[] TL: POISON FACTORY, COALITE UK CHEMICALS SO: Greenpeace UK (GP) DT: 1992 Keywords: toxics chemicals problems uk europe dioxins food health greenpeace reports gp / The Poison Factory: The Story of Coalite Chemicals (GP) The scandal This is the story of Coalite Chemicals, and the worst case of dioxin contamination ever found in the UK. Dioxin, one of the most deadly synthetic chemicals known to man, has polluted land, air and rivers around Coalite's Derbyshire plant. Farmers were banned from selling their milk and meat because of the contamination and there have been health scares among local residents. But calls for a public inquiry have been thrown out. The recent decision by Dr David Slater, head of Her Majesty's Inspectorate of Pollution (HMIP), to allow the Coalite plant to continue operating, demonstrates the Government's failure to protect the environment. A new investigation by Greenpeace has revealed that pollution problems at Coalite's plant are much worse than HMIP, the Government watchdogs, have admitted. Greenpeace obtained samples from inside the plant and discovered that high levels of dioxin and other toxic pollutants being produced at Coalite have been ignored by pollution inspectors. Greenpeace is calling on the Government to shut down the Coalite Chemicals plant and hold a full public inquiry into the contamination of the locality. Greenpeace is also pressing the Government to honour its international commitments to eliminate deadly chemicals, such as those produced by Coalite, from the UK environment. Contents 1. Summary 2. Coalite, the factory: Manufacturing and applications. 3. The Greenpeace evidence: Contamination is eight times higher than reported by the Government's pollution inspectors. 4. Dioxin in the environment: Dioxin discharges from Coalite incinerator into the air and local river. 5. Poisoned milk: The Derbyshire farmers banned from selling milk because of dioxin contamination. 6. Highest levels ever: More dioxin recorded in local milk than ever before in the UK. 7. Poison river: Dioxin in river downstream from Coalite's factory is 2000 times greater than upstream. 8. Symptoms but not the cause: Contamination source is unidentified. 9. The danger - organochlorines: Deadly dioxins and chlorophenols. 10. A history of pollution: Explosion at Coalite 1968 11. Calls for a public enquiry: Environment minister rejects calls for a public inquiry. 12. Chemical fire at Coalite: Chemical warehouse containing 2,4,5-T destroyed by a fire in 1986. 13. Effects on health: Health checks reveal contamination. 14. Dioxin diet: Local produce may be contaminated. 15. Cancer clusters: Evidence of cancer clusters. 16. Permit to pollute: Regulatory authorities give Coalite a license despite history of contamination. 17. Not in breach of law: The government's view. 18. Failure of the regulatory authorities: The Government bodies responsible for the protection of the local people and the environment, fail in their duty. 19. Ministry of Agriculture Fisheries and Food: Failure 20. Her Majesty's Inspectorate of Pollution: Fail to protect. 21. National River Authority: Too little too late. 22. Toxic Legacy: Dioxin still remains. 23. Who is to blame? Why has this pollution continued unabated. 24. Who will pay? Who will compensate the victims of the pollution. 25. The Company: What will happen if the company go bust? 26. Greenpeace demands 27. Chronology of Events Appendix 1 Anglo United/Coalite Chemicals Financial Information. Appendix 2 Coalite Chemicals Products. Appendix 3 Table shows a comparison between the Greenpeace sample results and those of Her Majesty's Inspectorate of Pollution. Appendix 4 List of chemicals identified in the Greenpeace samples. 1. The Poison Factory summary of findings ù The following is a dossier on Coalite Chemicals, which exposes the scandalous history of dioxin contamination from Coalite's plant, near Bolsover, Derbyshire. ù Dioxins are among the most toxic synthetic chemicals known to man. They are known to cause cancers, genetic defects, increase the risk of diabetes and reduce sperm counts. Even tiny amounts can interfere with biological processes. One millionth of a gram is enough to kill a guinea pig. For more than 25 years Coalite workers, local people and farmers have been exposed to high levels of dioxins emanating from this plant. ù Dioxins are by-products from the production of chlorinated chemicals, such as chlorophenols which are made at the Coalite factory. ù Samples taken by Greenpeace prove that the levels of dioxin in Coalite's production wastes from the chlorophenols and other organochlorine processes are eight times higher than those previously identified by Her Majesty's Inspectorate of Pollution (HMIP), the Government agency responsible for monitoring pollution. ù A study by the Ministry of Agriculture, Fisheries and Food (MAFF) in June 1991 revealed that milk from local farms was so severely contaminated with dioxin, it was unacceptable for consumption and could no longer be sold. Other MAFF samples showed that dioxin levels in grass and plants around the factory were 1000 times higher than the UK average. ù The NRA reported the highest levels of dioxins ever found in the UK, in sediments from the River Doe Lea. Levels downstream from Coalite were 2000 times higher than similar samples taken from streams feeding the river and 1000 times higher than background levels. ù In spite of these existing high levels of toxic pollution, HMIP has authorised Coalite to re-open its incinerator, closed in 1991 when it was found to be leaking dioxins. ù The Government agencies have failed to recognise the chlorophenol and organochlorine production processes as the source of the dioxin contamination around Coalite. ù By authorising Coalite to continue their operations they have given the company a licence to contaminate. They have also compromised the UK Government's commitment to eliminate dioxins and other organochlorines from the environment. Greenpeace demands: ù That the manufacture of chlorophenols and related organochlorines at the Coalite plant be stopped immediately, and that the whole plant be investigated to identify the primary sources of dioxins. ù That the authorisation of the on-site incinerator be revoked by HMIP. ù That there be a full and independent public inquiry into the dioxin contamination around Bolsover, and the Coalite site. ù That the UK Government immediately acts to prioritise elimination programmes for organochlorine discharges and emissions into the environment, in line with its 1992 Paris Convention commitment. 2. Coalite, the factory 2.1 The Coalite plant in Shuttlewood, Derbyshire, manufactures organochlorines and other chemicals including chlorophenols. Chlorophenols are chlorinated chemicals whose production provides the ideal conditions for the formation of dioxins and other organochlorines as byproducts. Dioxins will also be produced in the manufacture of other chlorinated compounds at Coalite, though probably in lower concentrations. It is these processes which are the source of the serious dioxin contamination of the local area. 2.2 The Coalite plant is divided into two manufacturing areas - smokeless fuels and chemicals. The smokeless fuels plant extracts the tar from coal so that it burns more cleanly. The dioxin contamination problem arises from the chemicals plant where the coal tars from the smokeless fuels plant are turned into chlorinated chemicals including the highly toxic trichlorophenols. 2.3 Coalite Chemicals manufactures a wide range of chemical intermediates which are used in applications as diverse as adhesives, biocides, fungicides for crops, wood preservation chemicals and photographic film (see Appendix 2) 2.4 The production of trichlorophenol (TCP) uses by-products from the smokeless-fuel process and chlorine bought in from Hays Chemicals, Sandbach, Cheshire. Coalite are the only manufacturer of trichlorophenols in the UK. Trichlorophenols are sold on to other manufacturers for products such as antiseptic and hair care products. 