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 Port Talbot. Following the failure of PM10 air quality objectives in 2007. I responded to the Welsh Assembly Government consultation and later in April 2008 to the Defra consultation that requested a time extension until 2011 to achieve PM10 air quality objectives.

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.




1. It has been claimed by both the Welsh Assembly Government (WAG) and Defra that, after correction for natural phenomena such as sea salt, Port Talbot achieved the NAQS objectives for PM10. The Environment Audit Committee might conclude that the 46 exceedences recorded in 2007 will not be repeated again and that no follow-up action is necessary. This would be a huge mistake for the following reasons.


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 Port Talbot requires the TEOM device to be sited at the point of maximum impact, as determined by dispersion modelling. A modelling study undertaken for the Action Plan of 2003 showed that the Taibach Fire station, where the AURN TEOM is currently sited, is 700 metres from the modelled point of maximum impact. This argument appears to have also been accepted by the Environment Agency Wales in their report Port Talbot Steelworks PM10 Permit Review Jan 2009. The conclusion that must be drawn is that the AURN TEOM has recorded appreciably less PM10 pollution than it would otherwise have done had it been sited at the point of maximum impact. Consequently monitored PM10 exceedences since July 2007 are likely to have been under-recorded. There are serious failings by the local authority and the WAG regulator that need to be urgently addressed.


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 Port Talbot's industrial area adjacent to the Margam-Taibach Air Quality Management Area. Although I recognised that stringent emission limits for PM10 are being imposed the following question has to be asked. Why is the UK Government asking the EU for a time extension to achieve air quality objectives, whilst at the same time adding more PM10 pollution to the problem?


Relocation of the AURN TEOM


6. In July 2007 the redevelopment of the Groeswen Hospital site forced the relocation of the AURN TEOM. A decision was made by Neath Port Talbot Council under the overall supervision of AEA Technology and the WAG to relocate the TEOM to the Taibach Fire Station. A report was commissioned by the WAG in February 2008 "A review of 2007 Automatic PM10 Air Monitoring data in Port Talbot", which outlined the sites shortlisted and methodology used to relocate the AURN TEOM. It also looked into whether the exceedences recorded from the two separate AURN positions could be combined.


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 Port Talbot, which is used to show compliance with air quality objectives, for historic analysis and consideration of further planning applications.

9. Had it not been for the fact that a Port Talbot resident (supported by Friends of the Earth Justice Section) had threatened legal action in March 2008, then it is unlikely that the WAG would even have bothered to launch a review of air quality or action plan consultation. Belatedly, in March 2009, the WAG commissioned "An Independent Review of Monitoring Measures Undertaken in Neath Port Talbot in Respect of Particulate Matter". The contract was awarded to Dr Enda Hayes of West of England University. The contract was awarded a full year after the air quality results for 2007 were ratified. This is just one of several failings of the WAG that will be highlighted in my submission.



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 Port Talbot", which attempted to defend the flawed procedures highlighted by Dr Hayes.

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?


Port Talbot PM10 air quality in 2008/09


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. Port Talbot was on track to fail the NAQS objective in 2008 but large cuts backs in steel production and the mothballing of a blast furnace in the final quarter of the year prevented further PM10 exceedences. Corus have operated on one blast furnace from October 2008 until August 2009 so much fewer exceedences have been recorded than normal over this period. Consequently it is important to keep any claimed improvement in air quality for 2008 and 2009 in perspective.


17. Historical record of PM10 air quality taken from UK air quality archives is shown below.










NAQS limit

Exceeds of PM10 - 24hr limit









Annual Average










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 Afan River at Mariners Point

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 "Port Talbot Steelworks PM10 Permit Review Jan 2009" clearly implicates the blast Furnace and the sinter plant facilities by triangulation.

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 EAW Port Talbot Steelworks PM10 permit review Jan 2009 highlighted that the sinter plant stack is still zero percent compliant with BAT and that parts of the blast furnaces are only 35% compliant (see below).

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. Port Talbot still has an air quality problem and it should not be targeted with more facilities that could worsen air quality. Planning law as it stands means that so long as emissions can be shown by dispersion modelling to be insignificant then the applications can be approved indefinitely.


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. Port Talbot requires the use of two additional software modules of ADMS not commonly used in other locations to account for the complex terrain and coastal landscape.


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 Port Talbot will not properly reflect the higher levels of pollution currently being recorded by the air quality monitoring equipment.


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 Port Talbot location and I suspect there is a high risk the Prenergy Power Station won't maintain this standard for very long, if indeed it manages to at all. I do not think the attitude of the EAW is helpful to maintaining air quality standards.


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 Port Talbot, as pollution reduction comes a poor second. The issue here is that the EAW have both a legal and moral responsibility to improve air quality in Port Talbot and it is indefensible to compromise people's health with false assessment.


34. I hold the view that government plans for biomass energy production in the UK are being promoted well beyond the resources available to fuel it. I oppose the building of six 300MW supersized schemes and other 150MW ones that will burn 25-30 million tonnes of imported wood annually. This is a totally unsustainable amount of timber and a great deal of environmental damage will result.


12th December 2009



AMDS - Air Dispersion Modelling Software

AQMA - Air Quality Management Area

AURN - Automatic Urban & Rural Network (Air Quality Monitoring Network)

BAT - Best Available Technique

CERC - Cambridge Environmental Research Consultants

EAW - Environment Agency (Wales)

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