(I see no cement plant?)????
LAND REGISTRY DENY VERY EXISTENCE OF RUGBY CEMENT!
WCC, RBC, & AGENCY CARRY ON IN SECRET, AS EVER!
PUBLIC NOW BLAMED FOR TYRE TRIAL DISASTER!
COMPANIES HOUSE CONFUSED AS TO OWNERSHIP OF THIS NON-CEMENT PLANT.
The Land Registry are in denial. They say they have no details of any cement plant at Rugby, despite the new plant changing hands twice since compulsory registration. The Environment Agency omitted it from the Pollution Inventory. Warwickshire County Council admit it never had any consultation in the planning stage, or over the addition of the equipment to make it a CO-INCINERATOR. It never had any kind of environmental impact assessment at any stage. The EA and Rugby Council admit they hid the June 1999 IPC consultation, and made no attempt to limit the damage to Rugby's environment and air quality. The Agency conveniently omits to put public notices on the Public Register. 62 County Councillors and 48 at Rugby have bags over their heads; and gags!
So here is the latest news from "no cement plant" at
Rugby Works OS Grid ref: SP 4487 2757
Cemex UK Cement Ltd (company reg: 475212)
Cemex UK Operations Ltd (658390)
Chinnor Transport (475212)
Rugby Limited (475212)
NEW TYRE TRIALS
One month consultation has now started by the EA as Cemex wish to double tyre burning, to 25% substitution. The baseline will be with 3 tonnes an hour tyres, and there will be two weeks testing after that at 6 tonnes. This trial will be different - so they say using a novel approach - it is to be "well-conducted!" Ha! 600 tonnes of tyres will now be stored in the open, and the restrictions on run-off into the sewer will be removed, presumably to allow all drainage from the tyres into the water course.
HOW TO JUDGE TYRE TRIAL SUCCESS
Cemex comedy sketch writer: "This trial will build on the success of the previous trial." The seven previous CSFs (Critical Success Factors) will be removed and replaced by such little gems as: CSF 1 "The current specified emission limit values will not be exceeded for any reason DIRECTLY ATTRIBUTABLE to tyres." So there is a challenge to the public. How is anyone to know, when even the Agency does not know.
AGENCY say:
"Emission limits apply to the Works at ALL times, with the ONE (teeny weeny little??) exception:
"The limits do not apply during shutdown or startup. Startup is complete at 200 tonnes an hour of dry raw material." That is at about 80% of full rate.
No mention is made of fuel/s! Nor for how many hours these shutdowns/startups occur.
Also when asked repeatedly for how many hours a day/week/month/year no emission limits count the Agency said to go to the Public Register and try to work it out. Finally, after seven years of badgering the Agency admit to having no idea at all about how many "unlimited" hours there have been since February 2000. They have, at last, asked Cemex to provide it. We would only note that in the tyre trials data the 1,000 hours was interrupted by 53 stops - with no data made available - so watch this space.
CSF 5: "There will be no increase in reportable incidents or JUSTFIED complaints relating to the use of tyres."
So that nicely puts the onus back on the public to collect samples and evidence.
£50 REWARD FOR SIMPLE SUMS:
The Environment Agency needs help. They cannot work out how many tonnes of clinker were made in the two "supposedly comparable" 1,000 hour periods of the trial
Can you help them work out how many tonnes of clinker in each of the 1,000 hours?
* 1,000 hours baseline produced 3291 tonnes bypass dust = 1.37% clinker produced.
* 1,000 hours tyre trials produced 3006 tonnes bypass dust = 1.59% clinker produced.
The Agency have asked Cemex to help them. One wonders why the Agency has permitted the permanent burning of tyres when the Trials and the with holding of all the crucial data were condemned widely by all the consultees. (Even Rugby Borough Council agreed with us for once! And the Primary Care Trust,Tyre Burning Review Group, Rugby Cement Community Forum etc etc)
POLLUTION EVENT 10 MARCH 2007 UPDATE.
