Friday, February 17, 2006

We will not speak to you, we will not answer

The Agency refuse to answer questions. No prizes for guessing why they will not answer such straight forward questions?

Sent: Wednesday, March 02, 2005 10:55 AM
Subject: Re: Cement Forum Technical questions

Dear Mrs P
I refer you to the letter sent by my Regional Director, Tony Dean on January 18th. In this he told you that in future we will not respond to any enquiries from you unless:

1. They relate to pollution incidents that you have reported to our 0800 80 70 60 hotline.

2. They are part of a public consultation process that has been opened by us.

3. They are put to us through the Rugby Cement Forum or Community Review Group and subject to approval by the chairs of those groups.

He also reminded you of our Chief Executive, Barbara Young's letter to you of 12th November 2004 where she asked you to address any further enquiries to the Area Manager at Tewkesbury.

I shall not therefore be responding to your questions and ask you to use the approved channels in future.

Yours sincerely
Environment Agency

To Rugby site inspector :

It was nice to meet you at the Forum, and renew our acquaintance with Mr Paul Quinn who we have not seen for over a year.

We note the new information, Audit of Particulate Emissions from Rugby Cement Plant, Permit Improvement Condition number 13 that was due on August 13th 2004,has finally been provided at the end of February, but is still not on the RBC Public Register. It is of great concern that you have seen fit to delay this important assessment, which has affected the air quality monitoring report, and Faber Maunsell's ability to monitor and model the particulate from the plant. Letters of concern are being sent to Defra.

Further to the Forum of 24th February, when neither you nor Mr Millard managed to answer these technical questions, please help us now to clarify these issues that arose. The Forum and the Public are anxious to understand the issues, and to move forward.

1. You said that the (massive, and often falling in chunks onto the town), plume that we can see consists "mostly" of water vapour - what, in percentage terms, is the water vapour present in the plume?

2. How many cubic metres of gas are normally emitted each second? Does this vary - and if so why, and how?

3. You do not accept - apparently - any complaints about "black smoke" from the public. You suggest we equip ourselves with Ringelmann's Charts. How much do these cost and where can the public buy them from, or will the EA/RMC provide them to us?

4. What are the Clean Air Regulations appertaining to a cement plant and black smoke (public nuisance) in a smokeless urban area?

5. Are there any exemptions to the rules, which relate the Clean air Act Regs and to the cement plant?

6. Is it the EA's or RBC's responsibility to take action against industries that put out black smoke in towns?

7. What is the total in terms of kilograms when there is an ESP trip? How is this calculated?

8. If the plant subsequently starts up, what is the combined total for the day of the trip emissions and the "normal" emissions?

8. With reference to the Technical Questions from the Forum August 16th 2004. It is noted that it took over SIX months to get the replies to what should be, for specialists, simple questions.

Page 1: there is a typo in line 3 - it should read 864 kilos a day.

The question refers to the emission rate for Particulate and relates to the release rate for July and August both of which were in excess of 50mg/M3 for particulate with 265 hours (?) Exceedence of the limits. With many hours up to (and over?) 83 mg/M3.

Taking the permit level of 55 mg/M3 how many kilos of particulate would be emitted each 24 hours at that rate? It is noted that you permit 22 hours at 55 mg/M3, and 2 hours at 83 mg/M3 each 24 hour day. Of course no limits apply at all during shutdowns and during start ups - until a feed rate of 200 tonnes an hour is reached.

Your answer has somehow got muddled up with a "mean rate". Where did this "mean rate" come from - how have you arrived at it?

The last paragraph shows your result of 596 kilos a day at 55 mg/M3. How many cubic metres each second have you used to arrive at the figure of 596 kilos each day.

9. In the Decision Document is refers to there being no increase in "trips" - there being only 3 each year. Why has the number of trips increased by so much?

10 Regarding question 10 - the dumping of CKD and bypass dust at Southam, you say that the Permit issued by the EA is a Waste Management Licence, but it my understanding that this does not cover the classification of class one hazardous waste as specified under the EU Waste Catalogue? Surely without the IPPC Permit, and without the lawful planning permission - that WCC have appeared to indicate is not valid for this useage - then this dumping is unauthorised and unlawful?

I look forward to your response, and trust it will not take SIX months this time.

Thank you.


No comments: