Dear Mr Ritchie,
It is with the greatest worry and concern that I am writing to you in objection to the submission for the proposed Genesis, Energy from Waste site in Eastern Creek.
I can only think that the Energy from Waste model has been proposed for consideration purely motivated by waste for profit completely sacrificing human health with huge detrimental risk for the high density residential population living in the proximity of the proposed plant.
I live in the neighbouring suburb of Mt Druitt less than 2.3 kms from the site, and my grandchildren attend a nearby Primary school, with minchinbury primary school located merely 900 meters to the site. The surrounding area is a dense residential working class community and one that i have resided in for over 30 years. The surrounding and highle effected areas are primarily made up of working class families. The closest residence in Minchinbury to the proposed site is 500 meters.
The proposal is of grave concern for all of the nearby residents, With the primary concern being the human health, ongoing health and the safety aspect of the effected residents and poor children subjected to such a catastrophic development . These effected areas spread to the neighbouring residential suburbs of Mt Druitt, Minchinbury, Erskine Park, St Clair, Horsley Park, which is expected to subject over 25,000+ residents to such potentially detrimental health impacts.
It is unclear to suggest the radius of impact although it is noted through other comparable sites, with comparable exposures such as the findings of the Wollongong cancer cluster the exposure decreases only after 20kms away from the emitting site.
Studies that have been documented to show a very high increase of cancer for people residing near waste incinerators with fatal outcomes.
With such studies available at the cost of other peoples lives, why is this even being considered so close to residential premises and exposure of long standing good community citizens that have been residing in the neighbouring suburbs all of their lives be forced to live and exposure their lives to such disturbing sites with such potentially fatal exposures.
With such information, studies an evidence available, I would have hoped that our governments act responsibly with the impact to human health at the forefront of the decision and immediately oppose to a energy from waste site in this area.
Take the Wollongong cancer cluster which was linked to the BHP steelworks, the hazardous emissions are the same.. Take Benzene - proven to the be linked to Leukaemia there is no safe level of exposure to benzene. Studies have found that the smallest doses can trigger the formation of leukaemias, with the highest risk among children, the aged and the ill. Benzene is one of the emissions noted on the Fitcher Assessment that will be emitted from the EfW site not to mention a cocktail of other hazardous substances, some of which i have noted with the potential human health effects below.
I would hope the lives that were lost in Wollongong due to exposure were not lost in vain and that lesson is learnt for all to ensure such events are never repeated.
Using Port Kembla as an example on the potential human health outcomes from hazardous emissions, there is a direct correlation of these cancer victims and the hazardous emissions from the steelworks in Port Kembla. There was a study undertaken of six postcode areas for which stable population data were available, the average rate of leukaemia was some 10 times higher at Berkeley (4 km from the Port Kembla site), than at Minnamurra, 18 km away. The cancer rate at Berkeley was 4 per 1,000 people over 22 years; and at Minmumurra it was 0.47.
These analyses, conducted by environmental scientist Chris Illert and mathematician Daniela Reverberi, confirmed the pattern detected earlier when a leading Wollongong oncologist, Dr Paul Clingan, supplied postcode details of the 1,325 cancer cases he treated from 1986 to 1996. Those results showed that the average rate of cancer was three times higher near the steelworks and the smelter than it was 20 km away.
Similar conclusions were reached by one of the largest studies of childhood cancer and leukaemia conducted anywhere in the world. Professor George Knox of Birmingham University examined the 22,000 cases of those who died before the age of 15 across Britain from 1953 to 1980. He found that children born within 5 km of an industrial source had a 20 percent greater likelihood of contracting cancer or leukaemia before reaching adulthood. The pattern persisted over three decades, regardless of population movements.
In Wollongong, further statistics obtained from the Cancer Council revealed an unusually high rate of leukaemia among children and teenagers since at least 1974. Moreover, they indicated two distinct peaks of this rare disease among young people -- from 1981 to 1983 and from 1989 to 1992.
Both these peaks followed incidents involving benzene related emissions.