Six months on and the Agency admit that they still have no idea of the chemical breakdown and particle size distribution from the Cemex pollution episode. Cemex confessed that an estimated eight tonnes of milled coal "escaped" from a silo and rained down on sleeping residents up to three miles away. The Agency do not know the answers to questions about the health and environmental impact, nor when, or even if, they are going to prosecute.Rumour has it that frustrated Rugby residents are taking a private action through the Magistrates Court. Against Cemex and against the Agency for permitting this type of incident to keep on happening to "innocent victims".
NO SURPRISE!
AIR QUALITY GETS WORSE IN RUGBY.
AIR QUALITY MANAGEMENT AREA BOROUGH WIDE FOR NITROGEN DIOXIDE, AND NOW ALSO PM10 INCREASES CAUSE CONCERN:
RBC say previous tyre trials increased particulate emissions. Main stack, bypass area, and cement mills increase burden and health impact of particulate of which THERE IS NO SAFE LEVEL!
PM 10 Readings in MICROGRAMS PER CUBIC METRE
AQMS 1 Webb Ellis Road :
25 March 72 Micrograms cubic metre
27 March 59
28 March 67
Has Maximum PM10 hour at 120 and PM2.5 at 72.
AQMS2 NEWBOLD ROAD : 11 EXCEEDENCES
25 January 54
3 February 66
4 February 62
6 February 80
7 February 68
25 March 82
26 March 57
27 March 70
28 March 77
30 March 59
31 March 53
PM10 maximum hour 206!
Why is this the ONLY TEOM with NO PM2.5 monitor?
AQMS 2 has massive NOX at 1138 for one hour!
NO at 683 and NO2 at 141 for the hour.
AQMS 3 LAWFORD SCHOOL
3 February 53
4 February 58
6 February 53
25 March 83
27 March 63
28 March 68
31 March 52
PM10 maximum 142 for the hour, and 62 for PM2.5 with a daily average of 42 for PM2.5!!
AQMS 4 Avenue Road
25 March 77
27 March 57
28 March 64
Avenue Road maximum hourly was 130.
Highest PM2.5 was 57.1 hourly and daily average 39.3!!!
CEMEX EXCEEDS EMISSION LIMIT VALUES
DIOXIN and FURAN EXCEEDENCE (admitted 4 July)
The ELV for the most toxic substance known to man was exceeded on 22 March at the CEMEX RUGBY works in the twice yearly tests from 0915 to 1540. After they removed the what they call "measurement uncertainty" they still had readings of 0.43 ng/Nm3 ITEQ (1&2) and 0.5ng/Nm2 WHOTEQ (1&2)
CARBON MONOXIDE EXCEEDENCE
Also on 13 June 2007 main stack test hourly average AFTER they removed confidence interval (-10%)was carbon monoxide 629 mg/m3 as an hourly average.
CEMENT MILLS EXCEEDENCE
Also they now admit (4th July) that the mills are also exceeding their permitted levels as well. On 28/03/07 from 16.15 to 18.20. Cement mill 4 running at 52.6mg/m3 particulate, after removal of confidence level.
23/03/07 Mill 5 separator at 34.2mg/m3 after removal of confidence level.
If you add back that 30% that means they have taken away as a "confidence level" they would have initially had a reading of 75 mg/m3 at mill 4. If you add the "uncertainty" instead of taking it away it gives a reading of 98 milligrams per cubic metre on mill 4. That is 98 THOUSAND MICROGRAMS in each cubic metre - to drift across Rugby, and to be resuspended in our air! Cemex say: "INVESTIGATIONS CONTINUING WITH CONTRACTOR INTO REASONS FOR HIGH RESULTS"
CONTINUOUS EMISSIONS MONITORS FAILED during tyre burning at 21:01 on 15th June. They did NOT stop the tyre feed until 21:50 which contravenes the Permit.
NO CONFIDENCE IN THE AGENCY TO REGULATE!
NOR IN CEMEX' OVER READING, OR UNDER READING?
There is no reason why the instruments might not be under-reading. Why should they assume they are over reading - merely to facilitate the company, and make the results look better - or rather to "look less bad"?
THE IPPC PERMIT OF AUGUST 2001
Included a permanent permission to burn 40% tyres so why are they again bothering us with yet another SHAM CONSULTATION?
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