Rugby In Blume

It's bluming propaganda to hear the Environment Agency and Rugby Cement/Cemex repeatedly saying that the SERIOUS and WIDESPREAD issues concerning the Rugby co-incinerator are:

# "within a narrow and local compass, and have limited social and environmental implications"

# and are merely the concerns of a "limited number of individuals" who are vehemently opposed to the ongoing lawful operations of a regulated industry in the town in which they live.


PETITION: The Agency should wake up and listen. Even their own recent Survey of just 530 hand-picked residents showed them how concerned many Rugby people are, but the Agency are only going to "communicate better how we regulate the cement plant". How comforting! 7,500 RUGBY RESIDENTS signed the PETITION (in just a few weeks) against the burning of WASTES (not just tyres) in the Rugby Cement works and this was presented to Tony Blair at Downing Street. Since then there has been a far greater INTENSIFICATION of USE, and we are now the target for London's household and commercial waste.


The manufacture of cement in which about one tonne of carbon dioxide is given off for each tonne made has far reaching consequences for the Climate Change, and global pollution.

Considerations involve: reducing the need for, and use of cement; pollution; health effects; waste disposal; sustainable development; BPEO - Best Practicable Environmental Option; Proximity Principal, etc. These are global, not little local issues as the EA would have us believe. There is a lot of concern here in Rugby in particular because of the nature (semi-wet) of the plant, the huge gaseous pollutant laden emissions (300 cubic metres second?) and the proximity to people.

All over the world cement plants and power stations are being studied as major sources of pollution. The Pulverised Fuel Ash from these power stations is used in cement plants - about 100,000 tonnes a year at Rugby. MERCURY EMISSIONS, hydrogen chloride, and total hydrocarbons among pollutants of great concern at cement plants worldwide. Hot off the press in the USA :

"If cement kilns use such fly ash, the contained mercury is likely to be volatilized in the cement production process and then emitted as air emissions from the kiln. Thus, the kiln's mercury emissions would increase and any benefit (or most of the benefit) of controlling mercury at the boiler would be lost."

Inside EPA July 21, 2006

DESPITE DELAY, EPA UNLIKELY TO ADDRESS MERCURY IN CEMENT MACT

Although EPA is allowing environmentalists more time to comment on a proposed rule revamping its court-rejected air toxics standard for Portland cement facilities, EPA and industry sources suggest the agency is unlikely to require the mercury controls activists are seeking, likely prompting new litigation to challenge the rule.

The agency announced in the July 18 Federal Register that it was reopening the comment period until Aug. 1 on its maximum achievable control technology (MACT) standard for Portland cement facilities to address mercury, hydrogen chloride (HCI) and total hydrocarbons. An EPA spokeswoman says the agency simply agreed to give environmentalists more time to submit comments, and says it is not "reconsidering" anything.

An industry source says the cement production industry will also take the opportunity to again raise its concerns that the rule's HCI controls are too stringent.

Under a court order, EPA was to have finalized the rule later this month, but sources say the environmental litigants and the agency have since petitioned the court for an extension until Dec. 8.

The Portland cement MACT was originally finalized in 1999 but was challenged by both environmentalists and industry in a consolidated case, National Lime Association v. EPA. In 2000, the U.S. Court of Appeals for the District of Columbia Circuit agreed with environmentalists that the rule was too lax and remanded it back to EPA. But the agency never acted on the remand, so environmentalists went back to court and in 2005 reached a settlement that required EPA to revamp the rule.

EPA's revised MACT, reproposed last December, requires existing facilities to control for total hydrocarbons and new facilities to control HCI, but does not impose mercury controls, finding that the cost-per-ton was unjustifiable. That proposal was met with opposition from environmentalists, who argued that it should have included mercury controls, and from industry, who said it may have gone too far in other requirements.

EPA also took comment on whether it should ban the facilities' ability to use fly ash -- a coal byproduct used as a raw material to make cement -- as a way to control mercury in lieu of facility-specific controls. Limestone, another raw material, also contains mercury.

Environmentalists are now pushing hard for the fly ash ban, as well as for mercury-specific control technology. In supplemental comments submitted in April, the Clean Air Task Force wrote, "If cement kilns use such fly ash, the contained mercury is likely to be volatilized in the cement production process and then emitted as air emissions from the kiln. Thus, the kiln's mercury emissions would increase and any benefit (or most of the benefit) of controlling mercury at the boiler would be lost." Relevant documents are available on InsideEPA.com.

Industry, meanwhile, supports continued use of fly ash in cement-making. In Feb. 23 comments, the power company Dominion wrote that it "opposes this ban on the use of fly ash as a cement plant raw material because it appears in the draft rule to be unjustified and not supported by existing scientific data. EPA acknowledges this uncertainty in the draft rule and at a minimum it should gather more data prior to making this decision."

A source with the Portland Cement Association says that despite the delayed deadline for a final rule, EPA is unlikely to require any mercury controls because the technical barriers and raw materials limitations have not changed since the revised rule was initially proposed. The source says environmentalists therefore will likely return to court when EPA finalizes the rule. An environmentalist says activists' understanding of the additional comment time is that EPA had agreed to give "further consideration to mercury control and to the use of mercury laden fly ash."

In a related matter, environmentalists filed suit July 7 over EPA's MACT for large municipal waste combustors, which does not require any additional pollution cuts. Environmentalists say the combustors are responsible for 13 tons of mercury emissions per year plus other air toxic releases. EPA finalized the rule in May despite internal concern that it might allow "backsliding," the environmentalist says.

The source adds that the rule marks the first time that EPA has taken action under Clean Air Act requirements to review and revise incinerator standards every five years, although the rule was officially due in 2000. Sierra Club took EPA to court to win a deadline for the revision, and is now challenging the revised rule as unlawful.

