Executive Summary of Comments on CCL’s Odour Neutralisation Plan (ONP)

1. The local community affected by the Factory’s operations opposes the granting of the application by CCL to run a trial of its ONP.
2. The ONP will not reduce the emissions profile of the Factory.
3. There are more effective ways of reducing or eliminating kiln odours, principally by burning only natural gas and not coal and by installing pollution reduction technologies.
4. If any trial is to be conducted in relation to ‘odours’ emitted by the Factory, DWER should mandate that CCL conduct a 90 day trial using only natural gas to fuel its kilns as a pre-condition to determining the conditions of CCL’s licence to operate.
5. The product to be used in the ONP (Product) is not designed for, or intended to be used for, the purpose or in the manner proposed by CCL.
6. There is no, or no satisfactory, evidence that the Product is certified or authorised for use in gaseous emission streams of cement kilns or other large production facilities.
7. The evidence submitted by CCL in support of the successful use of the Product in a cement factory is limited to one Italian based family company which has a poor record of corporate governance and pollution control.
8. There is anecdotal evidence that the US manufacturer’s products similar to the Product are ineffective even when applied in the recommended manner and for the recommended purpose, let alone for an unauthorised use and in an unauthorised manner as proposed by CCL.
9. There is no, or no satisfactory, scientific evidence and explanation as to how the Product actually works in a continuous high volume stream of a variety of noxious and odourous gases and what compounds will be emitted from the kiln stacks when the Product is used.
10. There is no, or no adequate, information provided in the application as to all the constituents of the Product so as to enable a fully informed assessment to be made as to any potential hazards it may pose.
11. There is no, or no adequate, information provided in the application as to the risk the Product may pose for human health and to the physical environment so as to enable a fully informed decision to be made as to the safety of the Product.
12. As the Product will be put to an unauthorised use in an unauthorised manner, there are potentially a range of unintended consequences which are likely to aggravate the risks posed to human health and the environment.