2.5 Workers, residents and farmers have been exposed for over 25 years to high levels of dioxin from this plant, and the Government authorities responsible for the protection of the local people and the environment have failed to protect them. 3. The Greenpeace evidence 3.1 New evidence from Greenpeace reveals that the levels of dioxins produced in wastes from Coalite's organochlorine and chlorophenols plants are more than eight times higher than the very high levels previously identified by Her Majesty's Inspectorate of Pollution (HMIP), the regulatory authority responsible for the Coalite plant. 3.2 In August 1991, HMIP took for dioxin analysis a series of samples from Coalite's on site incinerator and samples of the feed stock, which is made up of the chlorophenol and other process wastes. Results were published in December 1991. HMlP's analysis of the wastes showed that it was dominated by very large concentrations of dioxins. HMIP found there to be 2.4 parts per million (ppm) of total dioxins in the wastes, although they appeared to be unconcerned about the significance of this. 3.3 No further results have been released by HMIP. If any further analysis was done, the results have not been made public. The feed stock analysis also shows a large number of other toxic organochlorines, which could have been released along with the pollutants HMIP found coming from the incinerator. Yet no one has checked to see if the local land or farm animals are contaminated with these chemicals. 3.4 In February this year Greenpeace collected samples of the waste residues from the organochlorine and chlorophenols plants and the feed stock for the in-house incinerator. Our results reveal that the feed stock contains extraordinarily high levels of dioxin. Greenpeace found a concentration of 21.4 ppm of total dioxin in the feed stock, more than eight times higher than the very high levels previously reported by HMIP. The concentration in Greenpeace's analysis of the feed stock is equivalent to 0.25ppm of 2,3,7,8-TCDD, the most toxic dioxin of them all. 3.5 Figure 1 (omitted here; unscannable) shows a comparison between HMIP's samples of the incinerator feed stock and Greenpeace's samples. The difference in these analyses highlights the variability of such wastes. The difference in the congener profile - the "fingerprint" - of the wastes also suggests that dioxins are being produced from more than one source within the Coalite plant. Where complex mixtures of chemicals are being chlorinated and distilled, as happens at Coalite, this would be expected. 3.6 The Greenpeace results show that the processes at the plant are themselves producing extraordinarily high levels of dioxin and other toxic organochlorines which inevitably will be escaping into the environment. The incinerator is not the only route by which dioxins will reach the environment. 3.7 Coalite stores large quantities of waste from the chlorination and chlorophenols processes on site prior to incineration. As well as the very high levels found in the incinerator feed stock, Greenpeace results also showed that another tank of chlorinated wastes contained 87 ppm of total dioxins, (equivalent to 0.86ppm of 2,3,7,8-TCDD) though this would probably be diluted before being fed to the incinerator. Greenpeace calculations suggest that, if filled to capacity, the two main storage tanks on the site would contain the equivalent of 1.56 kg of 2,3,7,8-TCDD, the most toxic form of dioxin. One millionth of one gram of TCDD is sufficient to kill a guinea-pig. This enormous volume of dioxin is exposed directly to the environment via the air vents in the tanks, and evaporation of dioxin and the other poisonous chemicals in these tanks, could constitute a considerable, but unstudied, source of contamination. The buildings where these wastes are produced must also be contaminated and will also be acting as sources of dioxin into the environment. It is absurd that HMIP has taken the trouble to investigate the incinerator and to monitor the air around Coalite, yet apparently has not looked at the buildings where the dioxins are being created. 3.8 HMIP have made only one analysis of the other organochlorines which are emitted from this process and have not assessed the effects they have on the environment. 3.9 The Greenpeace samples of Coalites wastes also showed the presence of 7 other organochlorines in the incinerator feed stock, and 11 in the stored wastes (see appendix 4). Many of these were chlorophenols. Organochlorines are of concern because they are often persistent, toxic and bioaccumulative and have been found to disrupt biological systems. 4. Dioxin in the environment 4.1 Any process which produces such a high level of dioxin contaminated wastes can never be cleaned up by "end of pipe" technologies such as incineration. Incineration cannot totally destroy such huge amounts of contaminants but will merely disperse them into the wider environment. It will also actually create additional dioxins during the burning of organochlorine wastes. 4.2 As a result of the analyses of dioxin emissions from the incinerator, HMIP closed the incinerator down. However, they did not investigate any other possible source of dioxins from the site/ despite the evidence from the samples of the incinerator feed stock which showed that the manufacturing process itself was generating extraordinary quantities of dioxins. 5. Poisoned milk 5.1 There have been problems and concerns about the Coalite operations over the years, but they have been mainly restricted to the plant premises. In March 1991 a new twist to the Coalite story began. Gordon and Gladys Rockley, owners of the Woodside dairy farm near the Coalite plant, received a visit from the Milk Marketing Board. The Board took a special one-off milk test. The Rockleys were untroubled they were expert farmers with nothing to worry about. Or so they thought. Two weeks after the test was done, MAFF rang them to say there was a problem with the milk; it was contaminated with dioxin and no more was to be sold until the problem was sorted out. 5.2 The full extent of the dioxin contamination of the local food chain emerged a couple of months later in June 1991 when MAFF announced elevated levels of dioxin in milk in 27 Derbyshire farms. As well as the Rockleys' Woodside Farm, the other farm immediately affected was Larch Farm, owned by the Merkin family. Here too, milk sales came to an abrupt halt. Both farms are within one kilometre of the Coalite site. 6. Highest levels ever 6.1 In October 1991, MAFF reported that it had discovered the highest level of dioxins yet found in the UK, in milk from a third herd of suckling cows at Woodhouse Farm. This farm is even closer to Coalite than the other two farms. 6.2 Dr Richard Burt of MAFF said the contaminated milk found at Bolsover "is the highest dioxin level that I have found anywhere in the country. As far as I know this is the highest that has ever been recorded". 6.3 Although MAFF attempted to reassure the local population by saying that the milk from this farm was not for human consumption, this ignored the fact that calves had been sold for human consumption - calves which had been fed on this milk, transferring the dioxins to their bodies, and therefore into the meat. MAFF went on to ban the sale of meat from the farm. 7. Poisoned river 7.1 Following the results of HMIP's sampling in August 1991, which showed high concentrations of dioxins entering the firm's liquid effluent stream via the incinerator's scrubber - the National Rivers Authority (NRA) detected dioxins in the site's discharge to the River Doe Lea. Yet the permit issued by the NRA and held by Coalite, does not allow dioxins to be discharged into the River Doe Lea. 7.2 Levels of dioxin downstream of the plant were 2000 times higher than peak values found in streams feeding the rivers and 1000 times greater than background levels. 7.3 Sediment analysis showed that the dioxin contamination extended many miles beyond the Doe Lea's confluence with the Rother downstream of the Coalite discharge. Coalite is legally allowed to discharge 208 million gallons of toxic effluent containing cyanide and chloroform every year into the Doe Lea. But the firm does not have consent to discharge dioxins or trichlorophenol. 