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Memorandum submitted by Mr Peter Wilson (AQ13) I live close
to the Corus Steel works, which has been implicated as being the main source of
PM10 pollution in Two reports, which were intended to identify the main sources of the PM10 pollution from the Port Talbot Steelworks, have recently been published.
I) Port Talbot Steelworks PM10 permit review by the Environment Agency Wales (Jan 2009). II) An Independent Review of Monitoring Measures Undertaken in Neath Port Talbot in Respect of PM10 by Dr Enda Hayes by University of the West of England, Bristol (Oct 2009).
Both of the reports referenced have been written at the request of the Welsh Assembly Government under the direction of the Radioactivity and Pollution Prevention Branch, which in turn is under the auspices of the Department for Environment, Sustainability and Housing.
In my view the wider political aspirations of the WAG are seriously hindering any proper investigation into the main sources of PM10 pollution from the steelworks, and also the relocation of the AURN air quality monitoring equipment. Consequently public health is being compromised. My submission (attached) is intended to make the Environment Audit Committee fully aware of issues that are not being openly discussed by the WAG, the EAW or Defra.
Summary 1. It has been claimed by both the Welsh
Assembly Government (WAG) and Defra that, after correction for natural
phenomena such as sea salt,
2. An independent review by Dr Hayes of West of
England University for the WAG adjudicated that LAQM guidance procedure had not
been used to relocate the AURN TEOM device in July 2007. The correct
methodology for industrial locations such as
3. The short-term objective for PM10 was only just achieved in 2008 despite the fact that the AURN TEOM was located 700 metres away from the modelled point of maximum impact. Additionally one of the two blast furnaces in the steelworks was mothballed from October 2008 until August 2009, so fewer exceedences than usual have occurred over the period. It will be a while before normal steel production returns, so it is too soon to claim any long-term improvement in air quality.
4. Open discussion about certain facilities within the steelworks such as the sinter plant and blast furnaces is being systematically suppressed and excluded from official reports that are meant to determine the main sources of PM10 pollution in the steelworks. In their place unidentified sources are being blamed. This strategy is being used to protect the fragile position of Corus. A recent review of the steelworks by the EAW did highlight the fact that the sinter plant's stack is zero percent compliant with BAT and that parts of the blast furnaces are only 35% compliant. Corus has already submitted a report that argues the facilities already use indicative BAT thereby delaying any further improvements indefinitely. In my view this state of denial means that pollution reduction measures only happen at the pace that Corus can afford them, which is far too slow.
5. Three wood-burning power station projects
are currently being considered by the UK Government and Welsh Assembly for
Relocation of the AURN TEOM
6. In July 2007 the redevelopment of the
7. In October 2008, I made a serious complaint to the WAG that improper methodology had been used to choose the new location of the AURN monitoring equipment (TEOM). Specifically that: "The positioning of the TEOM has not followed the principles laid down in the LAQM Technical Guidance. In November 2006 the Welsh Assembly re-classified the Margam-Taibach AQMA to 'Industrial Background'. Prior to this the area was classified as 'Urban Background'." The LAQM Technical Guidance requires that "for Industrial Sites, where specific sources are being targeted (in this case PM10), monitoring should be carried out at the point of maximum impact as determined by dispersion modelling. AEA Technology have compared two shortlisted sites in their report to the WAG but there is no evidence that dispersion modelling has been used. Dispersion modelling examples (from the Margam Tiabach Action Plan 2003) show that both short-listed sites, the Taibach Fire Station and Dyffryn school, will significantly under-record compared to the point of maximum impact. This was previously determined to be on the boundary of the AQMA to the East of the blast furnaces. The Corus model used 18 separate sources from chimney stacks, blast furnaces, to iron ore stockpiles around the industrial area. These emissions are analysed together with Met weather data to produce predictions for concentrations of pollution".