In 1989 there was a six month period in which the EPA apparently ceased monitoring the emissions from the site however when asked to explain this suspicious gap in its records, the EPA director general replied that monitoring was suspended to reduce costs. Yet another six month gap occurred in late 1994 and early 1995, just before several months before the Warrawong High students were diagnosed. This proves that the monitoring of such dangerous sites is far from a adequate option to protect nearby residents.
There is concern about the technology and the ability to deliver the claimed levels of emissions and of course not to mention the poor record Dial a Dump Industries have in regard to environmental breaches.
May 23, 2012
Ian Malouf, the self-made millionaire behind the Dial A Dump rubbish empire, appeared in court today as one of his companies was fined for polluting water.
Alexandria Landfill Pty Ltd, of which Mr Malouf is a director, was fined $3750 plus costs in Newtown Local Court for the environmental offence which took place last year at the Dial A Dump Industries headquarters in Alexandria.
The Environmental Protection Authority prosecuted Alexandria Landfill after discovering a pipeline on the property on March 17, 2011 which was being used to pump leachate into a stormwater canal.
The EPA alleged there were "no extenuating circumstances" that it was not a trivial matter and Mr Malouf had attempted to shift the blame for the offence to one of his employees.
21 October, 2012
IAN MALOUF'S Dial a Dump rubbish empire has been slapped with two on-the-spot fines for unlawfully receiving waste at its proposed $300 million landfill site at Eastern Creek, before it has received a licence to operate fully.
Two fines of $1500 each were issued in August and September to Dial a Dump after Environment Protection Authority inspectors discovered hundreds of tonnes of waste on the property at Eastern Creek, in Sydney's west.
Mr Malouf denied his companies had done anything wrong.
December 19, 2011
the owner of the site, Dial-A-Dump CEO Ian Malouf, was under investigation by the independent Environment Protection Authority (EPA).
"He's subject to investigation by the independent environmental agency," Mr O'Farrell said.
His comments followed reports in Sydney's The Sun-Herald newspaper that Mr Malouf was linked to companies that were being investigated for serious pollution offences.
Clearly Malouf has no respect for the laws, and has become a law upon himself.. are we really going to upgrade his license to Kill and allow him to manage and operate a site which can easily over expose nearby residents to a person that has no personal accountability or care about anyone but himself and his own empire.
You say that EPA will monitor.... and what about risks of over exposure or non compliance of emission limits?
Do we allow the potential for this to occur and record / action non compliance after this has occurred?
The operators or regulators need to report instances of `non-compliance' where conditions of the licence (including emission limits) have been breached. The regulator then has the option of taking enforcement action against the facility operator in the form of prosecution and a fine. Such as the fine of Mr Malouf contaminating water... ACT AFTER IT HAPPENS!! Many environmental reports are provided periodically to regulators resulting in long periods when pollution can be occurring undetected by authorities .
It has also been commonplace for industrial regulators to raise emission limits in environmental licenses when industry exceeds the original levels set in the permit.
Not to mention that is known that many facilities have licenses that do not include some of their most harmful emissions.
The hazardous waste incinerator burning chlorinated waste in the Port Hedland, Western Australia does not have any reference to dioxin emissions in their licence, even though these emissions have serious effects to human health.
Are we prepared to expose nearby residents - Men, Women and Children to self monitoring by an organisation that has already had several breaches including water contamination, dumping of asbestos, illegal dumping of waste before obtaining a license and other irresponsible and risky occurrences?
It is concerning that high emission technology is even being considered in a region surrounded by residential dwellings. Regardless of the claims that this new technology has reduced emissions in comparison to prior technologies.. Firstly these claims of reduce emissions are unproven and secondly these dangerous emissions will still have exposure to the nearby men, women and children.
Benzene - proven to the be linked to Leukaemia there is no safe level of exposure to benzene. Studies have found that the smallest doses can trigger the formation of leukaemias, with the highest risk among children, the aged and the ill. Benzene is one of the emissions noted on the Fitcher Assessment that will be emitted from the EfW site not to mention a cocktail of other hazardous substances, some of which i have noted with the potential human health effects below.
