Saturday, August 25, 2007

MAKING MONKEYS


(click to enlarge print and wear!)
..OF RUGBY RESIDENTS YET AGAIN!

Speaking of Rugby residents a reliable source informed "They have been duped yet again. It is easy when you know how. We do it all the time. Making monkeys is us!"


PUBLIC CONSULTATION ANYONE?
The new-Labour Environment Agency promised much - "better regulation; open transparent governance; access to information; public participation; adequate effective meaningful consultation; environmental protection; air quality and health improvements; stricter controls on industry...."
The EA already had the Cemex Application to increase tyre burning by 100% was by 12th July, but "somehow" it was omitted from the July 18th RCCF meeting, and now we are being scrambled to consider it on 29th August, with only five days notice. No time to inform the public either! Typical.


RBC ON EXTRA TYRE BURNING * "While it is accepted that the statutory period for consultation is 28 days it is not considered appropriate for the voluntary sector, which have valid reasons to consider this application. Under the Warwickshire Compact Agreement 12 weeks is normally provided for consultation, in line with Government recommendations. "
* "Only 2 weeks is proposed for the trials. This is considered very short especially as new bag filters have been fitted and the proposal is a SIGNIFICANT increase in tyres as a substitute fuel. (100%.)"
* "The previous tyre burning trials had shown an increase in respirable particulates. The area has elevated levels of particulate. The Council requests the impact of the trials on particulate emissions be closely monitored and carefully considered."


BUNCH OF FLOWERS BUYS OFF TOWN - COMMUNITY MATTERS?
The Cemex Rugby Cement Plant Community Matters newsletter has dropped on the mat of the lucky few thousand houses in the areas CV21 and CV23 nearest the works. Funny it is not delivered in the town centre, nor of course in the nearby Rugby School conservation area, where residents seemingly do not need to know, and do not breath the same air? The latest charitable donations, £125,000 to Church Lawford Village Hall, and unspecified sums to RBC for the Rugby in Bloom competition are proudly announced. Never let it be said that these "timely select donations" are not specifically designed to buy-off, divide up, or compensate sections of the Community.

As the World Business Council for Sustainable Development admitted, the cement industry is not sustainable in the long term. It advised the cement industry to target decision makers, divide up the politicians, and to deal with protesters by isolating them or by engaging them in things the cement industry wants them to do, to keep them busy, and to keep the population happy by telling them plausible stories for the future.


TIME FOR REFRESHMENT?

Cemex say: "In a recent report to RBC Sean Lawson, Head of Environmental Health Services set out the options for the future of the Rugby Cement Community Forum or RCCF.
The RCCF was set up over five years ago to provide a means for the community and the company to meet, exchange information and examine any issues concerning the plant's operation. It was, he states, a short term measure which should now be reviewed. A number of options were presented and these included carrying on in its present form, disbanding it completely, or passing the responsibility (and the expense) to the company.
He believed that the Forum had become 'adversarial in nature' and this had contributed to it not achieving its objectives.

It is certainly more common practice for such liaison to be facilitated and financed by the company involved and it was this option that was accepted. However a final decision has been put off until later in the year. If the original decision is upheld, independent research would be carried out to establish the make-up and organisation of a new liaison group and how this can best serve the needs of the community."

WISHFUL THINKING CEMEX!
This "Option" has been "called in" by some environmentally aware Councillors. The Tory Cabinet have had their knuckles wrapped over their hasty and non-constitutional decision to disband the RCCF. A scrutiny exercise is being conducted into this apparent abuse of process, and into the aims and objectives of those who started this action.

BUNKUM!
As for Sean Lawson's Report to RBC Cabinet Rugby in Plume say how will handing over control to Cemex improve things? And if the RCCF has been ineffectual it is because:
* The so-called exchange of information is incomplete, stilted, censored, often misleading, and has to be dragged out, like pulling teeth.
* Neither the EA nor Cemex (nor hapless RBC) are capable of answering a basic straight question with a straight answer.
* Their objective appears to get away with telling us as little as possible.
* They do not tell us about incidents at the works, malfunctions,emission limit exceedences, and vital Public Register information is never presented.
Forum members have to dig it out.
* They hide data for months and even years.
* The Agency takes months and years to investigate pollution incidents and in the meantime tells the RCCF they may not discuss them.
* The consultations appear targeted at holiday periods, presumably in the hope the public eye is "off the ball!" and the RCCF numbers are down.
* The "consultations" fit neatly in between the four annual RCCF meetings, the dates of which are planned over year in advance, so that in effect the Forum as a body never ever discusses the variations and applications.
* The RCCF was never said to be only a "short-term measure".
* The RCCF declined the offer of reverting to the previous model where RMC would not permit the public, controlled the agenda, the venue, and minutes.
* The RCCF suggested Cemex should fund the RCCF as it is now - in line with the Polluter Should Pay principal - in an open and publicly accessible venue.
* The RCCF asked RBC how much the Community, (only trying to protect itself), has had to pay to subsidise Cemex, and its ever ongoing new applications for variations, planning permissions, changes to equipment, storage, waste raw materials, waste "fuels", increased emission limits. extra HGVs etc? How do these compare with the industry hand-outs?

