Allington Quarry Waste Management Facility
Community Liaison Committee
Minutes (amended)
Meeting
16 November, 6-8pm
Attending
Fiona MacIntosh (minutes)
Paul Andrews
Bob Napthine
KCC
Geoff Rowe
Brian White (chair)
John Turner
Steve Bruce-Jones
Prof. Jim Bridges (speaker)
Mark Walsh
Malcolm Robertson
Jim Wiegner
Peter Dyer
KCC
KCC
Jabbar Neseyif
Nicola Perryman
David Porter
Myra Farrer
Tom Jerral (speaker)
EA
Apologies
Nicola Barker
Tony Harwood
No apologies
Ross Knowles
(received later)
Tom Cook
Action points are noted in bold
1.
INTRODUCTIONS
All attending introduced themselves.
2.
APOLOGIES/SUBSTITUTES
As above.
3.
PREVIOUS MINUTES
Minutes of the meeting of 8 September 2004 were accepted as accurate.
4.
UPDATES
Mark Walsh gave a brief update of work on site:

Diaphragm walls are completed

Preparation for piling/construction is ongoing

The waste bunkers are being prepared/constructed

Building work will be above ground level in the next 1 to 2 months

There are currently c. 120 staff working on site

Orders have been placed for all mechanical equipment, which will be installed during 2005

Engineering design work is going on in tandem with construction.
Jim Wiegner explained that Steve Bruce-Jones is leaving Kent Enviropower and introduced Paul Andrews as the new MD.
will take Steve/Jim’s place on the liaison committee. The committee wished Steve well.
Committee Secretariat: Fiona MacIntosh, Tel: 0845 601 5432, Email: info@kentenviropower.co.uk
Paul
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Mike Clifton informed the committee that the application to extend working hours had been approved by KCC.
The committee agreed that there had been no complaints to date about work on site.
Malcolm Robertson said that Maidstone Borough Council has written to the EA asking for their full input in monitoring the
project.
5.
PROFESSOR JIM BRIDGES
Prof. Bridges gave a presentation on health issues.
(Copy attached.)
Malcolm Robertson commented that he had no particular concerns about operation of the plant in ordinary circumstances and
within the regulatory limits, but that he was worried about what would happen in the event of a malfunction or mismanagement.
He referred to a plant in Dundee which had experienced problems. He asked how small particulate matter (PM10s) was to be
dealt with adequately.
Prof. Bridges commented that any error at the plant would have to be massive for it to result in events causing health concerns.
He commented that the plant would have on line monitoring and results would be linked to the EA. (The plant will also have on
line monitoring available for local people to see.) He commented that there could be more concern about health impacts from
particulate matter resulting from walking next to a main road than from operation of the facility. He commented that short terms
peaks in dioxins, for example as the result of some error in the plant, were not a health concern since concern arises from the
concentration of chemicals over time.
Tom Jeral referred to the gas clean up systems to be used and the monitoring regime agreed with the EA.
Jim Wiegner said that to override any mechanical warnings of malfunction manually would not be in anyone (including the
company’s) best interest.
Prof. Bridges talked about emissions standards. Emissions from the stack are regulated by the Waste Incineration Directive and
are based on what the technology being used can achieve. Health concerns, by contrast, look at the ground level concentrate of
emissions and are set with health impacts in mind: for acute (short term) impacts and cumulative impacts. He commented that the
operation of the facility should no get anywhere near approaching the limits for emissions, but that its operation must always be
considered in context.
Malcolm Robertson asked whether the EA could require improvements in emissions from the plant.
Kevin Thaw said that the EA could, subject to a Best Available Techniques assessment.
There was some discussion about the ingestion of chemicals (particularly dioxins) and Prof. Bridges commented that it was
extremely rare to find a person 20% of whose food came from local sources. In most cases it was closer to 1% he said.
Geoff Rowe asked whether Prof. Bridges could quantify the scale of risk to health posed by the facility in lay terms. Prof.
Bridges commented that there were so many risks present in every day life it would be difficult to do this realistically without the
facility’s contribution getting lost.
Malcolm Robertson commented that an Air Quality Management Area is being instituted along the M20 corridor.
Bob Napthine talked about the dispersal of emissions under very low/no wind.
Apsinwalls is attached.)
(An answer to his question on this point from
Mike Clifton commented that the location of monitoring stations to consider operation of the plant was agreed under the S106
agreement which accompanied the planning permission.
The committee thanked Prof. Bridges for his presentation.
6.
NEXT MEETING
The next meeting will be Tuesday 18 January. A site tour will be held at 17.30. The meeting will run from 18.00 to 20.00. The
meeting will address water issues.
Committee Secretariat: Fiona MacIntosh, Tel: 0845 601 5432, Email: info@kentenviropower.co.uk
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The following meeting will be Tuesday 22 February. A site tour will be held at 17.30. The meeting will run from 18.00 to
20.00. Kevin Thaw will give a presentation on permitting and monitoring.
The following meeting will be Tuesday 12 April. A site tour will be held at 17.30. The meeting will run from 18.00 to 20.00.
The meeting will address security issues.
7.
ANY OTHER BUSINESS
MBC’s The Big Debate was raised as a possible forum for discussing waste issues. Malcolm Robertson has since confirmed that
the meeting will not focus on waste.
Ross Knowles has not attended the last 2 meetings and not sent apologies. In line with the committees terms of reference FM was
asked to write to him and offer his place to the next person on the list interested in joining. (Apologies have subsequently been
received from Mr Knowles and thus no action will be taken.)
David Alexander told the committee he was retiring from KCC.
committee wished David well.
His place on the committee will be taken by a colleague.
The
Malcolm Robertson commented that he was pleased to learn that an alternative route to the A20 for the power cables from the site
had been found. The cables will be laid from Jan-Jul 2005.
Action Points