7.4 The NRA says that as a result of Coalite's discharge, dioxins are likely to be deposited on farm land down river as both the Rother and the Don, which meets the Rother at Rotherham, are prone to flooding. 7.5 None of the areas affected by flooding, many of which support dairy farming, have been tested for dioxin contamination. 8. Symptoms but not the cause 8.1 In December 1992, MAFF brought out its third report on studies of dioxins in Derbyshire. The results showed that dioxin levels in the soil remained high. However, there was a decline in dioxin concentrations in the milk from all three farms since the autumn of 1991, though the milk on the beef farm was still above the Maximum Tolerable Concentration (MTC) for human consumption. Dioxin levels in beef and offal from the farm nearest the Coalite plant had also dropped. However, in a further report of studies on dioxins in Derbyshire published by MAFF in 1992, they indicated this was solely because the animals had been kept on a dioxin free diet. Undoubtedly if they had been allowed to graze in the contaminated fields, the contamination would not have dropped so dramatically. 8.2 On 16 December 1992, MAFF announced that the order banning the movement of animals and produce from Woodside Farm was being lifted, while the other two farms were able to resume selling milk. 8.3 The lifting of the ban on sale of milk and animal produce was welcome news for the farmers but it again highlighted the Government's concern only to address the symptoms rather than the cause of the dioxin contamination. The milk may have been cleaned up sufficiently to suit the milk marketing board, but the land is still contaminated and the source of the contamination remains undetected by HMIP. 9. The danger - organochlorines 9.1 Organochlorines are compounds created by reacting chlorine with organic (carbon-containing) molecules. Eleven thousand of these chemicals are now in use, and virtually all of them are foreign to nature; few are produced in large quantities by natural processes, as a result there are few pathways by which they are degraded once they enter the environment. They are also resistant to chemical attack which leads to their long persistence in natural systems, and together with their often high toxicities and their tendency to accumulate in animal tissue, this has rightly earned them a reputation of being amongst the most serious environmental pollutants. Included among the organochlorines are some of the most notorious industrial poisons and pollutants ever produced, including DDT, PCB's, CFC's, dieldrin and dioxin. Deadly Dioxins 9.1 In 1990, the World Health Organisation and the UK Government relaxed their dioxin limits, but it seems that they were premature - dioxin is at least as dangerous as previously thought. Latest information on dioxins comes from the USA. Following ongoing debates over the toxicity of dioxin, Dr Kenneth Olden, director of the National Institute of Environmental Health Services in the USA, announced on June 23rd this year: "I've reviewed the data thoroughly, and I'm not aware of any new scientific studies that suggest it is not as dangerous as we thought it was." Dr George Lucier, a world-leading dioxin expert based at the institute echoed these concerns saying that: "Not only is dioxin a carcinogen, but new evidence says it also increases the risk of diabetes, reduces sperm count and can cause defects by disrupting the normal workings of human cells. I would say that concerns about environmental levels of dioxin have not been diminished by recent scientific evidence." 9.3 The term "dioxin" is commonly used to refer to a group of 210 chemicals called the polychlorinated dibenzo-p-dioxins and the polychlorinated dibenzofurans. None of these compounds are made deliberately, but arise as by-products of processes involving chlorinated chemicals. These include the manufacture of chlorine itself, paper bleaching with chlorine, the manufacture of numerous pesticides and chlorinated chemicals, and the incineration of chlorine-containing wastes. The production of chemicals such as trichlorophenol and many of the other organochlorine compounds produced by Coalite, has been highlighted as a major source. 9.4 The dioxin group includes 2,3,7,8-TCDD, which is probably the most toxic and carcinogenic synthetic chemical ever tested in the laboratory. Infinitesimal quantities of TCDD can rapidly kill some laboratory animals; for instance, one millionth of one gram is sufficient to kill a guinea-pig. Longer-term exposure to concentrations too low to be immediately fatal have been associated with a wide range of pathological effects in animals and humans. Elevated levels of a number of cancers, and neurological, immunological and reproductive problems have been reported in groups of people occupationally and accidentally exposed to TCDD contaminated chemicals. 9.5 In animal tests, tiny amounts of dioxin have been shown to disrupt the immune and reproductive systems. It has been found to permanently affect the sexual development in male mice exposed before birth. It has recently been suggested that environmental exposure to dioxins and similar chemicals could be causing, or contributing to, the declining sperm counts and rising incidence of reproductive abnormalities found in the human male populations in industrialised countries. A leading dioxin specialist in the US has recently commented that levels of dioxin of 50 parts per trillion found in humans are a cause for concern. This is equivalent to 1 breath in the lives of over 100,000 people. Chlorophenols 9.6 Chlorophenols are used directly as biocides or as intermediates in the generation of pesticides and dyes. Much of the concern over their use and production has been concentrated on the possibility of contamination with highly poisonous dioxins. However, even if they could be produced with no by- products, there would still be cause for concern, since chlorophenols themselves display a wide range of toxic effects, and may be persistent, bioaccumulating pollutants, which under certain conditions can remain undegraded in the environment for decades. 9.7 Reproductive malfunctions and cancer are among the effects recorded from rodents experimentally exposed to chlorophenols. A range of cancers in humans, including non-Hodgkin's lymphoma, soft-tissue sarcomas and skin cancer have been associated with occupational exposure, and also with drinking water polluted with chlorophenols. The most toxic chlorophenol which was found in the Coalite feed stock is pentachlorophenol (PCP). Even the minute background levels of this chemical, to which we are all exposed, may pose a serious risk to health. The evidence for the detrimental health and environmental effects has led to a complete ban of PCP in Switzerland, Denmark, Germany and Sweden, and to calls for its removal worldwide. 9.8 Many of the other products and wastes from Coalite Chemicals must also be expected to be toxic and long lasting in the environment. Yet, the company and the Government have not investigated their concentrations or effects. This is a serious oversight and means that workers and local people may be being exposed to many more toxic chemicals than they know. 10. A history of pollution: explosion at Coalite 1968 10.1 In the late 1960s, Coalite operated a process for the manufacture of 2,4,5-T, one of the active ingredients in Agent Orange, used as a defoliant in the Vietnam war. Production of 2,4,5-T began at Coalite in 1965. The process used was similar to one operated by the Icmesa chemical plant at Seveso, Italy. 10.2 In 1968, an explosion at Coalite's 2,4,5-T plant killed one worker and exposed many more to high concentrations of dioxin. According to a report by Derbyshire County Council, at least 39 grams of 2,3,7,8-TCDD, the most toxic form of dioxin, was released. This is equivalent to over 108 billion times the US Environmental Protection Agency's tolerable daily intake for 2,3,7,8-TCDD, for an average adult human. 