RTP Company, whose headquarters is in Winona, Minnesota has applied for planning permission to build a Polymer Compounding Facility, under the name of a newly formed subsidiary, Daly Products, on the Baltimore Road Skibbereen.
The factory they hope to build in Skibbereen is planned with four 16 metre emissions stacks; nevertheless the planning authorities and EPA have decided that they do not require an Environmental Impact Study and the facility requires no Integrated Pollution Control licence nor even an Emissions Licence.
In the Cork County Council Ecologist’s report, 18th December 2017, there is no consideration of the possible impact on the environment of nurdle pollution nor is there any consideration of the impact of waste water that will contain microplastics that will be contaminated with heavy metals, volatile organic compounds and many toxins associated with the process of manufacturing RTP products.
Currently the planning decision rests with An Bord Pleanála. They have twice deferred their decision and the latest given date by which the decision will be made was 26th September 2018 though this has now been pushed back another 2-4 weeks. Should they find in favour of RTP Company/Daly Products Save Our Skibbereen intend to apply for leave to bring an application for judicial review.
We fear for the safety of the Environment in and around Skibbereen and West Cork and we fear for the Marine Environment should this planning application be approved and the factory be allowed to go ahead.
In the Irish Times article, below, the EPA has classified microplastics as “a newly identified contaminant” in water sources, including drinking water, but said “the impact of them on people’s health has not yet been fully assessed and determined”. The EPA does not yet take into consideration the impact of microplastics in any assessment of planning applications by plastic manufacturers.
Link discovered between microplastics in rivers and wastewater treatment plants
That micro-plastics are a threat to our environment and our health is now becoming obvious. What is more serious, with regard to this proposed development, is the likelihood that these micro-plastics will contain many toxic chemicals and heavy metals due to the methods of production and the water based methods of removing contaminants from emissions.
The Air we Breathe
Interestingly, RTP Company in Winona does have to be licensed and is set in a Non Attainment Area, which means air pollution levels are high and persistently exceed the National Ambient Air Quality Standards (NAAQS).
Indeed this area of Winona is persistently sub-standard for pollution levels of ozone, lead, sulphur dioxide and particulate matter.[i]
Particulate matter refers to small solid particles and liquid droplets found in the air and mostly formed as a result of complex reactions of chemicals such as sulfur dioxide
Some particles, such as dust, dirt, soot, or smoke, are large or dark enough to be seen with the naked eye. Others are so small they can only be detected using an electron microscope and can be made up of hundreds of different chemicals.
They are so small that they can be inhaled and cause serious health problems both to humans and to animals. Particles can be deposited on the vegetation in the surrounding environment and in the water.
Water and air quality report for RTP in Winona, Minnesota[ii]
Surface, Ground and River Water Contamination
RTP Company headquarters is in Winona, Minnesota. Winona includes a large area of Impaired Waters, which means the regulations and controls are not stringent enough to meet the water quality standards set by states for the quality of surface and ground waters. The RTP Company polymer compounding facility in Winona is close to the banks of the Mississippi and pollutants found in the river include Mercury and Polychlorinated Biphenyls (PCBS).
The Mississippi River ranks 2nd in the nation for total toxic discharges. Along its course in Minnesota, 703,019 pounds of toxic chemicals were dumped by industrial facilities into the Mississippi River in 2010.[iii]
The planners assessment for the factory proposed for Skibbereen states that the “Main impact (will be) on local flora and fauna populations located downstream in the SAC from contaminated surface water on site”. This report states that surface water run off will be discharged into an ‘existing drain’. However this drain is currently a stream that runs into the ‘Assolas Stream’ that travels alongside the Baltimore Road towards Skibbereen and into the Caol Stream. The Caol Stream runs into the River Ilen which flows out to the Roaring Water Bay SAC just 7 kms away from the proposed site.Indeed the planners report also states that all surface and process water will be discharged through Skibbereen Waste Water Treatment Plant, which in turn discharges into the River Ilen.
What contamination will be in the discharged water?
The company have not verified what toxins may be in the water discharged through the Skibbereen Waste Water Treatment plant or found in the run off from contaminated surface water on site, however we do know from the planning reports that they will be using
- trace amounts of other Class II compounds
- other Class III compounds will be used
- and that there is likely to be sulphur oxide released.
Looking at the parent company in Winona Toxics Release Inventory History of Reported Chemicals Released in Pounds per Year at the Site. [iv] shows that the greatest toxic release in 2017 was from Antimony Products.
Finely dispersed particles of ANTIMONY form explosive mixtures in air and there is a risk of fire and explosion on contact with acids or halogens.[v] This risk of fire also poses an even greater air-borne pollutant risk, via deposition to the surrounding area and the SACs of Roaring Water Bay and Lough Hyne.
We do not know if RTP/Daly Products intends to create the same end use polymer in Skibbereen as they do in Winona. They have supplied scant information in their planning application. That the EPA have not requested that they apply for an Integrated Pollution Control or an Environmental Impact Assessment Licence then is all the more puzzling.
