Wednesday, February 15, 2006

Plumeing fool?!!

"Leading Environment Agency lawyer, purporting to be an expert, and claiming tyre burning is good for Rugby residents, is befuddled about dispersion and air quality ..."

More proof has emerged that the Rugby residents are right to question every aspect of the Agency's Decision in the Rugby Cement case:
Observers of the action in the High Court this week, before the Court of Appeal, were stunned to hear the  Environment  Agency's Counsel (Mr Elvin ) in one of his many reasons why Rugby people should not succeed in their claim against the Agency, which withheld vital air quality data relating to air quality and dispersion modelling,  come out with this little gem:  
"Although it was suggested in A 's (the appellant's)   submissions that one of the areas of debate could be whether the LLPS heights (as opposed to the stack height) could have been increased/different, this is a completely new point. The suggestion that this would reduce the environmental impact of emissions from the LLPS is unsupported by any evidence - the LLPS are by definition low point sources and it is highly questionable whether the height issue would make any difference." !!!

The following comment was received from a leading air quality expert in answer to the question: "Is this unbelievable, coming from the Agency?"

 " You're right - if it hasn't been said before it's because it's bleeding obvious!!!!!!!!!!!  It is the business of the EA to make sure stacks are high enough, emissions hot enough and fast enough (they often use a minimum velocity of 15m/s), emission concentrations low enough to satisfy Air  Quality  objectives!!!!!!!!!
This would be laughed "out of court" if it were quoted at an air quality meeting. 
LLPSs are stacks too.   LLPS have their own "stack" or emission heights.   At Rugby they  are  at about  15 m high , and some more.  Even if the release is from a vent at 20m the emission height can be raised.   (It may not be simple but that's not my problem that  is  Rugby's problem). 
If the stack height is Z.  The maximum ground level concentration is roughly proportional to 1/(Z*Z) i.e. a doubling of the stack height reduces the maximum ground level concentration by a factor of 4.  The maths is the evidence.  This should not be a debating point.
What does it take???? "

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