SET UP NEW COMMITTEE TO FOOL PUBLIC

The track record of the Rugby Cement, the Environment Agency and RBC shows that they resort to setting up a new committee when they are discretely trying to slip in something unpalatable.

LIAISON GROUP 1999 QUITE UNAWARE and UNINFORMED
They had a Rugby Cement Liaison Group controlled by the works, and in June 1999 they tried to get away without following the LAWFUL PROCESS, and to evade the IPC Consultation for the new plant. So they formed a new committee involving many uninformed Councillors. Karen Stone, (Sean Lawson's predecessor), was then Director of Environmental Health, along with a Mr Cudlip who was in declining health. Dianne Colley was the Chief Executive and is now living comfortably on a pension after taking early retirement on ill-health grounds when it had all become too much for her! And for us!! Karen Stone was involved in secret meetings with the Agency about why this IPC application is "different", and "special", and why it is not following the "standard procedure."
FAILINGS AT IPC IN JUNE 1999
* IPC was "mentioned" once in passing at an early 1999 Liaison meeting, but the RBC and EA officers did not bring the consultation to the attention of the members, and Councillors. * They all now refuse to answer questions about why this deceit took place... and who decided they should do it.
* The Agency refused to provide copies of the IPC application being "duly made", and refused to give any copies of the "fees" that should have been paid for the IPC application.
* Neither RMC nor the Agency have any copy of the essential IPC advertisement, and the Agency admits to having no responses from the public because, as we now know, the public and the "gullible" Liaison Group had been bypassed completely, and kept in ignorance.
* RBC finally admitted that some officer/s at the Council had decided to completely ignore the IPC application they had received in June 1999 for the one month consultation. They have no records, no minutes, and no memory of who made that decision nor by what procedure this decision to "do nothing" had been arrived at.
* Whoever decided to act in this way wilfully committed the Rugby residents to many more years of unnecessary excess pollution, and deliberately damaged the environment, and air quality for Rugby people. What motivated them to get a lesser protection and a much lower standard than should have been enforced at that time?
* RBC and the Agency bypassed the lawful process. The Agency claims that Rugby Cement was responsible for the failure to advertise the mandatory consultation, for the IPC application which was completed on 16 June 1999. But surely this demonstrates the Agency's failure to regulate?

RUGBY CEMENT COMMUNITY FORUM OCTOBER 2002
The Liaison Group bumbled along, controlled, ineffective, secretive, minutes unavailable, until the time the public were in revolt as they had been told there was a "tyre burning application". Straight after its construction the cement plant was suddenly to become a co-incinerator. The growing public awareness was that they had been duped by: Warwickshire County Council planning office; by Rugby Borough Council planning and environmental health; by the Environment Agency's failings; and by Rugby Cement.

Even the Liaison group was not told there was an IPPC application - and were given copies of a tyre burning summary, and colour sheets about the joys of alternative fuels. The full IPPC application was deemed duly made on 31 August 2001, but the public were not informed. The "Tyre Burning meetings" were being held and for a year the Agency, unbeknown to the Liaison Group and the public, was collecting extra information from RMC, in correspondence dated 21 December 2001; 1 March 2002; 5 March 2002; 28 March; 3 May; 31 May and finally 5 June when the Agency advised RMC to revise the whole site plan for the application. So you see the level of ignorance even included not knowing exactly what the site included, and what the public and Council were actually supposed to be being consulted on.

The June 2002 Liaison Group meeting was cancelled without warning, and a new committee was set up seven months later in October 2002. Initially this was run by a Public Relations Company, Green Issues, hired by RMC. These carried out the first two meetings "in order to get the Critical Success Factors through" before new members understood the significance of them. Only the few hand-selected councilors were permitted to vote, and the voluntary sector community group members were treated as second class citizens. The January and April 2003 RCCF meetings saw the Agency evade all questions until after the IPPC Decision had been made - August 2003.

OTHER NEWS - FILTER BOOST
"Rugby Cement plant's new £6.5 million bag filter is performing well beyond expectations by achieving 80% reduction in dust emissions, despite having operated well inside the dust emission level allowed by its Environment Agency Permit." "The bag filter is replacing the kiln ESP, which collects dust, mainly chalk, to recycle back into the process". One wonders to which permit they are referring? Meanwhile the gases from the clinker cooler ESP and bypass ESP emit from the main stack, without passing through the bag filter.

