Memorandum by Castle Cement (EA 85)
Castle Cement welcomes the opportunity to submit
a short memorandum of evidence to the Environment Sub-committee's
inquiry into the Environment Agency (the Agency). In their oral
evidence to the Committee, Friends of the Earth (FoE) made reference
to our Ribblesdale Cement Works. We submit the attached annex
of background information, which we believe will allow the Committee
to place their evidence in context.
FoE suggests that the Agency is not being "tough
on the ground". This is not our experience. Indeed, quite
the contrary, Ribblesdale Works is one of the most tightly regulated
IPC processes in the UK. The norm for the regulation of IPC sites
is approximately one inspector per 20 sites. Ribblesdale Works
has on average three inspectors supervising its operations. This
level of regulation is not warranted by its environmental performance.
FoE's assertion that Ribblesdale is ". . . the only case
where the Agency should close down a plant because its environmental
impact is so great . . . ". Clearly, where air quality is
described as very good (the highest quality band of measurement
in the UK) for 99.5 per cent, as it is at Ribblesdale, this is
simply not correct.
However, we do recognise that the Agency has
a responsibility to respond to public concerns about, for instance,
health. If a lack of confidence exists, it may be attributed to
the failure of the Agency to comply with their statutory duty
to educate the public. The Agency needs to have the confidence
to explain their actions and decisions not only in accordance
with the principles of sound science, but to demystify it and
relate to people's every day life. There will always be stakeholders
who are intent on maintaining their position even when the majority
recognises that the facts tell them something different.
Castle recognises environmental legislation
is essential and desirable for business and private citizens alike.
However, we believe that the Agency's standing derives as much
from its educative role as it does from its regulatory one. Too
often we feel that it has shirked the former in relation to the
latter. The two are symbiotically linked. If the Agency continues
as at present, it will have the confidence of neither business
nor the public.
Castle Cement strongly believes in keeping the
community informed of the operation of its Works and Ribblesdale
is no different. We produce a community newspaper entitled "Open
Door". We have operated liaison committees for many years
on which district and parish councillors, council officers and
Agency inspectors sit. We believe that Castle Cement is leading
the field in public consultation and is always striving to improve
performance in this area. However, we conclude that the Agency
needs to improve its own performance in this area otherwise the
concerns of the public will not be adequately addressed.
RWF Boarder
Energy Manager
January 2000
INTRODUCTION
Following the oral evidence given by FeO at
an earlier session of the Select Committee enquiry in which they
discussed our Ribblesdale works we felt the committee would benefit
from a short paper stating the facts as we see them.
The following notes we hope will allow the committee
to consider the EA performance with respect to the Ribblesdale
works within a full context.
HISTORICAL NOTES
Castle and its predecessor companies have manufactured
cement on the site outside the town of Clitheroe, since 1935.
Previously lime had been manufactured from the same limestone
outcrop for several hundred years. The Ribblesdale works developed
to its current capacity of 1.4 million tonnes per year by 1981.
In this configuration the works uses about 200,000 tonnes of coal
or coal equivalent annually.
First the Alkali Inspectorate, then HMIP and,
more recently, the Environment Agency regulated the environmental
performance of the works.
The issue of plume grounding has been present
for some years generating some four to six complaints per year
during the period 1981 until 1994. Complaints rose to the current
level after the independent, though contemporaneous, issues of
a quarry planning application and the commencement of a campaign
against the use of the company's liquid waste derived fuel, Cemfuel.
The multinational mining company, RTZ, formed
the company Castle Cement in 1982 by merging three separate cement
companies. Castle is now a part of the German cement company Heidelberger
Zement AG, the third largest cement producer in the world.
All Castle Cement production units are registered
under the ISO14001 environment management system.
CEMFUEL©
In 1991 Castle applied to use Cemfuel as a partial
replacement fuel for its kilns at Ribblesdale. Planning permission
for the fuel storage system was granted. A specification for the
fuel was formulated and agreed with HMIP, as were a trial programme
and an evaluation scheme. The County Council Waste Officers were
consulted and the status of Cemfuel was agreed. The County Council
and the works liaison committee, which includes other local politicians
and Council Officers, were informed of the project before trials
commenced in 1992.
Castle made arrangements for Cemfuel to be manufactured
from spent solvents and residues from solvent recycling and detailed
contracts were signed.