10.3 Within a few months 79 workers had developed chloracne, a skin disease and the classic symptom of dioxin poisoning. The dioxin-contaminated debris from the plant was buried under a local open cast mine. Coalite's management refused to tell local councillors or local people the exact location of the contaminated wastes saying that the wastes posed no danger to anyone. It was not until twelve years later that a local tribunal revealed the location: Morton, a small town between Matlock and Mansfield, some 10 miles south of Coalite. After a clean up at the plant, production was resumed in 1969. Coalite admitted in 1971 that the trichlorophenol being produced then contained approaching 1 ppm of dioxin - a huge concentration. 1.4 In July 1976, the Icmesa chemical plant at Seveso in Italy exploded, spilling a cloud of toxic chemicals over the residential area nearby. 70,000 animals died or were slaughtered. The health of 30,000 people was put at risk and over 700 citizens were permanently evacuated. The Icmesa plant, like Coalite, produced trichlorophenol (TCP) and 2,4,5-T. 10.5 Local concern about the impact of the Coalite explosion, in the wake of the Seveso disaster in 1976, led to requests for a public inquiry. These requests for more information on Coalite's operations have been constantly thwarted. 10.6 However, Coalite was finally forced to cease 2,4,5-T production in 1976 after the Seveso incident, when the company's employees refused to resume work at the plant. Nevertheless, the company continues to manufacture other trichlorophenols (TCP) on site. 11. Request for a public enquiry 11.1 In 1982, the then Environment Minister, Michael Heseltine, rejected calls for a public inquiry in favour of continued monitoring of the plant. This is what HMIP have supposedly been doing for the past 8 years. If the aim was to protect the local people and the environment it must be obvious even from their own results that they have failed in their task. The dioxin contamination of the local milk was discovered only when MAFF analysed milk samples. In 1991 the contamination of the river and local land also went unnoticed. 12. Chemical fire at Coalite 12.1 A major fire at the plant in 1986 destroyed an on-site chemical warehouse. The company claimed there were no dangerous chemicals in the warehouse. However, it was revealed after several weeks that a third of a ton of 2,4,5-T had been destroyed in the fire. Not only would the 2,4,5-T have been in all likelihood contaminated with dioxin, but the uncontrolled combustion of 2,4,5-T would have generated the conditions for the creation of high levels of dioxin. The blaze at Coalite would have distributed these high levels of dioxins and other toxic pollutants around the local area. Local people would have been exposed to these high levels during and after the fire. Neither local people nor fireman were informed about the dangers. 12.2 A report by the Derbyshire Fire Brigades Union makes clear Coalite's irresponsibility: The report states that the information supplied to the fire crew by the company "did not indicate any substance that was particularly hazardous and the crews fought the fire believing that the chemist from the firm had given them all the information they needed for their safety..it was only later the next month that evidence was obtained that 2,4,5-T was present." 12.3 All fire fighters inhaled fumes during the fire. They also had to cope with large quantities of contaminated, slurry-like water, three to four inches deep. One fire fighter felt it necessary to fetch a pallet to stand on as his feet were becoming hot. "At no time were personnel instructed to wear rubber boots as opposed to leathers, nor were instructions given to ensure that equipment and appliances were decontaminated safely." Several fire fighters had to undergo hospital treatment as a consequence of their exposure to fumes from the fire. Others complained of headaches, tight chest, nausea, coughing, breathlessness, and irritations to eyes and skin. 12.4 Coalite has stated that it believes the dioxin contamination in the area to be a result of the fire at the plant in 1986. However, it is clear from the fact that high levels of dioxin have been found on the grass, (which takes up virtually no dioxin from the soil) and in the top 5 centimetres of soil, that the deposition must be of recent origin and cannot be explained by past incidents alone. 13. Effects on health Throughout Coalite's history, the regulatory authorities and the company itself have failed to take action to prevent or adequately assess damage to the health of workers and local residents. 13.1 Despite the severity of the 1968 explosion in the 2,4,5-T plant on 23 April 1968, the subsequent health effects on the workers involved have never been properly followed up. Coalite's failure to investigate the effect of the explosion on the workers or on local people was highly irresponsible. The toxicity of dioxin was well-established by 1961 and before the Coalite explosion there had been other "incidents" at similar plants. 13.2 Following the explosion, 79 employees were shown to have symptoms of chloracne. At the time of the explosion, Coalite treated the affected men for the chloracne and carried out some tests on the workers. These tests have since been criticised by outside doctors who have become involved as "crude, insensitive and outmoded". In addition, the tests were not described in sufficient detail to backup Coalite's claim that liver function in the workers had returned to "practically normal" two weeks after the explosion. Coalite refused to release the results of its own tests. 13.3 It was not until TEN YEARS AFTER THE 1968 EXPLOSION that any attempt was made to conduct a detailed clinical study of exposed workers' health. This was a study commissioned by Coalite following pressure from the Health and Safety Executive. Dr Martin, then Consultant Clinical Pathologist at Chesterfield Hospital organised the 1978 study. From the original group of 79 workers who developed chloracne only 41 were still working at Coalite at the time of the 1978 study. No attempt was made to trace the 38 who had left or to assess the exposed group as a whole. 13.4 When Dr Martin's study was complete, Coalite chose only to release an abbreviated summary of the study, dated November 1978. This report was made available to the trade unions in February 1979. This abridged report was totally different in its findings to the original study: it said that there were no statistically significant differences between the dioxin-exposed group and the non-exposed group. This was not the case. 13.5 In fact, Dr Martin's report suggested that Coalite may have been falsely reassuring about the health of its workers involved in the 1968 explosion. She had found that workers exposed to dioxin following the explosion in 1968 could face an increased risk of developing cardiovascular complaints and she detected a greater incidence of impaired liver function in the exposed workers. Dr Martin also noted metabolic differences between the groups, with the "most abnormal" being the dioxin-exposed group. 13.6 The Health and Safety Executive (HSE) said at the time of the explosion, that they were satisfied the Coalite workers had not been unduly affected by their exposure to dioxin. However, as HSE never saw the full results of the clinical investigations and have admitted that they were bound to rely on the good faith of the company, their judgement does not inspire confidence. The HSE failed to check the whole range of test results - despite the fact that Dr Martin says they were informed of the discrepancies between the company's summary and her original report. 13.7 Dr Martin later discovered that there were serious flaws in the way that control groups had been set up by Coalite for use in her original study. So she arranged to re-examine eight of the Coalite workers suffering from chloracne and to compare their blood chemistry with a properly matched control group. The results of this study were published in a letter to the Lancet. They show the abnormalities noticed in her original study to a more pronounced degree. 13.8 Shortly after Dr Martin's letter was published in the Lancet, her house was broken into. Detailed medical records of eight Coalite workers used in her study were removed. Martin had no duplicate copies of the records so the work and the medical records of the exposed men were lost forever. 