Sunday, February 25, 2007

HOW RUGBY CEMENT PLANT MORPHED!

..click pic to enlarge.

INTO RUGBY CO-INCINERATOR!

2.300,000 tonnes cement per annum!
According to Environment Agency Permit.
(Incredibly without "anyone" knowing !)

Rugby residents now face the unlimited use of the plant as a CO-INCINERATOR: starting with a mix of tyres and London's household and Commercial waste, while the Decision Document for the tyre trials is still incomplete, questions have never been answered, and data requested is still being concealed.

PERMIT/CONDITIONS MEAN NOTHING!
It is now admitted that the plant was running "outside of its IPPC permit" for TOC and nitrogen dioxide during 2005, including during the TYRE TRIALS. Unbeknown to the Rugby residents, and more surprisingly unbeknown to the Rugby Cement Community Forum/Tyre Burning Review Group, who met regularly with Cemex and the Agency, in a secret exchange of letters the Agency had given a discrete concealed "permission" for the permit conditions "not to be met" - although this was not FORMALLY finalised until the Variation was issued on 1st November 2005.

CONSULTATION MEANS NOTHING!
It somehow simply "slipped their minds" to notify the Community Forum, public, RBC Environmental Health Office, and Faber Maunsell Air Quality consultants, who are supposed to be consultees on all these issues. RBC even brought in another paid industrial EXPERT from Faber Maunsell and even he was "kept in the dark", although he had come to specifically examine the INCREASE in the TOC emissions that the Agency were permitting. Both Cemex and the Agency never thought to mention the changes to the Permit Conditions and the nitrogen dioxide increases, nor to Dr Mike Holland who was brought in by RBC as a Facilitator to examine the Tyre Trials data; no he was not informed either. So much for "openness and transparency and honest consultation!"

ELV and CSF MEAN NOTHING!
So the "consultation" carried out by Cemex and approved by the Agency had the wrong EMISSION LIMIT VALUES printed in the tables, and thus the WRONG CRITICAL SUCCESS FACTORS. "So What?" It is apparently of no concern to the Agency that the whole consultation has been a "sham" involving misinformation and hidden data. So What?

PLANNING and IPC PERMIT MEAN NOTHING!
How did this happen to Rugby residents? Could it just be by an unlawful planning permission, and by an unlawful IPC Permit, that was all carried out IN SECRET behind the backs of the public, and even behind the backs of our elected councillors, and MP? Who knew what, and when, and what did they do about it?

MATHEMATICS MEANS NOTHING!
WCC planners seem to have great difficulty with their SUMS! Simple arithmetic is obviously not a job requirement. On 09/09/99 told RBC officers that the EXACT CAPACITY of the NEW WORKS is 2.9 times that of the existing."

These are Rugby Cement's Own Production figures for cement at the time of the planning application.

1990 : 282,052 tonnes cement. 22,086 HGV movements. Average HGV movements 60 per day.

1991 : 202,052 tonnes cement. 15,808 HGV movements. Average HGV movements 34 per day.

1992 : 236,772 tonnes cement. 16,855 HGV movements. Average HGV movements 46 per day.

1993 : 267,664 tonnes cement. 20,010 HGV movements. Average HGV movements 55 per day.



According to that WCC says anticipated production was to be (on average): 247,000 tonnes per annum X 2.9 = 716,000 tonnes cement per annum. So what HAS gone wrong with the calculations - and where?


# The original outline planning application was for 1,050,000 tonnes CEMENT, which was then altered in February 1996 to read 1,250,000 TONNES CEMENT.

# The AMAZED Public knew nothing until they were then told by the Environment Agency in the IPPC Permit August 2003 that the plant is an EXISTING CO-INCINERATOR manufacturing 5,000 tonnes daily production of CLINKER = 1,825,000 tonnes clinker each year.

# To make cement we add in a 25-30% increase on the clinker figure of 1,825,000 tonnes CLINKER and HE PRESTO we have about 2,300,000 tonnes CEMENT each year.

WCC and RBC ADMIT THEY KNOW NOTHING!
There has been much confusion over the planning and IPC permitting process, Rugby Cement stating that RBC EHO was "not a statutory consultee", but the EA said "yes they were", and officially consulted them in June 1999 when Rugby Cement finally finished its IPC application. This with a response to a Schedule 1 request from the Agency sent to them in May 1997. (YES - over two years to answer a few questions!!) But RBC EHO made no answer to the IPC application and consultation in June 1999, and kept the application off the Public register, and out of the public domain. There are no Council records, minutes, or any data at all about how this was done at RBC.

WCC and RBC HAVE NOTHING ON PUBLIC REGISTER!
Similarly WCC mysteriously also has no publicly available records. And WCC, like RBC, also made no response to the June 1999 IPC application and consultation, although they were immensely involved in the process with the Agency and Rugby Cement. It seems from the above that WCC and RBC did not even know what was actually being built, even after it was already largely constructed.

WHY WERE PUBLIC TOLD NOTHING?
In JUNE 1999 the IPC Permit was slipped in "under the wire" to avoid the public finding out the truth about what was actually being built here, AND PREVENTING THEM FROM CHALLENGING THE PLANNING PERMISSION. The IPC Permit was issued 6 weeks before the regime changed to IPPC on 1st November 1999, because ANY DELAY to the proceedings would have meant that Rugby Cement would have had to make a WHOLE NEW IPPC application, (as opposed to the more simple IPC application) and operate under much higher standards, and also to have faced a very challenging public consultation BEFORE the plant was even operating. The public would have had to have been told then, in 1999, that what was built was an : "existing waste-burning CO-INCINERATOR making over TWO MILLION TONNES CEMENT A YEAR".


WE ANSWER NOTHING!
So instead of facing the TRUTH someone, somewhere, somehow, decided to HIDE the WHOLE IPC APPLICATION AND TO TELL THE PUBLIC NOTHING!

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