The necessary petroleum licences and fire certificates
were obtained. AEA Technology was commissioned to carry out a
COSHH assessment of Cemfuel, as well as a BPEO assessment and
HAZOP studies.
In accordance with the requirements of the Environmental
Protection Act regulations, Castle applied for authorisation of
the Ribblesdale Works. There was public consultation on this application
for authorisation, which included Cemfuel. Following the submission
of the Castle monitoring data HMIP considered the existing process
to be BATNEEC and BPEO.
The public response to the introduction of Cemfuel
was one of indifference, a situation which was maintained for
two years, until a handful of vigorous and vocal campaigners started
publicising ill-founded horror stories based on the constituents
of Cemfuel. Because its origins were from waste arisings, the
campaigners claimed that it would increase emissions; an untrue
accusation that ignores completely the advantages of burning spent
solvents in the very high temperature of a cement kiln flame (2,000°C).
Castle has responded to community comment and
concern by publicising its open door policy which has included
works visits, open days, regular news letters and other publications,
public meetings, as well as complete co-operation with regulators,
public officials and politicians.
PLUME DISPERSION
The works at Ribblesdale suffers from a phenomenon
known as plume grounding, where poor plume dispersion causes parts
of the plume from the chimney to be drawn down to ground level
from time to time. Due to certain constituents within the plume,
an odour can under particular circumstances be detected at ground
level.
Olfactory testing, LIDAR and DIAL testing showed
that the plume odour is related to SO2, which originates from
the pyrites in the raw materials. Similarly it is ammonia, derived
from the raw materials, which causes the plume appearance to be
persistent.
ACTIONS TAKEN
TO IMPROVE
PLUME DISPERSION
Castle Cement commenced a programme of plume
dispersion improvements in 1987. When, after some five years of
operation of kiln 7, the relatively low number of complaints about
its plume dispersion concerned the Alkali Inspector and local
management. Salford University undertook studies including wind
tunnel tests to try to improve the dispersion and concluded that
increasing the efflux velocity by fitting a cone to the chimney
would improve the situation. A cone was fitted.
When complaints increased to the current level
in 1994-95, the situation was further improved by extending the
chimney by some 15 metres, which was its structural limit.
A community panel, including some of the campaigners,
was set up to resolve the plume grounding problems. Analysis of
complaints and other investigations demonstrated that kiln 7,
the dry kiln, continued to cause most of the plume grounding incidents.
The studies concluded that the fitting of a gas cleaning system,
also known as a gas scrubber, to kiln 7 and the extension and
fitting of a cone to chimney serving kilns 5 and 6 would yield
significant improvement. The results of the studies were submitted
to the Environment Agency in August 1996. The Agency commissioned
a report by independent consultants. The consultants concluded
that the Company's proposals were the most effective way of improving
plume dispersion at Ribblesdale Works.
In consequence, a gas scrubber, with a reheat
facility, has been fitted on kiln 7 to reduce SO2, ammonia and
dust; as well as produce a plume without detectable odour or persistence.
Kiln 7 now meets the lowest emission limits of any cement kiln
in Europe. The scrubber cost about £5 million and costs a
further £750,000 per year to run. The cone on the chimney
serving kilns 5 and 6 has improved the gas efflux velocity from
the stack and therefore has improved the dispersion.
In all, some £5.75 million has been invested
by the Company to minimise this problem. These decisions were
made even though the Environment Agency said, prior to the installation
of the scrubber, "for greater than 99.9 per cent of the time
the measured air quality . . . can be described as "very
good" according to the statement on banding of air quality
from COMEAP".
FURTHER INVESTMENT
In accordance with its long-term improvement
strategy, Castle is seeking planning permission for a state-of-the-art
cement kiln at its North Wales plant and, on completion of that
project, intends to mothball the two wet kilns at Ribblesdale.
Castle will then, in 2002, have world class cement production
facilities at all its sites; certainly the most efficient and
with lowest emissions per unit of production in the UK. Ribblesdale
will have an environmental performance comparable with the best
cement manufacturers in the world.
THE ENVIRONMENT
AGENCY
Under the HMIP regime, Cemfuel—the first
alternative fuel in the UK cement industry—was permitted
after a testing programme that was the forerunner of the current
"Substitute Fuels Protocol". The specification agreed
by HMIP is very similar to the specification currently permitted.
