12. The Garden Discussion
After assessing the regulatory around ReChem I tackled the company directly. I telephoned the plant manager, Robin Drewett, and he offered to come and meet me at home. On a fine summer’s day we talked pleasantly in the garden for more than two hours and I took notes. I queried the measurement of PCB destruction efficiency at some length. I also knew that before the need to destroy PCBs had superseded the production of the chemicals, the American chemical giant Monsanto was the primary producer of our western world’s PCBs. Amidst growing concern in the US about toxicity and with Monsanto in the firing line over PCB contamination, in 1971 Newport took over from Monsanto’s Alabama plant as the company’s centre of PCB production.In 1977, the clock was ticking against the PCBs in existing applications when Monsanto in Newport voluntarily ended its own PCB production and waste from the chemical producer was already implicated in the contamination of a number of landfill quarries in South Wales. In some parts of the world there were reports of chloracne amongst workers exposed to high levels of PCBs and early indications of more subtle, but serious, longer term health risks that could result from low levels of exposure.
For electrical applications PCBs had two important properties. They were good electrical insulators and they had notable chemical and thermal stability. When production went out of fashion because of health concerns, the increasing demand for the disposal of PCB-containing transformers and capacitors translated into earnings for ReChem. In the whole of the UK, there were four major incinerators. Of these, only ReChem’s Scottish and Welsh Plants, together with Cleanaway at Elsmere Port were approved by the Inspectorate to burn PCBs. Cleanaway’s plant was allowed to burn PCB liquids, but was not approved to take on the tougher task of trying to handle the metal transformers and capacitors with PCBs inside them. Rechem was the sole UK company allowed to do that and then only in Pontypool, after Bonnybridge’s closure 1984. The company’s third incinerator, in Fawley, didn’t burn PCBs in any form at that time.
Their resistance to heat was an obvious drawback when wishing to burn the waste chemicals.That property and the general resistance to decomposition are qualities closely related to their chemical construction.At the heart of many petrochemicals lies benzene, an iconic hydrocarbon with its molecular structure represented diagrammatically by a hexagon of links and with carbon atoms at each of the corners. Shown sticking out from each of those carbon corners is a hydrogen atom. This arrangement is frequently called the benzene ring structure. Benzene itself is highly flammable and its colourful history includes applications ranging from perfumery to octane elevation in fuel. However as signs of its adverse health effects spread through the second half of the 20th Century, benzene’s use became restricted.
A hexagonal benzene “ring” minus one of its six hydrogen atoms is called a phenyl ring and that is then susceptible to joining with another phenyl ring and two of those diminished phenyl hexagons can join to make the biphenyl structure, which is the foundation for a PCB molecule. The join between the carbon-cornered hexagons is not side-on as in a honeycomb but corner-to-corner, leaving ten of the twelve corners with protruding hydrogen atoms to which other atoms can now attach. If chlorine atoms join to the hydrogen atoms at those corners, a polychlorinated biphenyl is made. There can be numerous arrangements whereby different numbers of chlorine atoms are attached to a selection of the 10 protruding hydrogens. Hence there can be 209 different PCBs (or PCB congeners) and they have differing degrees of toxicity. Each congener has a different name, to indicate the number of chlorine atoms and their positions in that PCB molecule.
When PCBs were first developed, it appears that their dangers weren’t fully appreciated and the question of what to do with waste PCBs was not a tasking one. When disposal became necessary, dumping was the choice before the chemicals began to show up in the environment and found their way to all corners of the Earth. Because of its stubborn nature, burning the stuff wouldn’t have been an obvious choice and would have been an even less attractive idea if the legacy of dioxins and furans had then been considered. ReChem, however, did find the marriage of PCBs with flammable waste a commercially attractive meeting of opposite types of material. The commercial fluid that contained PCBs in electrical equipment also contained chlorinated benzene and burning the blend was, unfortunately, asking for dioxins and furans as an outcome. The molecular structure of those slightly more intricate chemicals is similar to PCBs but this time the hexagons are side to side, making a pair of corner-to-corner links. Furans have, in one of those links, an oxygen atom. Dioxins have oxygen embedded in both links. Furans and dioxins then have only eight corners left for chlorine atoms to attach to. When it was realised that this small departure from the structure of PCBs could make large differences in toxic properties, the dioxins and furans came to be termed “ultra-toxins”. The symmetrical dioxin type which is termed 2,3,7,8 tetrachlorodibenzo-para-dioxin was then regarded as the worst of the new breed. Further research has now quantified the differing toxicities of the 209 PCB structures, plus the 75 different dioxins and the 135 furans, with the result that some PCBs have been elevated to “dioxin like” toxicity and, for convenience, the term “dioxins” is sometimes used to embrace furans too.
