to 3/3/08 ----- 583 mg/m²/day

3/3/08 to 1/4/08 ----- 428 mg/m²/day

2005 White Young Green report to Cork County Council

Now that Minister O’Dea knows it was very dusty on the Naval Base, and that the Government was warned in 2002 of the “high risks to humans from windblown dust”, and that a study in 2003 found significant breaches of airborne dust (PM10) limits, what did he and his Cabinet colleagues know about the chemical substances in East Tip that was turned into dust by machinery and activities in clearing the site?

The September 2005 report (‘Factual Geo-Environmental Report: Contamination and Geotechnical Assessment, Former Irish Steel Site, Haulbowline Island’) by White Young Green Ireland Ltd for Cork County Council first of all refers to environmental investigations by KT Cullen & Co in 1995 and 1998 as well as O’Callaghan Moran & Associates (May 2002) and Enviros Aspinwall (October 2002):

All of the reports highlighted the potential risks to humans and the environment from materials dumped and spilled on site. This included potential heavy metal contamination leached from waste slag and furnace dust, waste oils, organic solvents, PCBs, PAHs and radioactive material. Historical site activities may have disposed sludges containing high levels of metals and mill scale on-site” (p1).

“According to the KTC report 1995, the East Tip is predominantly comprised of slag (approximately 45 000 tonnes/year) with laboratory chemicals, hot flume dust, oil and grease and domestic waste. Prior to the 1980 s the fine filter dust was deposited with the slag without being processed, but was palletised and exported from the early 1980’s. In 1994 a part of the East Tip was reclaimed for the development of a Naval football pitch” (p6).

The 1995 KT Cullen & Co report concluded:

“The materials dumped on the East Tip are a significant potential source of heavy metal contamination of sediment and groundwater as demonstrated by the laboratory analyses” (WYG p7).

The 1998 KT Cullen & Co report concluded:

“…observations at the site suggest that the uncompacted waste near the ground surface has a high permeability. The permeability of the waste is expected to be highly variable due to the following factors: The nature of the deposited materials varied from fine dust or sludge to coarse metal fragments; The shallow waste was much less compacted than the deeper waste; and The waste below the water table was flushed by the tide which may have allowed some dissolving and washing of the finer particles” (WYG p8).

The 2002 O’Callaghan Moran & Associates report for KPMG Corporate Recovery (i.e. the receivers for Irish Ispat Ltd production facility on Haulbowline Island) identified:
  • Hazardous waste was disposed of at three separate locations; the former dock and waterway, the South Tip and the East Tip. That there is documentary evidence to confirm or strongly suggest disposal of furnace dust, waste oils, organic solvents and PCBs at the South and East Tips. That there is a possibility that similar wastes were disposed at the dock and waterway.

  • Process wastewater treatment sludge containing high levels of metals may have been deposited on-site.

  • A coal gasification plant was demolished ca. 1960. Such plants are recognized as sources of PAHs and can be a significant contaminant. There is a strong possibility that the contaminated demolition debris from the gasification plant has been disposed of on the site.

  • The furnace dust assessment established that it readily leaches lead and zinc and in sufficient quantities is toxic to marine organisms.

  • The East Tip was used for disposal of production wastes. The primary contaminants identified were heavy metals, oils and PCBs. However the investigation by OCM did not assess all potential contaminants and there was no investigation on the South Tip.” (WYG p8-9).
The OCM survey of Contaminated Soil and Groundwater identified the following:
  • “Contaminated demolition debris from the former coal gasification plant and possibly the galvanizing plant may have been used as fill. No site investigation data for the main plant is available to confirm the nature of the fill material.

  • Furnace dust emissions with high levels of zinc and lead and lower levels of other metals would have been deposited in the vicinity of the main plant prior to installation of the furnace dust collector. Such dust, which is susceptible to leaching zinc and lead by rainwater, could result in elevated metals in exposed soils on the site. …” (WYG p9).
Appendix I of the 2005 WYG report (600k pdf) lists results of laboratory chemical testing on 'soil' sample from trial pits and bore holes on the Base. It looks like a nightmare to me!

Arsenic, Cadmium, Chromium (including the infamous Chromium 6 or Hexavalent Chromium), Copper, Lead, Nickel, Vanadium and Zinc all have very high levels in many of the trial (i.e. surface) pits. There is also lots of hydrocarbons –- if this was an offshore oil rig like the Brent Spar, the thing would have been shut down by the authorities and Greenpeace would be all over it by now! Then there are the PCBs –- any they are bad.

What does this cocktail do to you? If just one of these metals and chemicals cab be carcinogenic, what does breathing in all of them in one go do to you?


Maybe Minister O’Dea should come down to Haulbowline Naval Base and get himself a good long lungful of dust on a dry day with the wind blowing from the tip, whilst the contractors resume their digging and shaking (poor devils!)? Maybe he should come work here for several months, even years? In fact, why doesn’t he relocate his Department to Haulbowline Island? I’m sure the unions would have something to say about it then! He too can then take this toxic dust back home on his clothes to his wife and kids!

Now let's hear him dare to say: “There is currently no indication that the situation at the former Ispat site represents any risk to the health of Naval Service personnel or civilian employees at the naval base.” Wake up and smell the chromium Minister!

Me? I’m off on me hols to Chernobyl. I hear it’s a lot safer there!

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