The Massive Impact of Toxic Nurdles
Adding to the risk of heavy metals and other toxins entering the River Ilen and the Marine Environment is the risk of plastic micro-bead pollution.
The factory will ship in tiny pellets of raw polymer called Nurdles. Each bulk truck can carry about 2 billion nurdles per load
Around the world these pre-production polymer pellets or Nurdles regularly get spilled in production, in road and rail transport and in shipping.
This is such a big problem that the industry itself has an initiative called ‘operation clean sweep’ which publishes ‘best practice’ to keep Nurdles out of the environment.Operation clean sweep has been running for 25 years and yet if you Google Nurdles, or Nurdle Spills you will find pages upon pages of reports of current spills, of volunteer clean up operations and of devastation to wildlife.
Many clean up specialist brought in for large spills state that a large Nurdle Spill is worse than an oil spill.
One polymer compounding factory in Sweden stated “our aim is to not lose a single pellet.”
However a study by the university of Gothenburg and published in Marine Pollution Bulletin estimated the total release of 5mm preproduction pellets (NURDLES) from this very same site into the surrounding environment is 36 million pellets annually. If fragments of pellets (down to 300 μm) are counted there is an hourly runoff, of over 500,000 plastic particles per hour released into the environment.
The same study showed that wherever there were compounding sites there were greater numbers of nurdles and fragments in the environment; and there were also spills around areas of subcontracted companies involved in transport, storage, cleaning and waste management.
A study in the river Rhine in 2015 showed that 60% of the identified plastic particles were 5 mm spherules (Nurdles) with a linkage to different industries along the river.
A recent study in the UK indicates a national yearly loss of around 53 billion pellets even when there are no major Nurdle spill reported anywhere.
The Irish EPA has looked at plastic pellets in freshwater streams and has listed molluscs, fish, crustaceans, amphibians and mammals that are at risk from micro-plastic pollution, and 13 different birds of conservation concern that are at risk of micro plastic pollution. The plastic get into these freshwater streams and rivers from production spills into storm drains as well as spills from transport.
In April 2018 a single trailer turned over on a bend in the the road near Pocono creek which runs into the Delaware River in Philadelpia. 49,000 lbs of nurdles were spilled. That was 1,125,000,000 x5mm spherules of plastic released into the environment. Local volunteers were left to do the clean up.
One pound of pelletized HDPE contains approximately 25,000 nurdles
The Threat to Fisheries
The EPA in Ireland in their studies of plastic in the fresh water environment showed how the water slows down as it reaches the lower courses and so many of the plastic nurdles are deposited in the estuaries.
These are hard enough to pick up from sand; if they were in the mud of the estuary you would need a beak to pick them up.
This is a picture of them in clusters in the water. They look like fish eggs and so fish and birds eat them.
These plastic pellets attract persistent organic pollutants. They are called persistent because, like the pellets they don’t disappear over time. They are mostly endocrine disruptors and affect fish, birds and mammals ability to breed and to lactate.
A study on behalf of The EPA in Ireland found manufacturing industries involved in the primary production and compounding of polymers, regulated under the IPPC licensing scheme, were found to emit micro-plastics (5 mm or smaller) to sewers. In one instance the EPA found that even though on a site-visit to the Plastic Compounder there was NO evidence of spillages, yet there was micro-plastic from that plant in the waste water treatment plant.
The waste water treatment plants use a system of screens to filter out large particles, however in most instances even their fine screens would not filter out 5mm nurdles, let alone the smaller pieces of plastic. Much of this plastic will go through into the discharge water – straight into the River Ilen and will rapidly travel the 7KM to mouth of the Estuary and into the Marine Environment there.
These deposited volatile organic compounds and particulate, heavy metals, nurdles and their associated persistent organic pollutants will enter the Ilen Estuary and the protected areas of Roaring Water Bay and the islands; on which we depend for :
- Mussel and Oyster farming
- Crayfish and Crabbing
- Food tourism
- Eco tourism
And on which we depend as a beautiful diverse and restful area to live in and to visit.
Too Much Is At Risk
The environment of West Cork is at risk. Too many jobs are at risk. Too much is already invested in this beautiful part of the world to be wrecked by a poor planning decision that brings no money in to Skibbereen and very few jobs.
We remain amazed that no Environmental Impact Statement has been asked for and that the EPA have not stated a requirement for the facility to be licenced or registered. The private arrangement made with Irish Water for discharge of waste appears to negate the need for the company to be regulated for waste water emissions, yet no mention has been made in the planning documents of the Skibbereen Waste Water Treatment Plant’s ability to adequately process and remove the risk of Toxic Release Emissions nor whether it holds the correct licence for industrial emissions from a petrochemical based industry.
The river Ilen is classed as a grade ‘A’ river. It is amongst the cleanest Waters in Ireland. A very recent study involving collecting water samples from 75 sites around the world during the Volvo Ocean Race showed that The West of Ireland is one of only three sites sampled with no trace of microplastic particles.[vi]
West Cork is special; Let’s keep it that way.