04 Dec

Platin Cement Burner- Skyfill is a bad idea.


Nov 2017 Submission to ABP Platin 

PLATIN: We’re concerned that this project will stop us recycling

Phosphorus and Nitrogen are needed to grow food , not burn as Fuel for Cement kilns.

Zero Waste Alliance Ireland (ZWAI) are very concerned at the use of recyclable materials as Refuse Derived Fuel (RDF). We know that this is a dangerous manner of turning Landfill materials into Skyfill pollution. Cement kilns are not designed to manage in an environmentally safe manner the pollutants that arise from the burning of a mix of recyclable and landfill bound materials. We have objected to An Bord Pleanala when such BAD IDEAS are proposed, most recently in Limerick and Duleek.

We made an additional Oral Submission to the Inspector of
An Board Pleanála  on the 22nd November 2017 in regard to  the  Platin Cement Proposal. It is a 10 year permission to facilitate further replacement of fossil fuel with alternative fuels  (RDF) and allow for introduction of alternative raw materials in the manufacturing of cement at Platin Works Platin, Duleek, Co Meath

ZWAI are an advocacy group promoting ways to recycle & recover materials and keep resources away from waste disposal so that they can be sustainably recycled. We are  particularly concerned about materials that are finite or are limited in their natural availability. So naturally, we question the wisdom of burning materials at the Platin Cement Kiln that in particular contain phosphorus and nitrogen.

You can read our Oral Hearing submission here.

Valuable Nutrients are lost.

The waste categories listed by Irish Cement  below are proposed to be incinerated in the cement kiln. Initially almost all of these originally required the use of Natural Gas or Coal to make the ammonia fraction of fertilizer for their growth. By burning in a cement kiln, Phosphorus will be wasted and will not be recovered. This is an essential element that is necessary for fertilizer to produce food.

Categories of waste that are proposed to be burned at Platin cement factory


02 01 02


animal-tissue waste

19 08 05

sludges from treatment of urban waste water

02 01 03

plant-tissue waste

02 01 06

animal faeces, urine and manure (including spoiled straw), effluent, collected separately and treated off-site

19 12 06

sludges from on-site effluent treatment other than those mentioned in 19 11 05

02 03 05

sludges from on-site effluent treatment

19 08 05

sludges from treatment of urban waste water

19 08 12

sludges from biological treatment of industrial waste water other than those mentioned in 19 08 11

19 08 14

sludges from other treatment of industrial waste water other than those mentioned in 19 08 13

Zero Waste Alliance Ireland(ZWAI) demands that Sewage Sludge or any of the other similar categories listed by “Irish Cement” that contain Nitrogen and Phosphorus should not be burned in the cement kiln for the following reasons:

  1. The Fossil Fuels (Natural Gas and Coal) that are used to make ammonia gas for fertilizer are finite and will eventually be depleted. We must reduce significantly the greenhouse gas emissions associated with the making of ammonia fertilizer. Any finite material must instead be recycled.
  2. The Burning of Nitrogen (Ammonia) and its loss to the atmosphere results in this resource being no longer available to farmers as part of the fertilizer to grow food.
  3. The emission of NOx will cause ozone in sunlight conditions. At ground levels ozone will cause ambient air pollution and should therefore be avoided.
  4. The energy of the Nitrogen (Ammonia) recovered in the Cement Kiln will not replace or be equal to the total energy required for its original manufacture, its processing as an NPK fertilizer, its transport around the world or the energy for its application on farms.
  5. Because the nitrogen is not being recycled locally to grow food it forces the continuation of this very wasteful energy intensive Harber & Bosch method that is depleting the remaining finite resources of natural gas. This failure to recycle nitrogenous waste as a fertilizer is not sustainable.
  6. The Green House gases that are generated by the manufacturing of Ammonia using the Haber & Bosch process contribute to climate change and must be reduced and eventually avoided.
  7. Phosphorus fertilizer is likely to become expensive in Europe, India and other parts of the world over the coming 20 to 40 years as the resources of the USA and China, two of the three remaining countries with phosphorus rock begin to protect their own national supplies. When “peak phosphorus” is upon us and world demand is greater than the supply then no nation will have cheap phosphorus to sell to Ireland. Unless we recycle nutrients of nitrogen and phosphorus, food prices in supermarkets that are based on fossil fuel and mined phosphorus fertilizer will become volatile, then more expensive, then affordable and eventually will not be for sale at all.
  8. Phosphorus is a finite resource that can be replaced by no other element. If burned in cement kilns this strategically important resource will be lost and wasted forever.
    We must therefore recycle Nitrogen and Phosphorus. We must avoid the possibility of a world population collapse.