Question time in Rugby

How are we to be polluted next?

Not quite Dimbleby, but MP Jeremy Wright chairs, and the infamous Mrs P. tries to get the truth out of Cemex; the Agency; and RBC. You must not miss it!

APPLY NOW for ring side seats at last legal blood sport.

PQT Monday, July 10th 2006 for immediate release

Public Question Time Event on the Use of Alternative Fuels by Cemex
Following the recent consultations by Cemex regarding its alternative fuel strategy, Rugby Borough Council is holding a public meeting to help interested members of the public to understand some of the issues. The event will be held on 27th July between 7pm and 9pm at the Benn Hall, Newbold Road, and Rugby.
The purpose of the event is provide a balanced discussion on the specific issues involved in the use of alternative fuels, in order for those present to come to an informed personal opinion on the issues. Panellists will include Cemex, Rugby in Plume, Friends of the Earth, Environment Agency and Rugby Borough Council. Jeremy Wright M.P will moderate the event

As space is limited the Council is recommending that people apply for tickets before the event. For tickets contact Rugby Borough Council with your name and address, and specify the number of tickets required.
Please quote “Question Time Tickets” on all correspondence.
Rugby Borough Council can be contacted in variety of ways;
By post to: Rugby Borough Council, The Retreat, Newbold Road, Rugby, CV21 2LG.
By Phone to: 01788 533869 or e-mail: HEH.Reception@Rugby.gov.uk
In person to any Council reception point.

As there is likely to be a great deal of interest and as such some question will not be able to made on the night, so there is an opportunity for the public to register a question in advance. If doing this, please submit it with your name and address, this is not a requirement but may assist the panellists to provide more specific responses.

As many questions as possible will be taken on the night, but it is unlikely that every person will be able to speak, however, all questions submitted will be passed to Cemex as part of the consultation.
Ends

NOTE TO THE NEW EDITORS: For more information please contact, Sean Lawson, Head of Environmental Health on (01788) 533850.
NOTE: The Benn Hall capacity is limited to a maximum of 450 people so you are advised to apply in advance for tickets. Tickets will be limited, initially to 2 per household. A limited number of spaces together with unallocated/used tickets will be available for those who attend on the night on a first come basis.
Doors open from 6.30pm. Last admission by ticket 6.50pm.
Additional material attached for information

Rugby's TEOM monitors NO GOOD!

RUGBY IN PLUME PROVEN TO BE "RIGHT ALL ALONG!"

The four air quality monitors known as TEOMs, on which Rugby Borough Council, the EA, and Rugby Cement have earnestly sought to rely in their desperate attempts to downplay and report low pollution levels in Rugby in general and in the area around the Rugby Cement works in particular, are now proven, (as Rugby in Plume and other experts have always maintained), to be substandard, not to be comparable, and not to be equivalent to the EU standard.

In a nutshell the TEOMS seriously UNDER-READ the pollution, and under-read the SHORT TERM PEAKS of PM 10 PARTICULATE, and thus they provide a false sense of security about air quality, misleading the public on the ACTUAL pollution levels. Short term peaks have severe health impacts, particularly on the vulnerable receptors, and the frequent "fugitive" incidents at the cement works, along with the permanent 24/7 emissions from the main stack, from the other 24/7 low stacks/sources, and the heavy traffic/HGV pollution, are not being monitored correctly in Rugby. The Turnkey monitors (19 in Rugby) which show much higher readings and far more DAILY EXCEEDENCES of the Objective, would seem to be more accurate, but the data from these peaks has NOT been provided, and these monitors are frequently "re-calibrated" in an effort to make them read lower - to make them READ LOW like the TEOMs!!

PUBLIC CONSULTATION REQUIRED
There MUST, as the Audit Commission has told, in a very damning Annual Report on RBC, be consultation between the PUBLIC and the Council, and we need to be consulted on the air quality and the proposed monitoring.

With the anticipated increase in TOTAL pollution to be caused by the Cemex co-incinerator, which is due to increase production and therefore to increase the emissions, and also to increase the types and mixes of wastes that it is burning, plus the impact of the PETCOKE, which is recognised world-wide to increase the emissions of the smaller more-contaminated and health-damaging particles, I ask that the public are consulted on this monitoring programme.

The TOTAL BURDEN of the cement works has been increasing year on year since the new plant began, and while Rugby Cement can rightly claim a good reduction in the emissions of sulphur dioxide, unfortunately many of the other pollutants are all increasing. There has never been any impact assessment of how much worse the emissions are today than in 1999, the last year of the old plant. Some of the pollutants are more dangerous and carcinogenic than others, and then there is the difficulty of working out the synergistic effects and health effects of these mixed-up chemicals.

We do not have enough data about the speciation of particles, and about the chemicals adsorbed onto them to work out the health impact and costs to the community. The data provided is very "primitive" - even if its accuracy were to be guaranteed? The Agency has been found by the courts to be in breach of common law, unfair, and to have withheld data about the emissions at Rugby Cement that would impact on the environment, and thus on air quality and health. The Company and the Agency do not know themselves what is coming out, and there is NO CONTROL of EMISSION LIMITS on any pollutant during start-up, until 200 tonnes an hour is reached, and during shutdown.

Many emissions are uncontrollable and immeasurable.

HEATH IMPACT ASSESSMENT RIP have asked some of the UK's top health experts to help us, at our own expense, to make a report on the health impact of the plant, but while consultants are willing to do so they have asked us for more data than even the EA or Rugby Cement possess, as without this they cannot begin to count the costs, nor to produce a meaningful report.

Maybe we should start a campaign to knock down the new plant and bring back the old!

http://www.airquality.co.uk/archive/reports/cat05/0606130952_UKPMEquivalence.pdf