EA to provide speakers for next two committees

FM to book Mid Kent Water speaker for next committee

FM to post Prof. Bridges’ presentation on web site

FM to write to non attendees (No action now required.)

DA to confirm to FM KCC member to replace him

DP to provide FM with links to Lurgi web sites for inclusion in web site
Committee Secretariat: Fiona MacIntosh, Tel: 0845 601 5432, Email: info@kentenviropower.co.uk
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Allington Quarry Waste Management Facility – Community Liaison Committee
Kent Enviropower response (by Enviros) to question raised by Mr Bob Napthine, August 2004
Re: Dispersion modelling – proposed Allington waste to energy facility
“Is there an updated EIA available which should include an analysis for the zero wind to light breeze (say up to
5 Knots). I had a quick look in the Library's copy but I think that is still the original. You might remember I
pointed this out as an omission at the meeting on site 2 years ago. The range of winds analysed then for
emission spread did not include this significant proportion as shown at the centre of the wind Rose.”
The general point raised by the questioner is a relevant consideration, because Gaussian dispersion models cannot
directly take into account dispersion under zero or low wind speed conditions.
However, it is not quite correct to suggest that the study excludes an analysis for wind speeds up to 5 knots. In fact,
the model produces results for wind speeds down to 0.5 metres per second, equivalent to approximately 1 knot, as
measured at 10 metres above ground level. At ground level, this would be equivalent to a wind speed of approximately
0.25 knots. So it is only the very lowest wind speeds which are not included in the modelling study. For example,
looking at the meteorological data for Gatwick, 1997, which was one of the datasets used in the dispersion model, only
3.0% of the hourly data recorded a windspeed less than 0.5m/s.
For the very lowest wind speeds, Gaussian dispersion models are not appropriate, because at these wind speeds, the
contribution of other physical processes to dispersion is significant. This issue is a more significant concern for
ground-level sources of pollution than for elevated sources. This is because the very slow dispersion of pollutants from
an elevated source under these conditions will in general take place at some distance above ground level, with no
potential for adverse effects on local people. Conversely, the slow dispersion of pollutants from ground level sources
such as road traffic under low wind speed conditions could give rise to relatively high levels of airborne pollutants close
to the source.
In order to ensure that uncertainties such as the absence of model forecasts for the lowest wind speeds did not result
in air quality impacts being underestimated, a worst case approach was adopted to the assessment of the potential
impact of emissions from the Allington plant. This was designed to ensure that air quality impacts were more likely to
be overestimated rather than underestimated. The worst case approach included the following aspects:

The plant is assumed to operate continually at maximum capacity throughout the year with no downtime. In
reality, some limited downtime will occur;

Emissions of NOx are assumed to occur as 100% NO2 for short term calculations and 50% NO2 for long term
calculations, whereas the actual proportion is more likely to be in the region of 5-10% NO2.

Emissions were assumed to be at the limits set out in the Waste Incineration Directive (2000/76). In practice,
emissions will be lower than these limits;

The dispersion modelling study was carried out using a number of years of meteorological data, and the
highest modelled value for any year used in the interpretation of results.

The ADMS model is verified against field monitoring studies and has been found to be more likely to
overestimate than underestimate impacts, by comparison to AERMOD, the main alternative system.
Even following this worst-case approach, there was a considerable “margin of safety” between the modelled air
concentration levels, and the air quality standards and guidelines. For example, the highest modelled levels relative to
the air quality standard was for PM10. In this case, the process was forecast to contribute 0.6% of the air quality
standard, with a combined process contribution and background level of 83% of the air quality standard. Similarly, for
nitrogen dioxide, the process was forecast to contribute 4.4% of the air quality standard, with a combined process and
baseline level of 82% of the air quality standard. Minor changes in the process contribution values would not have a
significant effect on overall air quality, and would not affect the interpretation of the model results.
Our own experience of measurement to verify dispersion model forecasts confirms that modelled levels of airborne
pollutants from elevated point sources are in general over-estimates of the levels which arise in practice. It should also
be noted that the use of a Gaussian dispersion model in the manner used for the proposed Allington facility is widely
established best practice, and is carried out by industrial process operators, by regulators such as the Environment
Agency, by consultants such as ourselves, and in academic research.
Committee Secretariat: Fiona MacIntosh, Tel: 0845 601 5432, Email: info@kentenviropower.co.uk
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In view of these considerations, we conclude that the exclusion of periods of zero or very low wind speed does not
have a significant effect on the conclusions of the air quality study.
Committee Secretariat: Fiona MacIntosh, Tel: 0845 601 5432, Email: info@kentenviropower.co.uk
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