We ask  An Board Pleanála to prioritize the long term public interest and put this above the private short term interests of a private business. It is not in the public interest that we should ignore the need for future food security.

23 May

Big burners – application is back for Ringaskiddy Incinerator


Ringaskiddy Incinerator Proposal – wrong place, wrong time, wrong solution.

There’s more than a whiff of toxic smoke from this project –

( Application to An Bord Pleanála by Indaver Ireland Limited for Planning Permission for a
Proposed  Incinerator at Ringaskiddy, County Cork An Bord Pleanála Reference PL04.PA0045) –

and the arrogance exhibited by both an Bord Pleanala, the EPA and the Co Co Council Executive Management.

Whiff of  suspicious smoke.

Firstly An Bord Pleanála refused to defer an oral hearing into a proposed €160 million (240,000 tonne  Hazardous and municipal waste) incinerator for Ringaskiddy, Cork Harbour which was needed to allow the opponents time to examine the large application and associated documents.

One of the 260 objectors, Cork Harbour Alliance for a Safe Environment (Chase) said Bord Pleanála had refused an extension to the oral hearing start date , leaving just 12 working days to prepare objecions against the proposed Ringaskiddy Incinerator.

This preparation period of just 12 working days was in stark contrast with the consultation period of over 3½ years which the applicant, Indaver,  have had with An Bord Pleanála to prepare this third planning application on the same site.

This must be the  shortest oral hearing notice and the longest consultation period on record for such a dangerous proposal.

Secondly, the haste at which the Ringaskiddy proposed Incinerator proceedings were transacted gave rise to concerns among the attendees that this might be a ‘foregone conclusion’ and the Board was merely paying lip service to the oral hearing and inspectors efforts to examine the proposal’s implications. A notable absentee was the EPA, normally a essential player in such applications.


Overwhelming support for opponents.

An Bord Pleanála received over 260 submissions objecting to the planned Ringaskiddy incinerator including objections from all four Cork South Central TDs including Minister for Agriculture, Simon Coveney, andFianna Fáil leader, Micheál Martin.

These submissions, among which Zero Waste Alliance Ireland, contributed a 28 page objection,  included objections because of site unsuitability, accident risk and hazard, health concerns and gross conflict with the regeneration of the surrounding area, include submissions from the Permanent Defence Force Other Ranks Representative Association (PDFORA) which represents 800 sailors based at nearby Haulbowline Naval Base. No project is in such direct conflict with the Circular Economy policy direction as this proposal, whih will be dependent on rising levels of waste generation to remain viable for a projected 30 year lifspan.

They also include submissions from CIT Students’ Union president on behalf of students attending the National Maritime College of Ireland , the Air Corps and submissions from the Teachers’ Union of Ireland (TUI) representing lecturers at the college.

Over 113 oral  presentations were contributed at the oral Hearing held in the Carrigaline Cour Hotel,  Co Cork which ended on  10th May 2016 after  4 weeks.

EU Complain looming.

A notable EIS omission during the hearing, in conflict with Art 5 of Stockholm Convention,  was pointed out by ZWAI in their closing statement, opening  the path to register a complaint to the compliance committee.

A decision is expected by the Board of An Bord Pleanala by mid July 2016.

26 Jun

Circle of life and re-birth.

It’s not often we like to think of death but it’s facing everyone of the 7+ Billion folks on this planet at some future time. And being Eco aware , Zero Wasters would like to find the best ecological manner to exit this state of being.  Of all the options open to us one environmentally friendly way to deal with it comes from a game -changing Eco innovation from EcoLegacy which we’ve recently come across.

eco facts

eco facts , courtesy of ecolegacy

It embodies the circular economy on a personal level. Birth, life, death,re-birth. Just like the recycling and re-work approach, if we consider our mortal remains we would like it to be recycled in the most eco friendly manner. What better way than ,  as the circle of life go through its stages, to reduce our remains back to its basic elements and use these elements  to create new life in the form or a living plant that our nearest  and dearest can see and touch.

The EcoLegacy approach is just this. With 7 + Billion people on the planet we’re all going to pass away in the next 70 or so years and face a burial or cremation. Burial is unsustainable because we’re running out of land in Urban areas but the alternative , cremation , has  environmental drawbacks.  The average cremation uses a lot of energy (natural gas  , electricity)and emits over 160kg of CO² (depending on the equipment  used). As is the case of Incinerators, it’s a source of dioxins, smoke, ash and mercury pollution.

