MICRO-CLIMATES.

WIND DIRECTION changes at different heights, as is clearly shown in this picture. See the massive plume from the main stack - about 3,000 tonnes a day of gas, laden with pollutants - about 1,000,000 cubic metres each hour. Then notice the streaming plumes from the cement mills, now known as emissions of particulate, "in pure air" (??) from these polluting Low Level Point Sources. When local people complain about "dust" they are invariably scathingly told by the authorities that their "case is not proven - the wind was in wrong direction". But where do these "experts" take their readings? Even the recent air quality assessments which monitored wind speed and direction at four points in the Rugby Borough had four different direction and speeds on the same graph! And do not mention re-suspended dust what ever you do!


WHAT'S NEW?
Since the Rugby Council with drew their support for the Rugby Cement Community Forum in July 2007 there has been only one meeting held in public, in December, in a freezing cold village hall in Bilton. There are plans afoot to change the name of the RCCF, to Rugby Community Cement Forum, which seems in appropriate when the plant has, over Christmas, increased its co-incineration to 220,000 tonnes a year. The household waste (Climafuel) that the public were consulted on in 2007, has now morphed into a permission for 15 tph - 360 tpd, 131,400 per annum of EWC 190210 and 191210, These are apparently residues from household waste and from "wastes from physico/ chemical treatment of waste including dechromatation, decyanidation and neutralisation! Due to the low calorific value 15tph makes only a 30% substitution, while the 87,600 tonnes tyres constitute a 40% substitution being 10 tph.


OTHER WASTES used and stored are listed without waste codes, or quantities, or storage/planning permissions, and the bypass dust is still being trucked in sheeted lorries to be landfilled at Southam, where the "temporary non-hazardous planning permission", such as it was, expired on 31st December. Apparently hazardous waste is not supposed to be allowed to escape, and must be contained, but WCC have agreed to allow them to use returning clay lorries under a Section 106 agreement in 2001. WCC do not seem to know what BYPASS dust is and how polluting.
The old planning permission was for CKD from a coal-burning cement works and this expired in 2001. The Environment Agency seems to have forgotten the Landfill Directive and PPC Regulations, seemingly allowing the dumping under the old expired Waste Management Licence. Every year good old Warwickshire County Council, seemingly in ignorance, gives the operator another temporary extension, even though the landfill has no permission as a hazardous waste site. The bypass dust from the co-incineration of waste is trucked in sheeted returning clay lorries - often streaming out as the lorries travel through the Rugby Town Centre - as witnessed again this week.

MOBILE DUST-CATCHERS ON THE STREETS.
Even the RBC EHO,who have often tried to downplay the air quality problems and contributions from the whole INSTALLATION,and who are slow to bother about such matters as hazardous dust spilling over the residents, have now saida mobile air quality monitor must follow the lorries to try to "catch the dust". Mind you I expect they will warn them first as usual!
Watch this space!!

RUGBY CEMEX CO-INCINERATOR

(click on image to enlarge)
UNACCEPTABLE, UNSUITABLE, UNLAWFUL, SITE OF INDUSTRIAL WASTE DUMP, ENCOMPASSING OPEN AIR WASTE STORAGE, CO-INCINERATION, BLENDING, AND DISCRETE (SECRET) INCORPORATION OF ALL MANNER AND QUANTITIES OF WASTES INTO CEMENT.

WHY OH WHY? IT MAKES NO SENSE!
We Rugby Residents are now in our fourth year of TYRE TRIALS,
with a further one year trial starting to see "how they can manage
to get to 6 tonnes per hour over the course of a year". With a
little bit of luck, and some 15tph of household/commercial/industrial waste
thrown in for good measure. The public were told in the "tyre trials application and non technical summary" that the trials to 10tph would be over within 6 months by 2004, but they are still struggling on with all manner of excuses why they have failed to succeed.
Apparently all this effort just to prove that the 0.15% of particulate emissions emitted from the main stack comes exclusively from the burning of the fuel, which is "not adversely affected by the substitution involved in tyre burning", while the other 99.85% of emissions comes from the raw material "cooking". Believe it - or not! Meanwhile they change the raw materials (responsible for 99.85% emissions) to substitutes/wastes - without any trial, consultation or comment? And Cemex fitted £6 million pounds of bag filters to meet the Waste Incinerator Directive - for the reduction of the particulate emissions from fuel burning emissions from 50mg/NM3 to 30mg/NM3 - except all the emissions are now said to be from the raw materials, and not the fuel at all. Under the WID they are supposed to meet the limits for VOC/TOC (Volatile Organic Carbons) and Sulphur Dioxide, but they claim "a derogation", and actually increased the emission limits fivefold from those existing before the tyre trials from 10mg/Nm3 to 50 mg/NM3.