When I began my inquiries in May 1984, I soon found that the question of PCBs being converted to dioxins in the incinerator was an area of discussion between me and officialdom that I had to tread carefully in for fear of appearing a little loopy. Furthermore, I found that the hypothesis of “de novo” synthesis of dioxins, by recombination of simpler products of combustion, was an idea likely to get me labelled as seriously deranged. Therefore, in my discussion with Rechem’s plant manager in the sunny garden, I simply focussed on the conditions necessary for destroying PCBs. I wanted to know how such conditions were sustained in Rechem’s incinerator. The plant manager actually retracted claims of total destruction, and replaced it with 99.999% destruction. I was still expected to be impressed and to regard that number as nigh on 100%. This aspect of the discussion began my 15-year attachment to millionths, billionths and trillionths. Even if 99.999% of something is destroyed it obviously means 0.001% is not destroyed. This is one part in one hundred thousand, or ten parts per millionWith 1 tonne being 1000 kg or a million grams, it meant one tonne of PCBs incinerated could leave 10 grams to be emitted through the stack or left in the residue or to go elsewhere. Therefore a hundred tonnes of PCBs could leave 1 kilogram of PCBs in the environment. If ReChem handled thousands of tonnes, then we could be talking in terms of tens of kilograms of PCBs leftover – and much more if 99.999% destruction wasn’t constantly achieved.
I was told that PCB destruction efficiency was measured by spot checks and calculations. Only infrequently did an Inspector visit to monitor the process and there was no continuous measurement for destruction efficiency or for the emissions of PCBs. Furthermore, there was some stretching of what little official guidance was in existence. I learned that the regulatory 1100C recommendation had been lowered to 900C, possibly because of unforeseen problems at the higher temperature. This was said to be compensated for by a longer cooking time for the chemicals in the incinerator, which were all the while to be bathed in the required 3% excess of oxygen.I still wasn’t happy when, shortly afterwards, I saw in ReChem’s literature a destruction efficiency of 99.9999%, meaning ten times less residual PCBs than I’d first been told. It sounded better, but I believed it less likely to be achieved, given the vagaries of the plant. In our discussion we didn’t begin to speak of possible PCB releases that might occur prior to incineration during the handling of the materials. That aspect of the process wasn’t near the top of my list of questions since my meeting with Robin Drewett took place before I met ex-Rechem man Martin Faye. The ex-incinerator operative’s account of events on the incinerator and in the waste handling areas where the technology of the pick-axe was employed in PCB preparation meant that you didn’t need to get as technical as I had been getting in order to envisage PCBs escaping.
Now I was by no means a chemical prude, having had contact with many nasty substances at work, and I wasn’t instantly alarmed at the results of my calculations for the emissions of PCBs.On an aluminium strip degreaser, I sometimes needed to explore malfunctions by stretching my head under the hood of a tank containing hot, fuming trichloroethylene. I had another tank of steaming, highly concentrated sulphuric acid which I sometimes needed to investigate at close quarters. I came into frequent contact with carbon tetrachloride and I entered environments rich in asbestos. I couldn’t keep out of the way of corrosive hydraulic fluid, I had a few soakings in kerosene from rolling mill coolant sprays and my responsibilities included the organisation of medical checks for nasal damage due to the use of chromates in the finishing of certain aluminium products. Because of my familiarity with hazardous chemicals I was probably less twitchy than most about the prospect of small releases from ReChem.I would have probably accepted the quoted destruction efficiency if I hadn’t gained the impression that the company wanted to gloss over the proportion of PCBs that would escape from the plant and if I did believe that the destruction figure could be guaranteed and if some of the undestroyed PCBs hadn’t come from other countries. Even if I told myself that my assessment of the technology was over-critical, then the black smoke still worried me, as did as the constant smell from the plant. Actually when I mentioned “black smoke” to Robin Drewett, he had the stock answer that it was an optical illusion resulting from the interaction of light with sodium chloride in the emission.This could be produced in the chlorine removal process at the base of the stack, when sodium hydroxide was used to extract the chlorine from the emissions. Tricks of the light were not out of the question, but I wasn’t convinced that what I was seeing was always the sun shining on salt in the air. By then I’d observed smoke pouring from the stack when looking from above it, below it, at all angles and in sun and shade.