Now the ecoLegacy company has  a sustainable, third alternative, to take care of our departed that they call  – the ecoLation™ process.

Still in its early stages of adoption , ecoLation™ is a 4-step process that returns the loved one’s remains to their families as calcium and carbon powder,  in a biodegradable urn. The process used is environmentally friendly and non-polluting, unlike Cremation. The Urn has a hollow spot in the cover in which to place a tree seed. Families can then plant the urn and seed thus having a tree as a living reminder of their departed. It’s a living reminder of the departed and will breath new life into our planet.

It’s a nice thought to think of your departed playing a role in fighting climate change long after their passing. As the circle of life closes it reopens anew.


10 Jan

EPA reveal Ireland’s 2012 Dioxin levels

Ireland must be vigilant to maintain our low environmental Dioxin levels.

Dioxins have, in recent years, continued to generate environmental concerns that capture public attention. In order to maintain surveillance of dioxins, furans and other related pollutants, the Environmental Protection Agency (EPA) carries out a number of almost identical surveys based on levels found in cows’ milk.

The latesincinerator stackt report on dioxin levels in the Irish environment shows that dioxin levels in all of the samples taken in a 2012 survey were well below the relevant EU limits. The report is based on dioxin levels measured in cows’ milk in a 2012 survey. The report also shows that dioxin levels measured in this survey compare favourably with those taken from similar surveys in the EU and other countries.

This is the tenth such survey undertaken by the EPA since 1995 and the results are in line with the earlier studies.  A total of 38 samples were taken and, at an average of 10 per cent of the EU limit, concentrations of dioxins were low by international standards and comparisons.

How was the survey done?

The principal mechanism for the entry of dioxins into the environment in Ireland is by low-level emissions from multiple combustion sources to the atmosphere, with subsequent deposition onto vegetation such as grass.  Any dioxins on grass ingested by cows tend to concentrate in the milk fat. Hence, sampling for dioxin levels in the milk of grazing cows is the approach adopted.

The survey was carried out between June and early August 2012, during the peak outdoor grazing season, by taking a series of milk samples mainly from representative regional dairies.  Additional samples were also taken from localities that might be seen as areas of potential risk of raised dioxin levels.

While Zero Waste Ireland welcome’s the results we are concerned that testing in areas downwind of the operating waste incinerators is not done. It is by testing in the vulnerable areas that the real situation is seen. This must become a routine operation in areas where Waste Incinerators are planned or operational. For example only one sample is taken from the Carranstown area of Meath, the site of a large Commercial Waste Incinerator, which has recently received the ok to expand its capacity.

Main findings:

  • There was a slight decrease in average dioxin levels in 2012.  The levels found in the survey are well below the EU limit in milk and milk products.
  • Dioxin-like polychlorinated biphenyls (PCB) levels were also found to be lower in 2012 samples than those in 2011, by 25 per cent on average.
  • These differences – in average dioxin levels and dioxin-like PCB levels – are not significant either in environmental or analytical terms and can partly be explained by a downward revision of the International World Health Organization (WHO) toxicity factors for some of the dioxin compounds.
  • The results of this survey are in line with the dioxin results from the latest report from the Cork County Council animal health surveillance programme (published in December 2013) which has been operating in the Cork Harbour Region since 1991.
  • The data are also consistent with an FSAI breast milk study (2010) which confirmed low levels of exposure of the Irish population to dioxins and other micropollutants.
  • In view of the increased international awareness of the presence in the environment of brominated flame retardants (BFRs) and brominated dioxins (PBDD/PBDF), a broad range of these substances was also tested in the survey.  Only Polybrominated diphenyl ethers (PBDEs) were found in any appreciable quantities in the survey and are consistent with international norms.
  • Non-Dioxin PCBs were also measured for the first time. The levels found were not of concern.

The report Dioxin Levels in the Irish Environment – Tenth Assessment is available on the EPA website.

How do we measure Dioxins?

The WHO Toxic Equivalent is the current internationally recognised system for comparing dioxin toxicities of different samples.  Results are expressed in picograms of WHO Toxic Equivalent per gram of fat: 1 pg is 10-12 of a gram.

2012 Dioxin Levels: 

Average dioxin levels in 2012 slightly decreased from 0.261 pg WHO-TEQ/g in 2011 to 0.196 pg WHO-TEQ/g. The levels are well below the EU limit in milk and milk products. The revised EU limits are 2.5 pg WHO-TEQ/g for dioxins only, and 5.5 pg WHO-TEQ/g for dioxins and polychlorinated biphenyls (PCBs) combined.

