Further memorandum submitted by the Environment
Agency (AQ 30)
SUBMISSION MADE
BY ALLAN
G NORMAN TO
ENVIRONMENTAL AUDIT
COMMITTEE:
"The recent example of the granting of a
licence to Prenergy for a large woodchip power station in the
town shows quite clearly that the Environment Agency sees one
of its primary responsibilities under the Environment Protection
Act 1995 as "to make a contribution towards attaining
the objectives of achieving sustainable development" as determined
by ministers, even when the ministers are obviously wrong. It
has accepted dubious computer modelling data and set
spurious limitations on the pollution arising from the new plant
that it knows cannot be achieved by the company in the
knowledge that the source of the PM10s or PAHs cannot be proven.
Therefore, no action will be taken against the company
even if the pollution in the town exceeds even more the guidelines
set by Europe and the UK government. There is a complete lack
of trust in the Environment Agency."
[Emphasis added by Environment Agency]
The Environment Agency's response:
PERMITTING OF
THE INSTALLATION
We issued the environmental permit to Prenergy
Power Ltd on 29 September 2009, but we would not expect the
installation to be operational until 2013. The decision to grant
a permit followed a lengthy evaluation process and discussions
with local people. We also sought the advice of the Local Health
Board and we set strict emission limits to protect human health.
The strict emission limits are important given the proximity
of the Air Quality Management Area for particulates in Port Talbot.
We are confident that the modelling data on
which we based our decision to issue the Prenergy permit gives
realistic predictions of the impact of the site. Extensive work
was undertaken by our Air Quality Modelling and Assessment Unit
to ensure that the computer modelling data was sufficiently reliable
to allow us to base our decision on it, taking into consideration
conservative error margins.
The site will have only one main point source
and negligible fugitive emissions of PM10 particulates.
All dusty materials on the site will be handled within totally
enclosed systems. A second stack on site will only be used during
plant start-up and there would only be emissions from it for the
initial 12 hours or so of operation.
The impact of additional road transport as a
result of the new development has been modelled separately and
was included in our decision making. Additional road transport
will be kept to a minimum as the primary fuel to the power station
will be delivered by ship. All other sources contributing to
PM10 particulates in the Port Talbot area are accounted for
within the measured ambient background which is included within
the modelling work.
Further information on the modelling data used,
and responses to previous concerns raised by individuals on this
issue can be viewed in the decision document which accompanies
the permit.
Biomass plants such as Prenergy's Port Talbot
power station will play an important role in helping combat climate
change if the wood they burn is sourced sustainably. As part
of its environmental permit, Prenergy must prove to the Environment
Agency that the wood it burns comes from sustainable sources.
This new power station will make an important contribution be
a big step towards meeting the Government's climate change and
renewable energy targets.
Our policy, in line with Government guidance,
allows for the permitting of new sites in areas of failing air
quality, providing the additional impact of new sites is negligible.
Any other approach would prevent any development, however small,
in some areas.
The emission limits in the permit ensure that
the contribution of
Prenergy to the ambient air quality will be negligible.
Evidence from other industries using bag filters
and information on PAH emissions from contaminated wood-burning
facilities (which would produce higher levels of polycyclic aromatic
hydrocarbons (PAHs) than the clean wood to be used at this site)
gives us confidence that Prenergy will be able to meet the limits
set for particulates and PAHs. All other limits set are routinely
met by combustion units that utilise similar abatement technology
to that to be used at the Prenergy plant.
The Prenergy power station will have one main
point source emission to air. As stated, there is a second point
associated with plant start-up. The enclosed nature of the operation
and controls on the storage, handling and movement of wood and
ash should ensure that fugitive emissions are minimised. The permit
requires continuous monitoring of PM10s in the emissions to air.
This will provide us with the relevant information on the PM10 releases
from the site.
REGULATION OF
THE INSTALLATION
Our regulatory effort is focussed on ensuring
that permitted sites operate within their environmental permits.
Where a permit holder does breach the conditions of their permit,
or other relevant environmental legislation, then the Environment
Agency will take appropriate enforcement action in line with our
Enforcement and Prosecution Policy.
Since the permit was issued, we have met with
the operator and they have confirmed to us, as well as stating
publicly in their own press release, that they are confident of
being able to operate within the conditions and limits set in
their permit.
OUR COMMITMENT
TO IMPROVING
AIR QUALITY
IN THE
LOCALITY
We are currently working closely with Neath
Port Talbot County Borough Council, the Welsh Assembly Government
and local industry to improve the air quality in Port Talbot.
This work has already included an extensive review of all the
environmental permits at the nearby integrated steelworks site.
We have spent a great deal of time listening
to the views of local people on the Prenergy Plant and the final
decision to grant a permit followed extensive public consultation.
The consultation included ongoing engagement with a local pressure
group throughout the determination process, a public drop-in surgery
in July 2009 to answer questions about the plant and consultation
under the Public Participation Directive to which local people
were invited to submit their views.
February 2010
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