The release of toxic air emission from incinerators can have a significant impact on human health. Waste incinerators release a diverse range of toxic substances to the atmosphere, some are short lived whilst others are persistent and ALL have varying degrees of toxicity. Once released toxic emissions can be carried large distances. Toxic emissions have a significant lag time before human health impacts become obvious, there is a issue of latency of onset of symptoms after exposure which can take decades. Only recently have scientific studies emerge that acknowledge the scale of public health impacts directly from waste incinerators. These public health impacts directly associated with incinerator technologies have been documented by internationally recognised scientists.
The British society for Ecological medicine concluded the following in relation to incineration
`Typically this decision is based on an inexact method called risk assessment. They tend
to rely almost exclusively on this type of assessment and often have little understanding
of its limitations. Risk assessment is a method developed for engineering but is very poor
for assessing the complexities of human health. Typically it involves estimating the risk
to health of just 20 out of the hundreds of different pollutants emitted by incinerators.'
The consideration of this EfW plant has a high impact on human health creating a public health risk. This has been studied and concluded in multiple countries in the world.
Japan now has dioxin contamination levels ten times higher than any other industrialised country. Japan has identified increased symptoms associated with proximity to waste incinerators, particularly in children.
"The findings suggest that proximity of schools to municipal waste incineration plants may be associated with an increased prevalence of wheeze, headache,
stomach ache, and fatigue in Japanese children, but worse another study investigated that an area in Japan near a waste incinerator had high levels of dioxin contamination in soil and an unusually high rate of cancer in residents. This study tested blood samples from 13 women and 5 men living within 2 km of the incinerator. Levels of dioxins were raised considerably in the residents compared to background levels found in the general population. For example, women had an average blood level of 149 pg TEQ/g lipid and men 81 pg TEQ/g lipid, whereas the background level for the general population is in the range of 15 to 29 pg TEQ/g lipid. The authors commented that increased exposure in the residents was considered to be due to direct inhalation of dioxins from the stack.
A 2013 study investigating health impacts from waste incineration and hazardous waste treatment plants in Spain concluded,
"Our results support the hypothesis of a statistically significant increase in the risk of dying from cancer in towns near incinerators and installations for the recovery
or disposal of hazardous waste"
Those townships in the proximity of waste incinerators had the highest excess cancer mortality for populations of all the towns studied.
France also has a high proportion of waste incinerators compared to most other countries. Researchers conducted a study in the area of Doubs, eastern France, to
investigate clustering of two types of cancer, soft tissue sarcoma and non-Hodgkin's lymphoma, near to a waste incinerator. The study was undertaken following a report of
high dioxin emissions from the incinerator. The study found highly significant clusters of both cancers in areas close to the incinerator but not in other surrounding regions.
The Fitcher Energy from Waste human health risk assessment for the Genesis Eastern Creek EfW Site, has noted
"The key issue is the release of substances from the proposed EfW to atmosphere which have the potential to harm human health. The Facility is to be located in Eastern Creek, approximately 36km west of the Sydney CBD and surrounded by the residential areas of Minchinbury, Mt Druitt and Rooty Hill to the northwest. The closest of these residential areas is approximately 1km (this is inaccurate, in fact it is 500 meters) to the north of the facility. Due to the proximity of the residential receptors there is the potential for emissions to impact upon human health.