13.9 No further follow up studies have yet been carried out to examine the true impact of exposure to dioxin in the workers at Coalite. This failure is even more serious in the light of the studies on 1,583 workers at the Boehringer plant in Germany, published in The Lancet in 1991. 13.10 The Boehringer plant, like Coalite, also used to manufacture 2,4,5-T as well as trichlorophenol (TCP). Cancer mortality increased among men who had worked at the plant for 20 years or more and there was increased risk of breast cancer mortality among women. The plant has now been closed down. 13.11 Contaminated blood: In July 1992, members of the Gillies family, owners of Woodhouse farm, the farm nearest to the Coalite plant, were found to have dioxins in their blood at up to seven times the normal levels. The family have consumed milk from their own cows over several years. Five members of the family had blood tests organised by the North Derbyshire Health Authority in May 1992, ten months after they stopped drinking the milk from their farm. 13.12 Nothing to worry about: The Department of Health has failed to respond to questions about what it regards as an acceptable blood dioxin level. Furthermore, no tests have been done on the local population. 14. Dioxin Diet 14.1 The village of Shuttlewood is about 1.5 km from the Coalite plant. Woodside Farm and Larch Farm, the two farms which have been found to have high levels of dioxin in cows' milk, are within 1 kilometre of the Coalite plant. Woodhouse Farm, where meat had to be withdrawn from sale, is closer to the works than the other farms. All the farms lie in directions and at a distance where maximum deposition would be expected according to HMIP's modelling of the incinerator stack gas. The village of Shuttlewood lies between the farms. 14.2 Many local people get a large part of their food intake from allotments which are nearly as close to the plant as the farms. Food such as lettuces, spinach, potatoes and fruit from these allotments have never been tested for dioxins. However, they are at least as likely to be as contaminated as plants from local farms or as contaminated as the grass the cows are eating. 14.3 Again the regulatory authorities have failed to act: ù Neither MAFF nor the Department of the Environment have taken any samples of vegetables from the allotments. ù MAFF has stated "it is unlikely that vegetables would pose any hazard to consumers provided that they are washed or peeled as appropriate in the normal manner." However since they have taken no samples from these allotments to test the truth of this assertion, their official reassurance should be treated with caution. ù Although HMIP have taken soil and dust samples from in and around the village, the results have not been published. The results were due for publication in the Autumn of 1992. 14.4 If local fruit and vegetables are contaminated to anything like the same extent as the samples of herbage from the contaminated farms, a Shuttlewood resident eating local fruit and vegetables, but with an average intake of other foods, could easily be consuming levels of dioxin well above the UK Tolerable Daily Intake recommended for dioxins. 14.5 MAFF are also ignoring the fact that dioxins can be absorbed through the skin, so if the soil is contaminated there is also a risk of exposure from simply working on the allotments. 15. Cancer clusters 15.1 There is evidence of elevated levels of some types of cancer in the local area. In particular, excess cases of breast and lymphoid cancers have been reported. 15.2 No work has been done by the local health authority or the Department of Health to examine the underlying causes of these patterns. Given the increased cancer risks that exposure to dioxins and other organochlorines is known to entail, reports of higher rates in the area are cause for concern. No work has been done to investigate any other health effects which could be a result of exposure to dioxins and other chemicals, for example, reproductive effects. 16. Permit to pollute 16.1 Following changes brought about by the 1990 Environmental Protection Act and the adoption of Integrated Pollution Control (IPC), Coalite has had to apply to HMIP this year for authorisation to continue to operate its processes. 16.2 All the authorisations which the company has sought have been granted, despite protest. Coalite's incinerator application generated considerable local opposition. Over 2,000 people signed a petition against the re-opening of the incinerator. The evidence submitted by Coalite in their application for authorisation of the redesigned incineration plant would have been wholly inadequate for a new incinerator going through the normal planning process. Nevertheless, on 30th April 1993, HMIP authorised Coalite's incinerator without announcing this to local people or their parliamentary representatives. Additional authorisations have followed - for a distillation process and for a carbonisation process. Because the key problem of the dioxin contamination in the process has not been dealt with, this will mean that the cycle of pollution will begin all over again. 16.3 Before the end of 1993, Coalite will also have to apply to continue operation of its chlorophenol process - one of the main sources of dioxin contamination. HMIP must now take action to protect the environment and refuse the company permission to operate the chlorophenols process, the cause of the contamination. 16.4 HMIP authorised the incinerator despite having failed to identify the ultimate source of the dioxin contamination. The Inspectorate also failed to take into account the impact of more dioxin emissions on a human and animal population which has already been exposed to high levels of contamination for many years. It makes no sense to consider the means of disposal of highly toxic wastes before considering whether it is necessary to produce these wastes in the first place. This is one of the intrinsic flaws of the IPC system. Under the current timetable for the introduction of IPC, in-house incinerators are being licensed in isolation from the processes which generate the wastes they are licensed to burn. 16.5 Bearing in mind the nature of the wastes produced during the production process, the application for Coalite's on-site incinerator should have been postponed so as to be considered alongside its authorisation for the manufacture and use of organic chemicals which create the wastes. 16.6 Coalite's application for the incinerator included details which showed that chlorophenols alone make up as much as 83% by weight of the chlorinated feed stock residues. As we have seen, all samples taken have shown a high degree of dioxin contamination. Coalite was unable to explain to the satisfaction of those who were opposed to its application how, given such contaminated feed stock, it was going to prevent dioxin emissions from the incinerator operation. 16.7 Coalite also stated in their application: "The impact on the environment of dioxins and furans is considered the only cause for concern and no plans are currently contemplated for monitoring other components of the aerial emissions in the local environment". Considering the toxicity of some of the components of the waste stream, this is an incredible statement; equally unbelievable is the fact that HMIP, in granting the application, appear to be endorsing the operation with no requirement for it to meet particular standards. 16.8 Since no incinerator totally destroys the waste fed to it, some of the dioxins will pass through the combustion chambers unchanged. Also, the highly chlorinated nature of the waste provides ideal conditions for the formation of more dioxin, through reactions taking place after the gases have left the combustion chambers. Even if some of these dioxins can be collected by the pollution control devices, they will be emitted in the scrubber effluent water which is discharged via the biological treatment plant to the already contaminated River Doe Lea. Other filters, which will again be highly contaminated, could end up in landfill sites, posing a threat even further afield. 