ALL THIS PUBLIC MONEY WASTED FOR WHAT?
Years of trials - for 0.15% of particulate stack emissions?
EIGHT YEARS of sham consultations; dubious data; withheld reports; pointless public meetings; question and no-answers sessions; misleading and false information distributed; RCCF meetings where questions are asked but not answered - see RBC web site which has suddenly been transformed!; An Agency, which had helped Rugby Cement to build the plant and had just given it an (unlawful) IPC permit in 1999, but that still in 2003 could not tell the public which emissions were permitted and which were not - nor where the emissions came from! The AEAT report into "some" of the differences between tyre burning emissions and coal emissions at four cement plants; The May 2006 EA survey of what people "think" about the cement plant emissions; and now £15,000 largely from the existing health protection budget in order to choose a new Rugby Cemex Co-incinerator Forum;
An Agency which said publicly if the 60,000 people of Rugby came to the meetings and protested, they would take no notice - and which now crows that the protest has somewhat diminished.

WASTES SUBSTITUTED and MATERIALS: TYRES - 600 tonnes stored in open; CLIMAFUEL - household/commercial/industrial wastes; PETCOKE - waste from oil industry; and coal that requires emission limits to increase from TOC 10 to 50mg/Nm3.

PFA; MINESTONE; BAUXITE; OIL CRACKING SPENT CATALYST; ALUMINIUM DROSS; FOUNDRY SAND; GLASS WASTE; SILT;C EMENT BOARD SANDINGS; IRON STONE; STEEL SLAG; IRON PYRITES; TIOXIDE; FLUE GAS DE-SULPHURISATION MATERIAL; POTTERY MOLDS; AND additives such as AMMONIA and SYNTHETIC SURFACTANTS; ALKANOLAMINES; POLYALCOHOLS; SILICA DIOXIDE AND ORGANIC SURFACTANTS and SLURRY THINNERS etc etc

ONE MILLION POUNDS AIR QUALITY MONITORING?
£1 million pounds Rugby Council tax payers money squandered on poorly/wrongly sited ineffective monitoring, in order to "catch" the tyre trials' pollution

- except the trials never properly got going, and the monitoring is over; A
million pounds of ambient air monitoring "hindered" by the Environment Agency which refused to disclose pertinent pollution Dispersion models to help with the locations, and hindered by Rugby Cement which refused to give stack emissions data to the consultants Faber Maunsell and to RBC.

An Agency that does not know which way the wind blows - first in late 1999 before the plant was opened they identified a monitoring site one mile due South of the plant as the "location as close as predictable to the place where emissions from the site were predicted to be a maximum." Rugby people were forced to pay up for two years monitoring - uselessly located due south, too far away, next to a large building, and under a tree.

Then the Agency, after more (secret) dispersion modelling, decided in 2003 that this was NOT the correct location after all, and they then put a monitor one mile due north of the plant, but it appears the data is still not in the public domain; RBC paid thousands of our cash to various consultants who advised the installation of boundary site monitors; properly spaced pollution monitors and the installation of an infra-red stack camera, but all this "good advice" was paid for and simply then ignored.


PEOPLE POWER AT PADESWOOD CASTLE CEMENT:
At Padeswood a straight forward civil law process as a Group Action is underway, on behalf of local residents, who have been blighted by the newly commissioned cement/co-incinerator plant. They will be seeking a) Compensation for Loss of Amenity and b) An injunction on Castle Cement to abate the nuisances caused by their industrial activities. The injunction would have the power of the court behind it and if not complied with, would result in Castle Cement being back in court for that failure. In this action the defence of "operating within permit" is not a valid defence. A Public Nuisance offence is not available as the industry is exempt apparently - as we have found out in Rugby. But, as in Rugby, there is a clear indication of continuing blight upon their lives, properties and possessions caused by emissions of dust, noise, the giant falling plume, and odour, emanating from the cement works, over the preceeding six years.

The cement industry has been left to "Self Regulation" seemingly by dictat of DEFRA. "A lighter touch of the regulations" was a phrase allegedly wielded by government a few years ago. Then, to facilitate the cement company activities further, the 2005 revision of the Substitute Fuels Protocol for Cement and Lime Kilns was so abrasively bullied through by DEFRA and the Environment Agency, after a farce of a "public consultation", that it became clear that as far as Government was concerned, sustaining cement/industrial activity had precedence over the quality of life of local residents. Allied to that, the cement companies, probably through having an eye towards profitablity, have done absolutely as little as they feel they need to do in order control the ill effects of their industrial activities, firmly believing, it would appear, that all and any public complaints via the Environment Agency would be "smothered" in regulation and red tape, and never be anything other than "another entry on the public register of complaints." This current action is "People Power" fighting back against that unjust and improper scenario. And, the inevitable banning from corresponding and from the cement forum has also been tried at Padeswood, with a motion to expel the properly-elected member involved in the legal action - as at Rugby. Only "friends" of the cement company, and those who agree with and endorse both the Agency and the industry are welcome on the Liaison groups and Cement Community Forum!!

DETACHED PLUME?