8. The Environment
Agency appear to have accepted this argument in their permit review report of
the steelworks and have very recently sited one of their own TEOM monitors in a
compound fairly close to the modelled point of maximum impact. The dispersion
modelling study from the Margam-Taibach Action plan 2003 is shown overleaf
and has been copied from the
EAW Steelworks review
report. Although the additional TEOM
from the Agency is welcome for shadow monitoring purposes, it cannot be
considered as a substitute for the AURN TEOM. The AURN TEOM records the
official air quality for 9. Had it not been for the fact that a
10. Other failures to adopt LAQM guidance were highlighted by Dr Hayes in his report, particularly in Recommendation 2 - Generation of an emissions database and undertaking a new dispersion modelling study. In this section Dr Hayes focused on two separate failures by the WAG and Local Authority in the past to adopt guidance. Firstly that dispersion modelling had not been used to relocate the AURN TEOM and secondly that local model verification (or calibration) had not been used to correct modelled studies of pollution so that they more accurately reflected the pollution being measured by the TEOM.
11. An explanation is required from Dr Hayes as to why both these important and fundamental recommendations were edited out of the executive summary version. In fact the Recommendation 2 in the executive summary was completely different from the main report. In short all the failings highlighted in the main report had been removed.
12. Consequently, it would be helpful to know from Dr Hayes what changes to his report were required by the WAG in August 2008 that led to a delay in publishing by several weeks.
13. Dr Hayes was not asked in his review to undertake a new dispersion modelling study, which would have assisted the relocation of the AURN TEOM. Neither have the WAG utilized the existing dispersion modelling study from the Action Plan of 2003. A year has gone by and the AURN TEOM is still monitoring air quality a long distance from the modelled point of maximum impact. Other TEOM monitors in the town have been placed in locations away from known pollution hot spots and are consequently recording few if any exceedences. 14. It is clear that PM10 pollution can be reduced significantly
or made to disappear altogether simply by selective positioning of the air
quality monitors in the AQMA. This is a clear failure to protect the public. It
is sad to remark, that the Pollution Prevention branch of the WAG has proven
itself either incapable or unwilling to investigate this matter properly. Indeed they commissioned a report "A
review of 2007 Automatic PM10 Air Monitoring data in 15. This failure to protect health must be addressed as a matter of urgency. The WAG needs to clarify what its intentions are regarding the AURN position. If the Audit committee cannot follow this up, who then? Who else can compel the WAG to adhere to guidance and the recommendations of an independent review?
16. Despite the fact that the AURN
monitoring equipment has been located 700 metres away from the modelled point
of maximum impact, at least 34 exceedences were recorded in 2008. This is only
one less than the allowed limit of 35.
17. Historical record of PM10
air quality taken from
18. At least 60% of PM10 pollution comes from the steelworks and the steel industry has been in a severe recession for 18 months with production at less than 50% capacity. Until normal levels of steel production resume, no proper judgements can be made about whether there has been a general improvement or not.
Main sources of PM10 19. The WAG and the EAW seem unwilling to implicate the blast furnaces and the sinter plant as main sources of PM10 in their reports. This completely defies the logic of the monitored data. I live adjacent to the steel works and see these facilities operating throughout the day and also at night too. I can personally vouch along with other residents of the town that they are the main sources of fine dust from the steelworks. Photo1 -Corus blast furnaces viewed from hills near Pen-y-Cae Photo 2 - Sinter plant stack and blast furnaces viewed from Bracken Rd Margam Photo 3 - Sinter plant stack viewed from mouth of the
Photo 4 - Sinter plant stack viewed from Mariners Point Photo 5 - Sinter plant stack viewed from Mariners Point Photo 6 - Sinter plant stack viewed from Mariners Point
20. Comments made by Dr Hayes are contradictory. On one hand Dr Hayes states emphatically "that the blast furnace and sinter plant are not likely to be the main contributors" but then later it is concluded that the main sources are likely to be stacks, to the South West of the Taibach Fire Station TEOM, and that theses sources are simultaneously emitting large amounts of Carbon monoxide in conjunction with PM10 and lesser amounts of sulphur dioxide (implicating the blast furnaces and sinter plant stack). 21. In my opinion there appears to be an unwritten rule in reports commissioned by the WAG that whenever PM10 pollution is discussed facilities such as the blast furnaces and the sinter plant are not blamed directly. In their place unidentifiable sources are flagged up as the likely sources of PM10 but these are never located. This inability to discuss the problem is a recipe for inaction. 22. The EAW report " 23. Emissions data submitted to the Action Plan of 2003 indicate that
the sinter plant stack has a PM10 emission rate of 20grams per
second making it the largest of any within the steelworks. The 24. This being the case, it seems illogical for anyone including Dr Hayes to conclude that the sinter plant and blast furnaces are unlikely to be significant contributors of PM10. In any event, dust from these facilities will be re-suspended by site traffic doubling up on the PM10 pollution. 25. Corus have been given 18 months by the EAW to present a BAT appraisal for the sinter plant. I have already read a report written by Corus in which they argue that BAT is already employed; so no doubt the 'Mexican standoff' will continue. This has become a farcical merry-go-round, where each party must be seen to be going through the motions. The loser in all this is the cardiac and respiratory health of residents.
