World expert considers Rugby's case:

I requested an opinion from world wide expert Dr Neil Carmen, who knows about the Rugby case as it was discussed at an International conference in Nice last year. I am concerned about the fivefold increase in the permitted VOC emissions from the main stack the Environment Agency has just allowed - as a Variation to the Permit. They "claim" that it is only methane from the "grinding of Welsh coal that is very high in methane" that is causing this increase in TOC from 50 tonnes a year to about 250 tonnes a year. They have already been burning Welsh coal for 8 hours a day for a long time, so why this sudden increase? But after consideration of the data from other waste burning cement kilns where TOCs had increased, I decided to consult the world expert. (The Health Impact Assessment was carried out using a 1mg/m3 emission limit and now they have permitted 50 to 75 times that.. that means there are 50- 75 milligrams in each cubic metre of gas emitted - being about 280 cubic metres every second.)

I was also mindful of the fact that RMC itself was worried about the TOC from wastes, having put in its own application (Non-technical Summary May 2002): "The size of the pieces of tyres is of very great importance from the point of view of the environment, cost and operation. The cost of chopping tyres increases substantially as the shred size is reduced. From this point of view these is therefore an incentive to use the largest practicable shred size. On the other hand a very large shred size may lead to unreliability or jamming in the mechanical handling system. Whilst unlikely, it might in an extreme case lead to an increase in the TOC level in the exhaust gas or to accelerate the rate at which accretions form (sic) the plant.
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From: Neil Carman
Sent: Monday, January 23, 2006

Lilian,

Today is a problem since I am very shortly flying out to a national EPA hearing on cement kilns today in North Carolina to speak Tuesday on mercury emissions and the need for controls.

There are a few cement kilns in small towns and on the perimeters of small cities which suffer. I think all of them are bad situations but yours seems particularly dangerous to the community whenever the plume comes to the ground and even then you will significant fallout of PM and gases as the pollutants cool and descend to the ground. Especially at night when it's cooler atmospheric conditions cool the plume more quickly and winter time when the same phenomenon happens.

I am concerned that the plant is so large that they are going to experience more and more operating problems because everything is so large and will suffer more and more equipment breakdowns.

Are the fuels in the new combustion chamber 40% tyres or is the fuel the same as in the cement kiln? I suspect they will have lots and lots of problems burning such a high percent of tyres because the tyres will be sticky and clog up their tyre loading & transfer system.

Depending upon the stack emissions, I think several pollutants will be major problems including mercury and others.

BIGGEST AIR POLLUTION CONCERN I SUSPECT FOR ADVERSE HEALTH IMPACTS IN RUGBY SHOULD BE THE ACID GASES AND ACID PARTICULATES!

BUT TOXIC VOC'S MAY ALSO BE A HUGE PROBLEM!

AND FUGITIVE TOXIC VOC'S LEAKING FROM TRANSFER POINTS COULD BE DEADLY ALSO.

Is this a death sentence to the Rugby community? Potentially yes.

Acid gases of SO2, SO3, H2SO3, H2SO4, NOx, HNO2, HNO3, HCl and HF plus acidic PM/PM2.5/PM1.0 particles will be exceptionally bad for health impacts and the plume is going to be extremely acidic and may kill people if it's bad enough when it descends to ground level.

SO2 = Sulfur dioxide

SO3 = Sulfur trioxide

H2SO3 = Sulfurous acid

H2SO4 = Sulfuric acid

NOx = Nitrogen oxides,

HNO2 =Nitrous acid

HNO3 = Nitric acid

HCl = Hydrochloric acid and

HF = Hydrofluoric acid

Acidic PM/PM2.5/PM1.0 + ultrafines. will be carrying all these acidic compounds and metals/metal compounds plus dioxins, furans, and other organic chemicals/PICs.

Neil
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This was in reply to my request for help of the same day:

On 1/23/06,

Neil

How are you?
Sorry to bother you, but things are dire here. They now admit that the plume, whether visible or invisible, will ground on the Rugby residents, but that it is not a "significant hazard". How much dioxin, metals, particulate, and mercury etc are good for Rugby people? All they can come up with is that tyres are "no worse for Rugby people than the burning of coal".. But now they have set even loser limits as they say that the emissions are "only" from the raw materials, and not from the fuel.

There are about 30 tonnes of fuel an hour, coal now being replaced by up to 40% tyres but they have not got beyond about 3 tonne an hour yet. They intend to burn al wastes and petcoke.

You have seen the photo of the plant. I can email it again. Do you know of any plants in a town like this? It is semi-wet and has a huge plume day and night that falls in chunks often. There are NO emission limits on shut down or start up - till 200 tonnes an hour throughput raw meal.

They have added a new combustion chamber - they say to make the plant run better and to homogenise it?

1. The kiln where they say 30-40% of "heat input through the burners will go" (no wastes go in there)

2. The calciner (original ) where they say 10-25% heat will go

3. New combustion chamber where 40-55% of heat will go.