31st May 2004

E-Mail from Councillor Arnold Wooley, CANK member and local resident, to The Flintshire Evening Leader dated 31st May 2004
 
 

Sir,

Perhaps you would permit either CANK, or myself, as a local councilor opposed to Kiln 4, the same amount of column inches as you have allowed Tony Allen on page 5 of today’s (31/05/04) Evening Leader.
 

   Either source might be able to point you in the direction of genuine facts, such as Castle’s latest documentation submitted to the Environment Agency this month, May 2004, in which the company seek to :-
 
 

a)       Remove all emissions limits for Carbon Monoxide

b)       Move the emissions limit upward for Total Organic Compounds, which are comprised of Volatile Organic Compounds, which, in general are not good news for people or the environment

c)       Delay the introduction of Tyre Chips and Profuel (That item is causing too much chlorine problems elsewhere)  and to start the kiln using coal and cemfuel only.  That limits the provision of chlorine
          for alkali reduction purposes to one source only.  That could be interesting.

d)       Vary the “balance” of alternative fuels according to cost implications, not environment betterment reasons.

e)       Indicate an intention to move to Agricultural Waste Derived Fuels, as requested at Ribblesdale on October 2003.

f)         Supports the potential use of meat and bone meal and tallow as alternative fuels.

g)       Worry about the possible increase of Nitrous Oxides (NOx) from the Kiln 4, in that short term rises of the order of 40% can occur and record that “If the performance of the kiln does not meet the
          expected BAT level of 500 mg/Nm3 when operating with alternative fuels then secondary measures such as flame cooling and SNCR installations will be required..”     It also has the notation that
          “During the commissioning of Kiln 4 there are likely to be variations in the emissions of NOx, up to 1500 mg/Nm3 for up to 30 minutes per time.  A short term limit of up to 3000 Mg/Nm3 is sought.

h)       Change an intended gas-oil firing system to a Kerosene based system due to lower costs of Kerosene.
 

Those are facts on paper, not corporate propaganda.
 

How about giving a balanced viewpoint for your readers to learn from?

Arnold Woolley

I am sure you will be concerned about proposals from the UK regulator, the Environment Agency, which could have potentially significant consequences relating to the health of local residents.

In summary, the Environment Agency is proposing that a much greater range of hazardous wastes should be allowed to be blended and burnt as fuels at cement kilns, such as that located at Padeswood.

The kiln, like others around the country, was not designed to burn these wastes and such a use was never envisaged when planning permission was originally granted. In effect, the cement kiln will function as a co-incinerator, but be allowed to operate at lower specifications and standards than purpose-built incinerators.

Specifically, the Environment Agency's proposal will result in:
          Environmental standards being lowered, not increased;
          Cement kilns not being required to undergo the thorough environmental impact assessments, or seek planning permissions for change of use, as is required for purpose-built High-Temperature
          incinerators.
          Local people and their elected representatives having NO SAY about what hazardous wastes are transported to their local cement plants or incinerated at the kiln.

The Environment Agency's stated purpose behind the proposals is to allow a greater range of hazardous wastes to be blended and reclassified as fuel. Whilst Cleanaway acknowledges that some environmental benefits can be achieved by the reclassification of low-risk wastes as fuel, those wastes should be proved as safe to burn, have high fuel values and low levels of contaminants.

It is not known with any degree of certainty whether it is safe to burn the current mix of hazardous wastes in kilns, let alone the broader range of hazardous wastes the Environment Agency is proposing, including:

          1)   Contaminated oils, by-products and highly hazardous chemicals, some of which contain heavy metals such as arsenic, lead, mercury, cadmium, nickel, chrome, zinc, tin, and chlorine which, together
                 with organic carbon, produce dioxins;
          2)   Animal products (including talloew, meat and bone meal);
          3)   Sewage sludge pellets, explosives, controlled drugs, slurries;
          4) Gases such as Halon and CFCs
          5) Some wastes may contain high levels of sulphur, leading to increased SO2 emissions which are one of the major causes of acid rain.

These are wastes that need specialised treatment, handling and controls. There are known health risks from the emission of pollutants that are generated when these wastes are burnt in inapproriate circumstances and the level of dioxins and particulates has been shown to increase when such wastes are burned.

There is no need to take the risk of lowering environmental standards by allowing the cement kilns to burn more hazardous wastes, as the UK already has a professional, highly regulated, incineration industry in which these wastes are handled to cmply with the highest environmental standards.

The Environment Agency is a strong advocate of 'the precautionary principle', which states  the UK should not go ahead with a new technology, or persist with an old one, unless there is ample evidence that ti is safe.

there is no justification in making an exception to this principle for cement kilns which were not designed to handle or process these hazardous wastes.

The EA should, therefore:

          Maintain current controls on the burning of hazardous wastes;
          Make full use of non-hazardous wastes available as potential fuels before deregulating more hazardous wastes that already have a highly controlled disposal solution;
          Ensure local people and their representatives have a proper democratic influence on issues which affect their environment, health, and community

The Environment Agency consultation period ends on 18th June. If you are concerned about the potential adverse impact of these proposals on the environment and health of local communities, then please write before that date to the Environment Agency, outlining your concerns.

This letter, was circulated to Local County Councillors and copied to CANK
The original EA Consultative Document and CANKS response, issued before the 18th June deadline.

From Phil via E-Mail:
i would like to thank castle cement for it's courageous decision to expand its plant.
myself being in the construction industry am grateful for the employment being generated locally,allowing myself to work locally instead of travelling a hundred miles or so to put food on the table.
i thank you castle cement
phil
p.s. i live in chirk and put up with kronospan on a daily basis
i.e. swing and roundabouts

CANK Response:

 Phil,

Thanks for this point of view.

But, why on earth would you want to risk inflicting what you already endure in Chirk onto another community?!

Jonathan
Webmaster
CANK

From
Eric Black.
Rhyl South West Central Residents Association.

I would like to register my protest concerning this incinerator which as you say is a blot on the landscape. I have known this area all my life and it is the most horrendous monstrosity i have ever seen, It is huge and therefore visible for many miles in an otherwise unspoilt valley.
 
Even if that is not bad enough this will have emissions when in use and cannot be anything but dangerous with the most populated region of North Wales in its potential radius.
 
Is there no way that it can be stopped. Or is it just as difficult as it is to stop communications masts?
 
As Secretary of a Residents Association In Rhyl we will support any campaign to prevent further pollution.
 

Dear CANK
We are not able to come to your meeting. However as Heidelberg Cement own and operate a solvent re-processing facility (SRM ltd) in Rye that produces Cemfuel and ProFuel we are always interested to be kept informed of your concerns.

We are also interested to know about the latest monitoring technologies both for emmissions to air and water and to ensure that these are being used by the Environment Agency.

Yours sincerely

Christopher Strangeways
 

Rother Environmental Group
PO BOX 100, Rye, East Sussex TN31 7DP
Tel: 01797 280282  Fax: 01797 280021
www.rotherenvironmental.org.uk