AT CEMEX RUGBY BLl7248IH

POLLUTION INVENTORY - CARBON DIOXIDE DOUBLES!
On the Agency WIMBY web site you can see various "actual measurements", "calculations", and "estimations", of the "main" pollutants emitted from the MAIN STACK at Cemex Rugby, presumably discounting the main health damaging pollutant of PARTICULATE PM10, which has been of much concern to Rugby residents and to health professionals. The "Cement and Lime Activities Guidance Note PI-CEML-yv071" has been issued to the industry to help them to fill in the forms, as required by the EU, in the correct manner. However there exists much "uncertainty" as to how these figures have been arrived at - and we are left wondering as to the purpose, accuracy and reliability of these figures. Meanwhile the British Cement Association is protesting against the 67% increase in charges to be imposed by the Environment Agency as it gains about £3 million from the EU ETS, with presumably 60 EA staff working full time on this issue alone. See Charges Consultation 2007/08.

CARBON DIOXIDE has more than doubled, (quadrupled since 1999), and in 2006 has been split into two parts - 471,000 tonnes of "thermal" and 604,000 tonnes "chemical" - whereas in 2000 they state they have emitted only 500,000 tonnes - double that of the old plant! But other pollutants do not appear to have increased by the same ratio - suggesting something is possibly "wrong" with the reporting? They have evolved a new method of reporting the pollutants in a "random order" instead of by alphabetical listings. Carbon monoxide seems to have disappeared all together! The old plant can be traced under AH8697. AMMONIA appears steady at about 6 tonnes.

ENVIRONMENT AGENCY TO ANSWER CONCERNS:
about increased number and duration of apparently "detached plumes", which by nature form after they are released from the stack, which is very worrying? We have requested information about the time and duration of any trials, tests and changes that have been carried out at the plant during December 2007 as permitted by the Agency such as the use of AMMONIA to reduce nitrogen dioxide, and clay-substitute trials.

ON DETACHED PLUMES: RAPCA:
"For condensable PM and detached plumes - which by nature form after they are released from the stack, BLDS and PM CEMS are meaningless. Measuring precursors (SO2, NOx, THC) would probably be more sensitive and certainly VEs would be more cost effective. Although reading detached plumes (especially since they are usually combined with steam plumes) is EVEN MORE SUBJECTIVE than reading an attached plume."

HEIDELBERG CEMENT California:
"Cement plants, are sometime afflicted with a "detached plume" meaning that detectable emissions do not form until after exhaust leaves the smoke stack.
Chemicals in the plume don't combine to create a problem until after leaving the stack, so sensors inside the stack can't detect the problem.
This often occurs due to changes in the ore and other raw materials used to make cement. The ultimate cause can only be determined through exhaustive and expensive testing. Testing of the plume by the company so far shows the plume contains ammonia, sulfates, chlorides, all potentially harmful to the public under the wrong conditions."

HEIDELBERG CEMENT 1 JUNE 2006:
"With an SNCR control NOX is reacted with ammonia or urea in an environment with a specific temperature range and for a sufficient residence time. The effective temperature range for SNCR is approximately 100-2000F. For a preheater/calciner system this would occur in a zone near the lowest stage of the preheater tower.
Below the effective temperature ammonia present in the gas stream does not react and "AMMONIA SLI " occurs. Likewise if excessive quantities of ammonia/urea are injected some pass through un-reacted and cause ammonia slip. Either case will result in a release of ammonia from the stack that could result in producing a detached plume, causing an opacity compliance issue. If injection occurs at temperatures above the effective range, ammonia present in the gas stream will react to form additional NOX, and NOx emissions may increase."

WARWICKSHIRE COUNTY COUNCIL
Are stuck between a rock and a hard place, yet again! They are disputing with Cemex over various issue including the Western Relief Road, which we recall was prevented from being built in 2000 by the intervention of Rugby Cement and ex MP Andy King who said they wanted to re-open the rail link to the Southam clay quarries, (because they have NO RAW MATERIAL in Rugby) removing about 70 HGVs a day from the villages - about 10% of the TOTAL LORRIES!

Now it is a question of whether the new SILO for the EXPORT/IMPORT of clinker needs a planning application under the Town and Country Planning General Development Order 1995 - or not? And also what about the new conveyors, docking station, etc for the burning of household waste? And also what about the STORAGE of the large quantities of INDUSTRIAL WASTE which have been substituted for raw materials, on the site, without any European Waste Codes or publicly available information about the nature, quantity, and likely/possible impact of these wastes on local air quality and health?
The Environment Agency will not answer any questions about these wastes - so who is responsible for the turning of Rugby into a WASTE DUMP without apparently any planning permission or IPPC Permit? And not to mention the words PUBLIC CONSULTATION!

CEMEX SET FOR TILBURY PORT MILL:
This new 1.2 million tonne per annum facility, (opening summer 2008) according to Paul Fletcher UK Environment Manager: "is ideally positioned for shipping in the half a million tonnes of SLAG it will require per year for the production of CEM3." The CEM3 blended cement product uses 50% clinker - compared to 95% (??) used in the previous blends, which will reduce its CO2 emissions by 50% for each tonne of cement produced.

GREAT ENVIRONMENTAL BENEFIT?
"The 600,000 TONNES CLINKER will be transported by ROAD from the RUGBY CO-INCINERATOR plant." Is that extra clinker - or instead of that they make into cement at Rugby?

Sensitive lorry miles - what are they?