Castle is of the view that, at that time, HMIP made its decisions
on the basis of sound science and that these decisions have stood
the test of time and furthermore have been replicated at other
UK cement works. This is a policy that Castle applauds.
This policy continued after the formation of
the Environment Agency and when Castle applied for its IPC authorisation,
it was granted on the basis of the detailed analysis of the environmental
monitoring record when the kilns using Cemfuel were proven to
be operating under BATNEEC and BPEO.
However the campaigners started using scaremongering
tactics about public health and the Environment Agency's response
was disappointing. They stated that health was not a matter for
them but a matter for the public health authorities; a statement
which was seized upon by the campaigners.
We believe that the Environment Agency is concerned
about public health: It sets limits that have as a basis the National
Air Quality Strategy which are air quality limits, set after taking
a very prudent view of the potential health effects of the pollutants
by bodies such as the Expert Panel on Air Quality Standards. Castle
believes that the Environment Agency has a duty to educate the
public on the principles of sound science and to correct any misconceptions
when they occur. Furthermore, we believe that the Environment
Agency should take the lead responsibility for health implications
for the public, as this will avoid misunderstandings in the community
around IPC processes. When the statutory consultees advise that
there may be a health risk posed by an IPC process, the Environment
Agency should apply risk based limits, which would thereby enable
an explanation that the limits imposed are such that there is
insignificant risk to human health.
Following the Environment Select Committee investigation
into "SLF" at which the Environment Agency did not perform
well, the latter has taken a more political stance. The Committee
visited Clitheroe and the report gave specific mention of Ribblesdale
Works; the Environment Agency responded by promising stronger
and more consistent regulation.
The level of regulation, supervision and monitoring
increased dramatically at Ribblesdale. A £500,000 monitoring
programme was organised which found the air quality in the surrounding
of the works was generally excellent and also found that emissions
from other industrial plants in the area contribute to the local
situation. Despite an extraordinary amount of ongoing monitoring
and test work, the Environment Agency has consistently concluded
that the air quality is generally very good and nothing within
the Works emissions can be perceived at ground level to have any
effects on health.
Ribblesdale has become the most highly regulated
plant in the country; authorisation changes, enforcement notices
and prosecutions were initiated at every opportunity, while at
the same time the Company experienced delays in dealing with its
various applications for changes in authorisations; including,
incidentally, the authorisation to fit the scrubber.
Most Environment Agency Inspectors each supervise
the operations of about 20 IPC regulated plants. Ribblesdale has
on average three Inspectors supervising its operations.
The campaigners have continued to keep up the
pressure and have taken to copying all their propaganda to politicians
at all levels. This has even prompted intervention by the Minister.
Under these political pressures the Environment Agency is desperate
to demonstrate they are being tough with Castle's Ribblesdale
plant and have prosecuted at every opportunity; this has resulted
in six prosecutions, five of which have been heard.
There can be no doubt that if Ribblesdale emissions
were affecting health, constituting a serious nuisance or breaking
the law, the Environment Agency would have acted. The Friends
of the Earth in their evidence required the works to be closed
down and blamed the Environment Agency for not doing so. They
cite evidence from a report that has not been published and has
not been submitted to the Committee. There can be no credence
given to this evidence.
The Environment Agency needs to take an honest
view of the situation. It needs to demonstrate that it has listened
to the campaigners as well as politicians, has taken decisions
based on sound science and that its actions reflect that situation.
The big issue to be dealt with by the EA is
the unreasonable campaigners who will not show respect for the
exhaustive work done on their behalf by the Environment Agency.
The lack of public confidence in the Environment
Agency will not be solved by trying to "catch out" organisations
such as Castle on legal technicalities.
A full and honest appraisal of all the evidence
should be made and then any decision should be explained with
confidence, repeatedly if necessary, whichever way it falls.
CONCLUSIONS
There is no basis for the Friends of the Earth
requirement to close down Ribblesdale Works.
Planned investments will by 2002 make Ribblesdale
Works comparable with the best cement manufacturers in the world.
The Environment Agency is regulating the Ribblesdale
plant with a very firm hand.
The Environment Agency needs to take responsibility
publicly for health issues.
The Environment Agency should listen to campaigners,
but take decisions based on sound science.
The Environment Agency needs to have the confidence
to explain its actions even when they do not meet the expectations
of the campaigners.
January 2000
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