16.9 At no point is Coalite required to undertake a detailed waste audit of its plants. By comparison, companies in the U.S. are required by law to undertake a complete toxic release inventory which is available to the public in an easily accessible form. All emissions from plants in the US of 313 listed dangerous chemicals, whether they are intentional or fugitive, must be accounted for. It is only with the introduction of similar legislation in the UK that companies and regulators, as well as the public, will begin to have an idea of the types and quantities of chemicals currently being discharged into the environment. At present Coalite, in common with other UK companies, do not know exactly what they are discharging into the environment or in what quantities. How can the Government expect to protect the UK people and the environment, let alone meet international agreements, when this type of information is not available and no one has any idea of what the figures may be. 17. Not in breach of law Government Legislation, International Commitments and Broken Promises 17.1 The Government's failure to protect the environment and local population from pollution is revealed by the scandal of Coalite's dioxin production. The law is ambiguous with regard to discharging chemicals which aren't specified on a company's permit to discharge. The government has said Coalite is responsible for dioxin pollution but "is not in breach of the law in the manner in which it has operated the incinerator". If this is the case then the government is failing in its duty to protect the environment and Coalite appear to be taking advantage of a loophole in the law. Coalite holds no permit to allow it to discharge dioxins into the environment. 17.2 By allowing Coalite Chemicals to continue its polluting processes, HMIP has given the all-clear to the continuation of a large UK source of dioxins and other organochlorines. This compromises the Government's ability to fulfil its commitment, under international agreements, to eliminate organochlorines. Under these agreements the Government is contracted to eliminate organochlorines, including dioxins and other toxic persistent chemicals such as chlorophenol. 17.3 The UK Government is a signatory to the Paris Commission (PARCOM). The Paris Commission is the Convention for the Prevention of Marine Pollution from Land Based Sources. In September last year, UK Environment Ministers, along with ministers from 14 other countries around the North East Atlantic, agreed to reduce, with the aim of elimination, the discharge of organochlorines, (including dioxins), and other toxic and bio-accumulative chemicals, into the marine environment by the year 2000. This convention covers pollution from land, and includes atmospheric and river pollution. 17.4 In addition, the 1990 Ministerial Conference on the North Sea set a target of at least 70% reduction by 1995 for dioxin, mercury, lead and cadmium entering the North Sea. 17.5 By allowing the Coalite incineration plant to continue to burn the wastes from the organochlorine production process, and by allowing the continuation of the organochlorine production itself, the Government is reneging on its own international agreements. 17.6 Greenpeace is calling on the UK Government not only to shut down the chlorophenols process at Coalite and to hold a full public inquiry into the contamination of the area with dioxins and other organochlorines, but to initiate a timetable to phase out organochlorines from the UK environment. 18. Failure of the Authorities 18.1 The statutory authorities have failed in their obligations to protect the local environment, workers, farmers and residents. ù The Health and Safety Executive (HSE) waited 10 years before it suggested to Coalite that it should investigate the health consequences of the 1968 explosion. Despite the unsatisfactory nature of the study, HSE said they were satisfied the workers had not been unduly affected, even though they hadn't seen the full results of the investigation. ù The local health authority, North Derbyshire County Council has never carried out a health survey of the local people living just 1.5 kilo metres from the plant, despite the evidence of the dioxin contamination. Nor has the Department of Health taken the lead in investigating the health of local people. ù Severn Trent Water Authority and Derbyshire County Council refused to reveal the whereabouts of the toxic waste buried by Coalite after the 1968 explosion. ù The old Industrial Air Pollution Inspectorate (IAPI), predecessors of HMIP, stated each year in their district annual reports that the Coalite incinerator "continues to work well" and that the chlorinated hydrocarbon wastes were "destroyed and unable to contaminate the environment". This was obviously not the case. More recently, other Government bodies have been "economical with the truth". 19. MAFF's failure: 19.1 In 1989, the Government set a guideline level for human exposure to dioxin. It was the most stringent guideline set by the UK for any substance, though still one of the less stringent of guideline levels in force internationally. It was expressed in terms of a Tolerable Daily Intake (TDI) which is an estimate of the amount of a contaminant which a person can ingest daily over a lifetime without appreciable health risk. 19.2 However, following MAFF's discovery in June 1991, of highly elevated levels of dioxin in milk in Derbyshire, the Ministry raised the guideline level for dioxin by a factor of ten. This meant that only 2 of the 27 milk samples taken from all over Derbyshire were over the new recommended daily limit - both these farms were close to the Coalite plant. 19.3 Had the earlier trigger value been used, most of the Derbyshire dairy and retail samples, and all of the Bolsover farm samples, would have been above the limit. MAFF argued that the relaxation in the TDI merely reflected a new World Health Organisation (WHO) recommendation the previous year. Strange then, that they had made no previous announcement of their change of policy. The revised level had not been ratified and had no regulatory status. 19.4 It seems clear that by adopting a less stringent policy on "tolerable" levels of dioxins in food, MAFF were able to defuse a potentially explosive situation. The TDI was also based on the assumption that dioxin does not cause cancer in humans - now a rather outdated idea. 19.5 Following the discovery of the dioxin contaminated milk in the spring of 1991, MAFF undertook sampling of animal tissue, (fat and liver), soil and herbage in the area of the Coalite plant. MAFF was "economical with the truth" in the way in which it released the results of those tests to the media and to the scientific community. 19.6 MAFF presented the results of its tests on animal tissue, soil etc in such a way as to prevent the various types of sample being compared directly by calculating the results in a variety of ways but not releasing the congener specific analysis which is needed to convert results from one form to another. MAFF was asked why only selected figures from the MAFF reports had been released. Their reply was evasive: "A sufficient number of samples has been analysed to enable MAFF to establish the level of contamination in food products from the affected farms and to take the action necessary to safeguard the public food supply." 20. HMIP's failure 20.1 HMIP have been responsible for monitoring air pollution from the Coalite site since the demise of the old Industrial Air Pollution Inspectorate. HMIP inspectors must have visited the site on a routine basis. But no concerns about the plant, its production processes or its wastes were made public. 20.2 HMIP must have known of the dioxin contamination, at the same time as MAFF in March 1991. Yet it was another 8 months before HMIP got Coalite to close down the incinerator. HMIP should have closed down the incinerator as a precaution until the ultimate source of contamination was discovered in order to protect local people, the environment and the food chain. 