What are Dioxins? 
Dioxins form a group of some 210 closely related, complex organic compounds, the vast majority of which are considered to have little environmental significance at the levels normally encountered. However, 17 of these substances have been shown to possess a very high toxicity, particularly in animal tests. The toxic responses include dermal effects, immunotoxicity and carcinogenicity, as well as reproductive and developmental toxicity. Dioxins arise mainly as unintentional by-products of incomplete combustion and from certain chemical processes. Similar effects are caused by some of the dioxin-like polychlorinated biphenyls (PCBs) and in order to conform to current practice, testing for these compounds was also included in this programme.

Sources of Dioxins
Although PCDDs and PCDFs are not produced intentionally except for research and analysis purposes their formation is often a by-product of many activities.  Some significant sources internationally are:

  • Incinerators and thermal treatment plants
  • Residential combustion
  • Open burning of waste (backyard burning, bonfires)
  • Wood preservation (~15%)
  • Iron and steel industry
  • Power production, non-ferrous metals, chemical industry
  • Traffic

Other Micropollutants
An emerging category of pollutants, brominated flame retardants (BFRs) and brominated dioxins (PBDD/PBDF) were measured as part of the main survey.  Brominated dioxins (PBDDs and PBDFs) are also formed unintentionally, mainly through incineration of wastes or accidental fires that include consumer products containing brominated flame retardants (BFRs). Many of the BFRs have been banned for future use because of their toxicity and environmental persistence but they continue to be found in many consumer products such as furniture, fabrics and electronic products.

Persistent Organic Pollutants (POPs) & the Stockholm Convention

Dioxins, PCBs and PBDEs (See Chapter 5) are among the substances listed as POPs in the Stockholm Convention. In keeping with its obligations under the Convention, the Environmental Protection Agency is designated as Ireland’s competent authority under the national POPs regulations. It  has prepared a National Implementation Plan on POPs which details the measures to be put in place to protect human health and the environment from the POPs that are
listed under the Convention, such as  dioxins, PCBs and PBDEs.
Read the plan herehttp://www.epa.ie/pubs/reports/other/dioxinresults/dioxinlevelsintheirishenvironment2012.html#.Us_pAPRdW8B

The plan ,to whch ZWAI contributed,  which was very late in being delivered, sets out further priority actions to support the control of POPs showing how it plans to limit and control POPs.

Sampling Strategy

Two types of sampling stations were chosen:

Type A background stations covering the entire country (24 samples)
Type B potential impact stations in areas of perceived potential risk (14 samples)
Type A samples were normally taken from full milk silos (30,000 to 50,000 gallons) in regional dairies. However there were a number of instances where sampling from silos was  not possible and the samples were taken instead from road tankers representative of the area to be covered.

Type B samples were taken from road tankers representing the
“potential impact” areas.

Test Sample locations.

An appendix to the Report shows the list of locations, however these are not very specific and we would welcome a detailed map of these test locations.
A1 Mitchelstown Area
A2 Co. Waterford
A3 Dublin South.Co./North Wicklow Area
A4 North Co. Wexford
A5 Charleville, Co Cork Area
A6 Ballyragget, Co Kilkenny Area
A7 Renmore, Co Galway Area
A8 Moate, Co Westmeath Area
A9 Tipperary Town/Thurles Areas
A10 Nenagh, Co. Tipperary Area
A11 Cavan/Longford/Leitrim
A12 Drinagh, Co Cork
A13 Bandon Area
A14 North Kerry Area
A15 Co Sligo
A16 Roscommon/East Galway
A18 Roscommon/Leitrim
A19 Co Monaghan
A20 Co Louth
A21 North Kildare/West Dublin
A22 So Kerry (Cahirciveen area)
A23 South Wexford
A24 SE Co. Mayo
A25 Co. Donegal
The potential impact samples B1 – B 18 were taken at 
B1 Carrigtwohill/Cobh/Great Island
B2 Aghada/East Cork Harbour
B3 Askeaton area
B4 Tarbert Co. Kerry
B5 Clarecastle, Co.Clare
B6 Cooraclare Co.Clare
B7 Ballydine, So. Tipperary
B8 Swords/Mulhuddart. Co.Dublin
B9 Grannagh, So.Kilkenny
B13 Kinsale (Dunderow) Co.Cork
B14 Ringaskiddy area. Co.Cork
B15 Crossakiel (nr Kells) Co.Meath
B17 Carranstown, Co.Meath
B18 Kinnegad, Co Westmeath