New planning applications, more PM10
26. I have been very critical of the UK Government and Welsh Assembly Government for agreeing to site three biomass power stations in the industrial area adjacent to the Margam Taibach Air Quality management Area. i) 15MW - Locally sourced woodchip (Western Wood Energy/ECO2) ii) 35MW - Waste wood (Western Wood Energy) iii) 350MW - Imported Woodchip (Prenergy)
27. Common sense should have prevailed.
28. There is a general failure by the Environment
Agency to undertaken local verification (or calibration) of the dispersion
models used, which is a requirement of guidance, especially in areas like Port
Talbot that have complex terrain and high model uncertainty. In applications
for new PPC licences, stack emissions are proven safe with dispersion model software
such as ADMS, by Cambridge Environmental Research Consultants (CERC). The
ability of the dispersion model to predict to a required standard is proven by
software validation examples, which can be downloaded from CERC's website. I
highlighted to the EAW that ADMS' ability to model pollution was not consistent
across all the examples listed by CERC, especially those that required the
complex terrain module of the program.
29. In a recent planning application for Prenergy Power Ltd, the EAW allowed for a dispersion model software accuracy of 50% to predict the annual average benchmark and 24hr mean objective level. This is far more optimistic than the 25-30% accuracy achieved in the validations from CERC that used the specialist complex terrain module. Essentially, the software in the CERC study examples was seen to systematically under-predict pollution levels so that they were on average 1/3 to 1/4 of those observed.
30. When the local health board and I both
complained to the EAW about the optimistic accuracy being assumed for
Prenergy's dispersion modelling study, our complaint was misrepresented in the
permit document, so that it could easily be disregarded. This is totally
unacceptable. The modelled results should have been given higher factors of
safety to offset modelling uncertainty and bias for under-prediction. The requirement
for local model verification to LAQM guidance highlighted by Dr Hayes in my
view is fundamental. Until this aspect of guidance is adopted all past, present
and future modelling studies for
31. The EAW knew about the need to undertake the local verification procedure to correct dispersion models but issued a permit to Prenergy regardless without correcting the applicant's modelled emissions. The reason why they did this in my opinion was that the power station filters were already on the theoretical limit of their performance and any further reduction in emission limits would have resulted in the failure of the application.
32. Filtering standards of 6mg/Nm3 have been
specified for Prenergy's stack by the EAW in an attempt to limit PM10
emissions that could cause further exceedences. The emission limit imposed is
three times more stringent than is normally achieved with BAT, (typically
around 20mg/Nm3). The EAW has a poor record of achieving compliance in the
33. The EAW as part of its charter has a legal
responsibility to support ministers and find sites for renewable energy
projects. Herein lies the problem for
34. I hold the view that government plans for biomass
energy production in the
12th December 2009
Abbreviations AMDS - Air Dispersion Modelling Software AQMA - Air Quality Management Area AURN - Automatic Urban & Rural Network (Air Quality Monitoring Network) BAT - Best Available Technique CERC - EAW - Environment Agency ( MW - Mega Watt LAQM - Local Air Quality Management PM10 - Particulate Matter below 10 microns PPC - Pollution Prevention and Control TEOM - Tapered Element Oscillating Microbalance (Air Quality Monitoring Device) WAG - Welsh Assembly Government
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