I was disturbed by the plant manager’s reluctance to acknowledge the true nature of the plume from the incinerator and the implications that this phenomenon might have for the claim of controlled destruction efficiency. Rechem and the regulators persisted with the optical illusion ploy for many years and would have succeeded in convincing those who wanted to hear it, but when it came to the smell, any claim that this phenomenon was also an illusion was untenable. The continuous, cloying ReChem stink was part of the normal ambience around the plant and it appeared to come not just from the stack, but from pre-incineration activities too. Smell alone was an indication that some chemicals were escaping into the atmosphere and I knew that whatever techniques were employed to measure incinerator destruction efficiency, there was no provision for quantifying emissions from elsewhere at the site. One potential source of such emissions was in transformer handling, where PCB fluid for burning was extracted from transformers before the transformers were loaded into the incinerator to burn-off the dregs that couldn’t be otherwise removed.
When back in industry, for several years I had lived and breathed furnaces. They weren’t furnaces for incinerating but furnaces for heating aluminium. I would have rated these furnaces as being easier to control than an incinerator, partly because the conditions inside were relatively constant and partly because of all the control mechanisms employed. Nevertheless I grew to respect their temperamental personalities. For one thing, the temperature was unlikely to be uniform throughout a large furnace. To monitor the variation in temperature, we would occasionally rig-up sensors in thirty-two different locations. Our furnaces were well sealed to the outside world and had huge internal fans agitating the atmosphere to even-out the temperature. Just as with a cake in an oven, opening a furnace door would have disastrous consequences for furnace temperature. The effect of even a small leak in a door seal could be noticed instantly on the many temperature displays. It wasn’t just that the Pontypool incinerator didn’t have the degree of monitoring sophistication I would have liked, but the changing nature of the atmosphere inside meant that sustaining a high enough temperature would be much more of a challenge than in my simpler furnaces, which themselves could be difficult.That large and often open incinerator door appeared to be an anachronism.
Even to an uninitiated onlooker, the performance of the incinerator was clearly affected by the opening of that large door of Cell One. In fact the door was quite a local attraction because of the excitement associated with it. Waste with sufficient liquidity could be pumped into the flames through pipes and nozzles and, there was there was the potential for good control over its combustion conditions if it was sufficiently homogeneous. What took more of my attention was the incineration of what was termed “solid” waste. Barrels, capacitors, transformers and other items were fed from the forks of a truck through the vertically-opening heavy steel door and onto the furnace hearth. I was perplexed as to how temperature could be controlled when cold air was rushing in and I wasn’t satisfied with explanations of a more controlled zone of combustion further along the fireway. Checking the circulation and composition of the atmosphere in furnaces had been one of my routine tasks in industry and it was fascinating. It wasn’t just the temperature that varied in a furnace, but the mix of gases would change from time to time and place to place in the furnace. Applied to ReChem’s incinerator my recollections made me think that the variation in the gaseous components could be as profound as temperature variability. The plant manager assured me that skilful calculations of the ratio between flammable and less flammable materials going into the incinerator were the foundation for the control of combustion conditions. I agreed, but I was taken aback by his reliance on the theoretical approach. I wanted to hear more about instrumentation but that wasn’t forthcoming.
After some hours of technical probing, I wasn’t prepared to condemn the incinerator outright and I still had room to be persuaded that my growing fears were unfounded. On that sunny afternoon in the garden I might even have just left it there, if not for my unease about industrial incentives. It was that comparison which swung my view. There were three strands in assuring the quality of our aluminium factory’s output. One was chemical analysis, to ensure that the precise constituents of the ingredients in a specific aluminium alloy met the specification, since were numerous different recipes for the aluminium alloys, depending on their use. Aluminium for lithographic printing plates needed to be almost pure aluminium. Alloy section for use in buildings had a liberal sprinkling of magnesium. Aircraft alloys relied on additional copper. Other ingredients were also needed in small but important amounts. Another arm of quality assurance was testing the finished product, to ensure that it would perform as expected.For army tanks, impact resistance was obviously important; for ships, anti-corrosion qualities were required and for drinks can production, ductility went with strength. The third and the most extensive dimension of quality assurance lay in controlling the production processes to such a degree that testing and analysis was only a back-up. If the checks were left until the product was finished then failure could be very costly. There would be an annoyed customer and the expence of re-making the material. In my time at Alcan I saw the philosophy and techniques of process control become so sophisticated that testing the finished product became almost superfluous. With all this in mind, I tried to draw a parallel for the incentives driving ReChem. I asked myself who were ReChem’s customers, what were the incinerator’s products, who was setting the standards, what clout did quality control personnel have and who paid the price if the process went wrong ?
