IT COULD HAVE BEEN WORSE!

GREEDY OR WHAT?
NO you are not seeing double!
Rugby Cement said "one kiln not enough!"

In August 1999 when the Agency should BY LAW have been consulting Rugby residents and Rugby Borough Council on the minutiae of the New application and New IPC Permit for the New Rugby kiln and works, the Agency minds were actually pre-occupied by the desire of Rugby Cement to operate the TWO works simultaneously - together - at the very same time! So pre-occupied that these authorities apparently FORGOT to even tell us about it, let alone consult us. Except of course that RBC were consulted (sworn to secrecy) and they simply FAILED to answer the consultation; a decision made by RBC employees/person/s unknown who acted in secret, and simply HID the application and consultation from everyone.

And despite frequent Freedom of Information Act requests they still refuse to tell us WHO made the decision, and HOW, and WHY? What spurred them on to deliberately damage the environment, the whole town of Rugby, and the health of Rugby residents? What could possibly make an "Environmental Health Office" behave in this way?

Rugby Cement meanwhile, true to form, took full advantage of the incompetent, weak, and secretive WCC, RBC and Agency officers :

"Rugby Cement had planned to shut down the existing kiln at Rugby immediately before starting the new kiln. But a recent survey of MARKET REQUIREMENTS for cement has shown that almost the FULL capacity of the new plant is likely to be needed as soon as it has been put into service. It is unlikely that kiln 7 will operate at a high availability during the first few months of service so Rugby Cement has had to review its options. Rugby Cement requests a condition in its "Authorisation" allowing kilns 6 and 7 at Rugby to operate simultaneously."

"We have carried out Dispersion Modelling, and if the highest emission limit were combined with the most adverse weather condition then that value would be ignored anyway!"

"Rugby Cement recognises the need for operation of the plant to a proper standard during this period of simultaneous operation. The old and new kilns will be under overall control of the same works manager to ensure that operation (including staffing) of the two kilns is co-ordinated effectively.

The kiln operators for the old plant will be properly trained, and particular attention will be paid to the way they perform their duties!"

WCC SAY: "With regard to the operation of the two Rugby plants at the same time the situation is as follows. It has always been accepted that there will be a period during commissioning of the new works when cement will continue to be produced in the old kiln. Southam was not brought into the equation as the closure had not been announced. We are now aware that the chalk pipeline delivering chalk to Southam from Bedfordshire is unlikely to have sufficient capacity to run the new Rugby works, and so Southam will close."


# So that's all right then - proper training and a HOPE and PRAYER that the weather will be kind to Rugby people! #

Old Kiln 6 has:
Stack height 92.4 metres;
Exit Velocity 15.4 metres/second;
Normalised flow rate 54.4 Nm3/s:
Actual flow rate 92.1 Am3/s;
Temperature 189 C;

New Kiln 7 has:
Stack height 115 metres;
Exit velocity 15 metres/second;
Normalised flow rate 197 Nm3/s;
Actual flow rate 279 Am3/s;
Temperature 115 C;
Preheater : 24 m X 33m X 100 m = 79,200 cubic metres.
(planning application was - with integral stack 20 m X 20 m X 76 m = 30,400 cubic metres).


CO-INCINERATION IS HERE TO STAY.
THE AGENCY CLAIMS TO HAVE COMMON SENSE!
"It is considered the operator has a 'degree of success' in meeting the Critical Success Factors. In determining whether or not Cemex has succeeded in this we have applied 'reasonableness and common sense'."

HOW REASONABLE?
The Wrong Permit was quoted; the wrong ELVs (emission limit values); and the wrong CSFs (Critical Success factors). The Agency watered down the need to comply with ELVs 'at all times', and in secret, gave dispensations to allow Cemex to operate OUTSIDE of the permit conditions for both nitrogen dioxide and TOC.

The TOC limit in the original BL7248 permit was 10mg/m3 and it was varied on 1st November 2005, during the Tyre Trials (which had begun with the baseline in August) to 50/75mg/m3.


Nitrogen dioxide in the Permit was to be reduced by Improvement Condition to 500 mg/m3 from 13th August 2005, but in a 'secret' letter Cemex were allowed to increase the level to 800mg/m3, which was then confirmed in the Variation of 1st November 2005. So for 3 months the specified Permit ELVs were not complied with.

£400,000 FINE APPARENTLY NOT ENOUGH!
And we must not mention the Warwick Crown Court Case 3RD October 2006 which heard how the plant was being managed (or rather not managed!) during the Tyre Trials on October 14-15th 2005, when Rugby's Lawford villages got 'plastered' in reject clinker dust and particulate; and Cemex was fined £400,000. And in the three related Court Cases somehow neither Cemex nor the Agency just happened to remember to inform the Judge that this was during the Tyre Trials. Although blissfully unaware that this "two day pollution episode" occurred during the Tyre Trials, still a very serious sentence of £400,000 was imposed by a stern Judge.

CEMEX DECISION TO APPEAL APPALS !
On March 23rd the Court of Appeal will hear the plea for leniency, and be able to Judge for themselves whether they think the sentence was too harsh.

AIR QUALITY REGULATIONS:
MORE BAD NEWS FOR RUGBY:
New standards in air quality (designed to protect health) for heavy metals and polyaromatic hydrocarbons introduced in the EU Daughter Directive are not "absolute limits" and must only be "attained as far as possible" and will NOT apply round the IPPC regulated cement/co-incineration plant, which will only have to use BAT to control releases.