Incompleto il disegno di legge Pacher-Kessler in materia ambientale
A titolo di trasparenza e correttezza, we want to urgently move away from what appeared on the bodies of the local press in recent days regarding our position on the alleged contents of the text unified Pacher-Kessler bill environment. On this occasion, attempted to clarify in order to avoid misunderstandings or more or less unwanted distortion.
- is absurd to extend the limit of PCDD / PCDF in 0.2ngTEQ/Nm3 for the first two years and then setting it to 0.1 ngTEQ/Nm3. For three reasons: first because there is a clear EU regulation (Reg.CE 304/2009 of 14 April 2009) determining the value of 0.1 ngTEQ/Nm3 even now in all member countries of the European Community, and second because the values \u200b\u200bmeasured in self-monitoring and declared by the company and the PAT would seem even to far below the 0.1 ngTEQ/Nm3 and therefore should not even be a problem, and thirdly because it does not appear to have further improvements in the installation of gas collection / filtering of the foundry.
- PCBs and their toxic effects have been known for at least 30 years! Not only that. Among them were identified at least 12 congeners, the so-called dioxin-like PCBs, dioxins are on a par with the classic as a risk. So it goes without saying that we do not share the decision to exclude them, for whatever reason from the tables of the bill by Pacher and Kessler. Besides the fact that we found mostly in their own organic matrices that we tested (grass, trout and milk) and that you are working at European level to limit not only the 12 but all the PCB congeners.
- The extent and the mass flow. Putting a limit on the mass flow in the form that appears in the text Pacher-Kessler, leaving the authorization or any other Integrated Environmental regulation limits the volume flow essentially does not put a limit to the source of pollution in the area. That is, the limit for concentration may well be met by increasing the volumetric flow rate but in essence it would allow air to enter the same volume as the absolute mass of pollutant. We therefore believe it essential to introduce a limit explicit and direct mass flow of pollutants in order to prevent a future expansion of the steel complex in an area as unsuitable Trentino and around itself. It also takes as a reference volume flow current (real, not the one allowed by the AIA) of steel mill village (1 million Nm3/ora). Multiply it by the concentration of 0.1ngTEQ/Nm3. It follows that the limit of mass flow to be requested in the table of the law is precautionary 100microgrammi/ora. It should also prevent being "bypassed" the legislative obstacle by creating 2-3 or more companies than simply prohibiting these are attributable to the owner himself or by some other device legislative purpose.
- Continuous monitoring systems must also include the webcam in the visible and infrared, high-definition with a frame rate of at least one image every 1 second, direct the whole of the building and put online on the Internet available to any user. This will put a visual check frequent, consistent, free of charge, from the same city that this would also be reassured with regard to health and environmental aspects of the area where he lives. "
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