My take on incentives revealed an inherent difficulty facing the whole waste business with its reversed commerce.ReChem didn’t send products to customers. The company’s customers were simultaneously its suppliers, who may have been uninterested in what the incinerator actually produced. I didn’t see how those customers could have a strong leverage on the quality of the plants operation. Would they be concerned as long as the waste was off their hands? Whenever I stood amongst the rolling mills, furnaces and clattering machinery in my own industry, even with the pressure for production I felt a constant commercial incentive to get things right. I couldn’t envisage a parallel in waste processing. If I’d been in ReChem’s position, without customers influencing operational standards and without a strong regulatory enforcer, I would have found it hard to justify sacrificing productivity and profits in favour of quality. I would have found it even harder to justify investments in technology or process control to achieve standards that would have no influence on financial performance. With its customers not receiving the tangible products of the plant, I concluded that the commercial incentives to perform well couldn’t have been as great for a waste processor as they were in normal industry and that burning badly could actually be lucrative.So, it was the direction in which incentives worked in the waste business waste that sealed my misgivings about the whole operation and ensured the continuation of my enquiries.
On that sunny afternoon in 1984, I don’t think the plant manager would have been too concerned about my probing of his destruction efficiency guarantees or about my calculations of possible emissions. He would have been well aware of the practical difficulties facing anyone wishing to prove that he was wrong. Detecting contamination in the environment and then tying to identify the source of chemicals that didn’t carry a company logo was nigh on impossible. ReChem’s plant manager had been exceptionally pleasant and I believe very sincere in his attempts to re-assure me but our conversation ended with a polite agreement to disagree and with my suspicions reinforced.
My next line of inquiry was into the company’s corporate position. Luckily, Companies House had been transferred from London to nearby Cardiff, so I spent a morning in the new building studying microfiches of the British Electric Traction conglomerate. There, alongside ReChem in the BET portfolio, I saw household names such as Wembley Stadium and I recognised some important people amongst the company directors. This particular bit of research was soon to be influential in campaigning and it was arguably influential in ReChem’s whole future. At the same time as investigating the corporate structure I wanted to further my inquiries about the incinerator design so I took the trouble to find the engineering company responsible for the Pontypool plant. I had a fruitful conversation with designer John Ainsworth and we concurred that the incinerator may have been running below its temperature potential because of an unforeseen risk to refractory material and possibly because the design was originally not so orientated towards the large solid items going in through a furnace door. He was also perturbed by rumoured increases in the burning of PCBs and other halogenated compounds.
With my inquiries continuing, the escalation from probing to protest really began as I looked out of the bedroom window again, this time not after, but before bedtime. At around 11 pm, against the dark night sky there loomed even darker clouds, tumbling down the valley for miles. I could guess the source, but I couldn’t seee the incinerator from home I telephoned my close friend, Jeff Malyn. Jeff and his wife Ann were still up, with their children Ceri and Laura in bed.The family’s home was on another hill overlooking the valley and it was higher than my vantage point.I asked Jeff if he could see the source of the clouds. He confirmed it was certainly Rechem and he immediately drove the few miles from his home to mine. We both felt we wouldn’t rest with the smoke accumulating whilst our children slept, so we drove towards ReChem and soon came across the dense outpourings of the incinerator stack. Not a steady stream of smoke, it was more like a volcanic eruption, bursting its way into the air and expanding violently with a life of its own. Standing outside the plant, we were enveloped in the stuff. We shouted through the steel security gates, but failed to draw attention. When annoyed, Jeff could be a fiery character and there was no holding him back at that time. He shook the gates, setting off alarms that sent ReChem’s people out to us. We explained why we were there and demanded that the emissions stop. I’m not sure whether it was the firmness of our request or the pandemonium created by the alarms, but the smoke soon began to die down. We also asked to see the same plant manager that I’d previously spoken with. He lived some distance away, but he arrived around midnight. During our long discussion into the early hours of the morning the emissions ended and it appeared that work at the plant had come to a standstill. Despite not feeling reassured about the plant’s future performance, Jeff and I went home satisfied that our physical presence had made an immediate impact. That was our very first protest. In the weeks that followed we were joined by others in devising a strategy for campaigning that would soon be conducted under the banner of STEAM.