A LITTLE SYMPATHY IS CALLED FOR
Cemex confirm that "at present adequate supplies of material of a consistent quality are limited in the UK, due to the slow progress in the development of mechanical biological treatment plants to process waste and meet the industry's rigorous specifications for a quality fuel, and Cemex is already HAVING to import waste (Climafuel) from Holland for burning at South Ferriby and possibly Barrington." Spare a thought for them "having" to import household waste!

SURVEY OF RESIDENTS IN THE VICINITY OF CEMEX PLANTS
The newsletter contained a Liaison Group Questionnaire for residents to complete. "It is important to us to be aware of your views"....fill in and post, or download from http://www.cemex.co.uk/su/su_co.html

Sunday, August 19, 2007

LOST - ONE CEMENT PLANT.

£50 REWARD.

(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?

Thursday, August 02, 2007

Cat out of the bag.


IS THIS FRAUD?
Cemex case for tyre burning NOT PROVEN! Of course while the Jury was out both Cemex and the Agency refused to give the public any emissions data.

Now why could that possibly be?

Because the Agency Emissions Report of 4th April 2006 now at last finally revealed, to a very suspicious public, actually shows what we said all along - there is no proof that tyre burning improves emissions. In fact there is more proof to the contrary! It makes some emissions worse!

ALcontrol Laboratories were contracted, number 11812, to take the periodic samples of coal and tyre burning emissions for the Agency.
These were supposed to be the proof of the tyre trials much heralded "environmental improvement"!

In fact coal burning seems cleaner.

COAL BURNING (BASELINE)
Nitrogen dioxide 841and 472Mg/m3

TYRE BURNING TRIAL
Nitrogen dioxide 459 and 540mg/m3

COAL - particulate 12.6; 18.8; 18.1; 16.5 mg/m3
TYRES - particulate 30.0; 43.4; 26.0; 30.0 mg/m3.

COAL - TOC as carbon 5.0; and 2.7;
TYRES - TOC as carbon 13.5 and 13.1;

COAL - TOC as toluene 5.48 and 2.9;
TYRES - TOC as toluene 14.8 and 14.4;

COAL - benzene 32.1; 0.1; 157; 43;
TYRES - benzene 88.2; 220; 110 ; 56;

In particular they claimed that the nitrogen dioxide was reduced by 25%. A funny calculator they used? Now they use the "claimed success" of the 2005 tyre trials to increase by 100% the burn rate, to 6 tonnes an hour, with the possibility of two further increments. And also to burn household and commercial waste - possibly to be
sourced from Holland as their waste is of a higher quality - suitable for getting good "trial" results.

Cemex' letter to the Agency 28 June 2007 says that they still cannot meet the Improvement Condition to reduce NOX from 800 to 500 mg/m3 which was required in the original Permit - by August 2005.
They ask for another extension to August 2008. They grumble about the low allocation of CO2 in Phase 2 of the EUETS, and cite that as a reason to burn increasing amounts of biomass. They claim the monthly NOX without tyres averaged 779mg/m3, with tyres April-June 2007 averaged 611mg/m3 - a 21.6% reduction.
But their own monthly emissions reports appear not to concur with this claim. "We anticipate a further reduction in oxides of nitrogen, although it cannot be guaranteed to be on a scale as seen previously."

PUBLIC GET BLAME FOR SHOWING INTEREST IN ENVIRONMENT

"Due to insufficient supply of tyres 10 tonnes an hour could not be reached. It was envisaged at that time that perhaps 6 tonnes an hour would be achieved, and authorisation would be requested at that level. As it turns out, due to high levels of public interest, delays in permitting, and delays in undertaking the trial, only 3 tonnes an hour was achieved within the time constraints facing Cemex due to the Waste Incinerator Directive compliance date of December 2005. This issue was never foreseen in the original application due to the early date of that application."

RUBBISH!
It was only too well foreseen, and widely discussed at meetings, and the Primary Care Trust, RBC and consultees requested that Bag Filters be fitted as soon as possible to meet the criteria - ahead of their being "forced to fit them". And to reduce particulate emissions by hundreds of tonnes.
But Rugby Cement and the Agency argued strongly that bag filters would not work on this plant, would make emissions even worse, and that the ESPs were BAT (Best Available Technique) - that is until they were forced to meet the WID legislation, and to fit Bag Filters!

INTENTION TO BURN WASTE 100% OF TIME "subject to restrictions imposed by the WID which dictates periods when waste derived alternative fuels may not be used. Standby continuous emissions monitors will now be fitted to allow immediate switch over in the event of failure of any of the primary units.

This will minimise potential periods when waste derived fuels cannot be used and the feed has to be shut down, to periods covering start-up, shut-down, periods of feed less than 200 tonnes an hour, periods of malfunction and if emission limits are exceeded."

In short all the time when no emission limits apply! And what will happen to the nitrogen dioxide limits then? Nothing as they will not apply!