We have been particularly concerned about ultrafine particles emitted by incineration. Ultrafine particles are PM 0.1 that is particles of less than 0.1 micron or 100 nanometers in diameter. Nanoparticles of otherwise benign substances are now found to be toxic at this small scale. The human body has no defenses against them.
The fabric filtration Flue Gas Treatment technologies proposed by the applicant are inadequate in stopping these particles.
The scientific understanding of these particles is incomplete and consequently emission levels or controls for them do not yet form part of the WHO guidelines or part of the EU standards.
Ultrafine particles have not been studied in the EIS despite our requests.
DCC failed to address in the EIS the health impact of ultrafine particulates despite being asked to do so by us in person, at public meetings, at private meetings, via written submissions and in letters during the public scoping exercise.
See our attached submissions and correspondence with DCC on the matter.
We reference a report from the WHO (see reference below). This report lists some 200 relevant papers dealing with air pollution. The EIS makes no reference to papers such as these in its analysis of air pollution particularly that caused by ultrafine particulates. Dr Schrenk makes no reference to ultrafine particulates (other than in his criticism of the EcoMed paper).
Since these particles are so dangerous the precautionary principle should apply in the interim and no new source should be permitted. In particular a concentrated source like an incinerator located in the capital city is contrary to the precautionary principle.
The EIS is deficient in this respect.