Some of these pollutants listed in the Fitcher assessment include:
nitrogen dioxide - Irritation of eyes, nose, throat, and lungs, nausea, shortness of breath, respiratory problems, reduced oxygenation of body tissues, and a build-up of fluid in the lungs
particulate matter - Increased respiratory symptoms, decreased lung function, aggravated asthma, development of chronic bronchitis, irregular heartbeat, non fatal heart attacks, and premature death in people with heart or lung disease
carbon monoxide - Chest pain, cardiovascular effects, vision problems, reduced ability to work or learn, reduced manual dexterity, difficulty performing complex tasks, and respiratory problems
mercury- Brain, kidney, and developing fetus damage, lung damage, nausea, vomiting, increased blood pressure, and ocular and dermal irritation
cadmium - Severe lung damage, kidney disease, stomach irritation, increased bone fragility, and increased risk of lung cancer
arsenic - Sore throat, irritated lungs, nausea, vomiting, decreased production of red and white blood cell s, abnormal heart rhythm, damage to blood vessels, darkening of skin, skin irritation, and increased risk of skin, liver, bladder, and lung cancers
lead - Adverse effects on nervous system, kidney function, immune system, reproductive and developmental systems, and cardiovascular system, and neurological effects (especially in children)
Dioxin and furans; - Chloracne, increased risk of cancer, increased risk of heart disease, and increased risk of diabetes
Dioxin like PCBs; - Increased risk of cancer, specifically rare liver cancers and malignant melanoma, immune system damage, reproductive system damage, nervous system damage, endocrine system damage, dermal and ocular effects, and elevated blood pressure, serum triglyceride, and serum cholesterol
Polycyclic aromatic hydrocarbons (PAHs). - Increased risk of cancer
Benzene - Benzene is a well established cause of cancer in humans.
1,3 The International Agency for Research on Cancer has classified benzene as carcinogenic to humans (Group 1).1,3 Benzene causes acute myeloid leukaemia (acute non-lymphocytic leukaemia), and there is evidence that benzene may also cause acute and chronic lymphocytic leukaemia, non-Hodgkin's lymphoma and multiple myeloma. Individuals who have experienced benzene poisoning requiring treatment show a substantially increased risk of mortality from leukaemia.
3. Chronic exposure to benzene can reduce the production of both red and white blood cells from bone marrow in humans, resulting in aplastic anaemia
Dioxins are highly toxic at extremely low levels (effects have been reported in the parts per quadrillion range) making claims of `low dioxin emissions' from incinerators somewhat meaningless.
Incinerator proponents commonly claim that dioxin emissions were only ever a problem with `old' incinerators and that `new' incinerators have overcome these problems.
However, there is no definition of new or old incinerators and most current proposals are merely variations on the same technologies that have been in use for decades.
What has changed is the branding of these technologies. Proponents are now well aware that the public has a very negative perception of any technology with very good reason, called an incinerator and associate it with dioxin pollution.
In order to avoid this association the industry has been advised to use a range of new terms for incinerators including : Waste to Energy
Despite this re-branding, a range of recent studies and incidents conclude that dioxin emissions remain a problem for incinerators.
This proposal is a serious health concern to the local communities. I hope the rejection of the application in light of the human health risks are prioritised above and beyond any unstable concept that is a risky business venture with no security to succeed as seen in other EfW sites..
Brightstar Environmental's SWERF plant in Wollongong. This operation closed after 3 years of trials in 2004 without having become operational and with many emission breaches. The parent company Energy Developments Ltd lost around $160 million along with the local community investment of $1.5 million.
Harrisburg, the capital city of Pennsylvania is on the verge of filing for bankruptcy with up to US $345 million in debt mostly associated with the city's waste to energy incinerator.
Really really, are we going to consider such sites in dense residential areas.. what will you do WHEN there are cancer clusters such as the above?.. that you have been made aware of and we as residents have documented and studied?
What will you tell the parents of the ill children, the local doctors that raise concerns?
This is a fight for all of our lives... A fight we should start now to stand up and right to oppose such alarming developments, than watch my families and friends lie in their beds fighting their last breath.
Please..... we urge you as our leaders in which we put our trust and welfare.. look after our local residents, and reject such applications in Eastern Creek for the safety of these families, safety of these people, safety of these good citizens, safety of these fathers, safety of these mothers, safety of these children, and the safety of your citizens that trust you will do the right thing by them.
If you have any queries or require any additional information or assistance please feel free to write to me
Mr T A