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