20.3 HMIP had identified extremely high levels of dioxins in the feed stock for the incinerator. These results would have strongly suggested that the incinerator was not the primary source of dioxin emissions from the factory, yet no action has been taken to close down those parts of the operation where the dioxins were being manufactured. No further analysis of the feed stock, nor any from the other possible contamination sources within the plant have been published. 20.4 HMIP later carried out soil sampling around the plant after their first investigations into the emissions of dioxins and furans from the incinerator found high level emissions. The tests were carried out in early 1992 and were supposed to be published in the Autumn. 20.5 HMIPs soil samples, if they prove Coalite is the source, could undoubtedly provide good evidence for many of the current compensation cases and should be a matter of public concern. However at the time this report was written these results had still not been published. 21.National Rivers Authority: Too little too late 21.1 Sixteen months after the MAFF banned sales of milk from farms near Bolsover, the National Rivers Authority (NRA) announced that it was taking civil action in the courts against Coalite Chemicals for the dioxin contamination of the River Doe Lea. 21.2 The NRA, who are responsible for maintaining the water quality of the Doe Lea and the Rother, are taking civil action against Coalite Chemicals in order to force the company to pay for the removal and disposal of the dioxin contaminated sediments of the River Doe Lea. The cost of this operation in the Doe Lea alone has been provisionally estimated by the NRA at about œ1 million, although this is inevitably a gross underestimate of the true cost of such a clean up. The NRA's analyses have shown virtually no dioxin contamination upstream of Coalite Chemicals' outfall to the Doe Lea, but substantial contamination downstream, implicating Coalite as the responsible party for this contamination. 21.3 This final move by the NRA to initiate court action, although welcome, comes too late. Coalite have been breaking the law by failing their consent regularly over the past few years. Since 1991 the NRA public register data shows that Coalite have broken the law on the amounts of chemicals they are legally allowed to discharge at least 7 times, yet the NRA failed to prosecute the company on any of these occasions. The NRA's own monitoring data shows that Coalite discharged chlorophenols without a consent, yet they still took no action, ignoring the danger signs indicating that dioxins may have been present. 21.4 The discharge from Coalite Chemicals has downgraded the Doe Lea from a class 3 river to class 4 river. This means that the river has deteriorated from one which is of "poor quality", which is polluted to the extent that fish are absent or present sporadically, to a class 4 river, one of "bad quality". Yet, the NRA took no action to rectify this situation or to alter Coalite's consent to discharge. Coalite's consent covers only the effluent from coke and chemical production and does not explicitly sanction the discharge of incinerator scrubber liquor, which is the effluent which contains the high concentrations of dioxins, or control the discharge of dioxins. 22.Toxic legacy 22.1 Despite reduced levels of dioxin contamination in herbage and milk since the closure of the incinerator, there is still highly elevated contamination in the soil surrounding the plant. 22.2 The River Doe Lea also remains contaminated both at the site's discharge and for many miles beyond the Doe Lea's confluence with the Rother. 22.3 Because dioxin is passed from mother to child both before birth and during breast feeding, this contamination in and around Coalite may be passed on to future generations. The continued operation of the organochlorine and chlorophenols processes and the incinerator suggest that the future may be as bleak as the past. 23. Who is to blame? 23.1 During a parliamentary debate, Dennis Skinner, MP for Bolsover, claimed that, at a meeting between MAFF and a delegation from Bolsover, "one of the Ministry's officials told the 20 people who were around the table that he believed Coalite was to blame for the dioxin contamination. The next hour of the meeting was spent trying to cover up for that statement." 23.2 The issue of blame is extremely important because the Government says that it is the polluter who must pay for the consequences of its pollution and any ensuing clean-up. However until Government agencies identify the source of the contamination, the problem of who will pay for the past, present and future legacies of this pollution cannot be resolved. 24. Who will pay for the pollution? 24.1 The three farmers affected in the Bolsover district are seeking compensation from Coalite for the loss of their livelihoods, acting through the National Farmers Union. 24.2 Although the government claims to have adopted a polluter- pays policy, it is left to the aggrieved party to take action. This system does not work in practise since individuals rarely have the resources to take on multi-million pound chemical companies in court battles which last for months or years. 24.3 In this instance, it is particularly difficult for the farmers to prove their case because the Government has not pointed to any single source of the dioxin pollution, even though they have admitted that Coalite is at least partly responsible. HMIP have calculated that, based on their results and unpublished research by MAFF, emissions from the incinerator probably account for only "a part" of the dioxins in milk. However, the Inspectorate has not studied the potential for contamination from the chlorination and distillation processes. 25. Company news - Coalite's parent 25.1 Until the company was bought by Anglo United in 1989, the chairman was Eric Varley, now Lord Varley, an ex-Labour cabinet minister. Since this takeover, the company would seem to be in some financial trouble with large debts. James Capel & Company, city analysts, have commented: "Whilst recognising the concerns of the banks, we would however doubt whether this reconstruction will prove more than a temporary reprieve." The company, it would seem, needs cash - "an asset that the company simply doesn't have and that the banks will almost certainly remain reluctant to provide." 25.2 Pollution liabilities are usually covered by environmental liability insurance. It is not clear whether Anglo United have this insurance and to what extent. If they have no insurance or not enough, who will pay? 25.3 Polluter takes all: If Anglo United are in such dire financial state as is indicated by James Capel, who is going to be liable for compensating the farmers and cleaning up the local environment? So far, it is not the polluter who pays but those who live and work nearby who pay with their health and their livelihoods. 26. Greenpeace demands ù That the authorisation of the on-site incinerator be revoked by HMIP. ù That the manufacture of chlorophenols and related organochlorines at the Coalite plant be stopped immediately and that the whole plant be investigated to identify the primary sources of dioxins. ù That contamination of the Coalite Chemicals site, indoors and out, be investigated and all results be publicly available. ù There should be a full public inquiry into the dioxin contamination around Bolsover. ù That the Government amends its current policy of "polluter pays" and takes action to identify unequivocally the source of the pollution and ensure immediate compensation for the victims. The Government should amend its policy to allow interim support of victims of pollution through Government funds, which can then be recovered from the responsible party once identified. ù The UK Government implements legislation to prioritise elimination programmes for organochlorine discharges and emissions into the environment in line with the 1992 Paris Convention. ù Full investigation of the identity, concentration and toxicity of other pollutants being emitted from Coalites premises. ù Full clean-up of the Coalite site and the surrounding area. ù Coalite and the regulatory authorities release all analytical data currently not available to the public for whatever reason. ù A full investigation of human health and human dioxin contamination be carried out for the exposed populations. ù The site at Morton where Coalite dumped contaminated waste be cleaned up. 27. Chronology of events 1965 Coalite and Products Company starts producing trichlorophenol at the Shuttlewood plant, in Derbyshire - in order to make the herbicide 2,4,5,T 23 April 1968 Explosion at Coalite chlorophenols plant - 1 man dies, 79 workers develop chloracne Dioxin contaminated debris from site buried at undisclosed location. Feb 1971 Two pipe fitters working at the plant on a new building with new materials, well away from the site of the explosion, contract chloracne. (source: The Superpoison, 1980) June 1971 Four year old son of one of the pipe-fitters and wife of another also contracted chloracne. 1976 - July 10 Explosion at ICMESA, Seveso in Italy. Evacuation of local population. Derbyshire County Council asks for whereabouts of buried debris from 1968 fire to be disclosed. Permission effectively refused with the assurance that the waste was safe if it remained undisturbed. Coalite's on-site incinerator comes on stream. 2,4,5-T plant closes down. 1980 Information on location of buried debris refused again. 1981 Derbyshire CC Tribunal pinpoints location of explosion debris as open cast mine workings in Morton, Derbyshire. 1 April 1982 Environment Secretary Michael Heseltine rejects recommendations from an independent tribunal for a public inquiry into potential dioxin pollution from waste produced at Coalite. 24 July 1986 Fire in chemical warehouse containing 7 cwts (1/3 ton) of 2,4,5,T; firemen only informed one month after fighting blaze of presence of this chemical. 1989 Coalite PLC bought out by Anglo United PLC after a well-publicised struggle. Dennis Skinner raises question of breast cancer cluster in Bolsover area - confirmed by North Derbyshire Health Authority. 1990 Breast cancer cluster in Bolsover area confirmed again - and promises of investigation by North Derbyshire Health Authority April 1991 MAFF finds high levels of dioxin in milk from Derbyshire farms 26 June 1991 MAFF publicly releases information on high levels of dioxin found in milk from two farms near the Coalite plant. The sale of the milk is stopped. August 1991 HMIP carries out sampling for dioxin from Coalite's incinerator stack. Work carried out by Harwell Laboratory; published Dec 1991. 2 Oct 1991 MAFF finds highest levels of dioxin so far in milk from third farm, near to the Coalite plant. Oct 1991 NRA sediment samples from River Doe Lea, below Coalite site show dioxin levels more than 1000 times background levels. Nov 1991 Publication of HMlPs report which confirms that Coalite incinerator is at least "partly responsible for dioxin contamination in milk " HMIP closes down Coalite's hazardous waste incinerator for upgrading. Nov 1991 Tony Baldry confirms that Dept of Health will study claims that there is a high level of breast cancer in the Bolsover area. Feb 1992 Harwell laboratories take soil samples for analysis. Results due summer 1992. 20 March 1992 MAFF releases results of further testing of dioxins in soil samples and meat 28 May 1992 MAFF release additional sample results of dioxins in herbage, showing levels 1,000 times higher than UK background levels. June 1992 Seven times the normal level of dioxins found in blood of farmers's family (whose milk had been withdrawn from sale.) NRA announce a prosecution of Coalite for pollution of River Doe Lea. July 1992 40 herbage samples went missing from MAFF. When these sample were found they had deteriorated so much that it was decided not to analyse them. MAFF say they have collected more samples from all farms, and that the results will be published in due course. December 1992 Third Report of Studies on Dioxins in Derbyshire, carried out by MAFF is published. Report shows decline in dioxin concentrations in milk on all 3 farms. Dioxin levels in beef and offal had also declined. Concentrations in soil little changed, however The Government lifts restrictions imposed on one of the Bolsover farms. 31 March 1993 DOE releases results of further investigations into dioxin contamination in the Staveley area. Elevated levels identified. 30 April 1993 HMIP gives Coalite IPC authorisation for its updated incinerator. Appendix 1 Coalite and Anglo United - Financial and Company Information (Based on the latest information at companies house as of 8/6/93) Environmental Performance The company claim to have spent more than œ2 million on environmental protection measures since the takeover of the company by Anglo United in 1989. The company spent œ700,000 on effluent control and site improvement during 1990-91 and a further œ1.6m was spent on site clean-up, including the removal of waste built up over many years. River Permit The company's site in Derbyshire has an effluent volume of about 110,000 litres per hour from carbonisation liquor and effluent from the chemical works, which flows into the Doe Lea, a tributary of the Rother. Company Information Coalite is a wholly owned subsidiary of the coal distributor Anglo United PLC. As such most of the directors of Coalite are also directors of the parent company. Their positions are listed below. Directors of Anglo United are: Harold Cottam (Chairman) John Henry Gainham (Group Managing Director), (Director of Coalite Group Ltd & Coalite Products Ltd) George Wallace* (Group Finance Director), (Finance Director of Coalite Group Ltd & Coalite Products Ltd.) Alan Brooks (Non-Executive Director) John Alfred Stoddart Nash (Non-Executive Director) Mr John Veasey (Company Secretary) * George Wallace (Group Finance Director of Anglo United and Coalite's Financial Director) was a director of Coalite pre- takeover by Anglo United in 1989. The following is a list of major institutional shareholders in Anglo United. Major Shareholders in Anglo United HSBC Holdings pic including the separate notification of: 40.22% Samuel Montagu & Co Ltd 31.79 The Hongkong and Shanghai Banking Corporation Ltd 8.43 Barclays Bank PLC 7.98 Scottish Amicable Investment Managers Limited 7.16 ARP(American Real Property)NV 4.63 Guinness Mahon Holdings PLC 3.36 Westpac Banking Corporation 1.41 Hill Samuel Bank Ltd 1.18 Credit Suisse 1.02 National Westminster Bank PLC 0.52 Banque Internationale a Luxembourg S.A. 0.38 The parent company, Anglo United, is currently trying to sell the Coalite chemicals section (as part of its strategy to sell off non-core businesses). No buyer has yet appeared. Appendix 2 Coalite's products are sold under the brand names: "Cotane" (O.P.P., Ortho Phenyl Phenol) "Coaltec" Wood Preservative "Panacide" (dichlorphen) (Source: Kompass Directory 1992) Other chemicals: Benzole: Coal Tar Cresote, Coal Tar Pitch, Coal Tar Road Tar Acid Tar and Cresylic Xylenols Catehol Phenolic ethers Butyl phenols Hydroxy diphenyl Tritolyl phosphate Chlorocresols Chloroxylenols Cresols Chlorocresol: Chloroxylenol Chlorothymol Chlorophenylphenol Chlorophenols Trichlorophenol Tetrachlorophenol Biocides Perfumery & fixatives Appendix 3. A Comparison of the dioxins found by HMIP and Greenpeace in Coalite waste. (omitted here; unscannable) Appendix 4. COMPOUNDS OTHER THAN DIOXINS IDENTIFIED BY GREENPEACE IN THE COALITE WASTE SAMPLES Compounds identified to better than 90% Phenol phenol,2-chloro- phenol,2-methyl- phenol,2-chloro-6-methyl- phenol,2-chloro-5-methyl- phenol,2,4-dichloro- phenol,4-chloro- phenol,2-bromo-4-chloro- phenol,2,4-dichloro-6-methyl- phenol,4-chloro-3-methyl- phenol,2,4,6-trichloro- [1,1'-biphenyl]-2-ol, tetrachlorophenol [1,1'-biphenyl]-2-ol, 3-chloro-2-hydroxy-5-chlorobiphenyl benzene,1,1' thiobis- triclosan animert Compounds tentatively identified benzene,1,1'-thiobis- ferrocene,1,2-dichloro- benzene,1,1'thiobis[4-chloro-] 2,3-dimethoxyphenylmethyl 4-chlorophenyl keton benzene,1,2,4-trichloro-5-[4- chloroplhenyl)thio]- phenol, dim ethyl-, phosphate 3-acetyl- 1 -(3,4-dimethoxyphenyl)5-ethyl- 4,5-dihydro- References: (102 references omitted here; unscannable)