United Valleys Action Group (UVAG)

United Valleys Action Group (UVAG)

Response to the Coal Closure Consultation Document

(Ref: Coal Generation in Great Britain: The pathway to a low-carbon future - Consultation - November 2016)

produced by Chris Austin on behalf of UVAG - February 2017

Introduction

The Group

The United Valleys Action Group (UVAG) is a fully constituted community action group that has been operating in the Heads of the Valleys zone for over 6 years. We work with the community on issues of social and environmental justice that affect the upper Welsh Valleys communities, and sometimes beyond.

Our most significant campaigns to date have been against a mass burn waste incinerator and opencast coalmining. The former was the threat of a mass waste 'black bag' incinerator proposed by Covanta at Cwmbargoed, near Merthyr Tydfil, and the latter has been primarily a campaign against the Nant Llesg opencast coalmine proposal overlooking the upper Rhymney Valley communities. This is a 15-year extension to the massive, and controversial Ffos-y-fran opencast coalmine operated by Miller Argent (South Wales) Ltd. at Merthyr Tydfil.

The group was heavily involved with the successful premature termination of Covanta's planning application and the rejection of the Nant Llesg planning application by Caerphilly County Borough Council's (CCBC's) planning committee in late 2015. Unfortunately, an appeal by the applicant, Miller Argent, against the Nant Llesg decision in January of 2016 is still, one year on, being held in the planning process by the Planning Inspectorate (PINS).

Our Concerns, Hopes, and Aspirations

Our local concerns are the continued threat of further opencast coalmining in the upper Rhymney Valley, the continued operation of the Ffos-y-fran opencast coalmine, and the future of the Ffos-y-fran opencast coalmine in respect of its restoration and the inevitable cost of its failure on the public purse.

Our wider concerns are for the future of the highly polluting Aberthaw coal fired power station. Its continued operation risks the health, and even the lives of hundreds of people every year. Aberthaw's status as a standby power station would come at a heavy cost to the public purse.

Our hopes and aspirations are centred on the greening of the upper Rhymney and Merthyr/Taff valleys. This encompasses both the physical greening of the valley and our ambitions for community 'green' energy generation schemes.

Preamble - Factors Considered During our Analysis of the Document

The Impact of Coal - Introduction

You speak of the impact of burning coal on the environment being the emissions; of 'greenhouse' gasses, toxic emissions, and the impact of employment in the generating and fuel supply industry. However, there is, of course, the human cost that is the effect of mining the coal on the affected local communities. The only method employed now for extracting coal is surface mining, or 'opencast' mining that has a ruinous effect on the local environment and the quality of lives of those living and working within its catchment area.

The Ffos-y-fran opencast coalmine has been, and continues to be, a blight on the lives of those who live within its sphere of influence. The noise and dust pollution, 15/16 hours a day for the last 9 years has been awful and, at times, intolerable. They have had to go to bed and rise in the morning within the 8-hour period allotted them, the noise making it impossible to sleep for any. The dust coating their properties has ruined their quality of life to the degree that using the garden is restricted to times when the wind is blowing onto the site and giving them some respite. When the wind blows off the coalmine, the residents are unable to hang out washing or open windows, even when the weather is warm.

The pleas of the affected community have fallen on deaf ears since the mining company started operations in 2007. The company was granted self-regulation and despite strong representation the communities attempts at getting the operation monitored and controlled by the local authority their entreaties have been dismissed or ignored. This has been recognised by the United Nations (UN) and a Special Raporteur met with Merthyr community representatives recently (February 2017). The community has also taken its complaints to the courts and they are now awaiting their case being heard in the European Court of Human Rights (ECHR). The community would not have been able to progress their case this far if it was weak or baseless.

As much coal is imported, you also have to consider that the impact on global communities is similar, if not worse in some countries.

The diesel particulate pollution from the massive earth moving machinery and the release of Methane (CH4 - a very reactive greenhouse gas 70 times the global warming potential (GWP) than Carbon Dioxide (CO2) in its effects) from the coal seams are when they are uncovered and worked must also be a consideration. I don't want to pontificate here, but it's far more complex than just the emissions at the point of burning the coal. We have very 'gassy' seams up in the Welsh valleys, and the machinery at Ffos-y-fran burns through many road-tanker's worth of diesel fuel in a week.

We also have the global societal impacts with coal being sourced from countries with questionable human rights conduct, such as Russia and Colombia, but we will leave this issue for others to explore and UVAG will focus more on the local and regional issues.

These issues have to be factored-in when looking to the future of coal; the UK Government has to consider the environmental and societal impacts of the source of the coal too.

The Impact of Coal - Detail

Opencast Coalmining - Emissions

Methane

The coal seams at Ffos-y-fran opencast coalmine in Merthyr Tydfil have not had gas drainage methods employed during excavation. If that is coupled with the fact that the seams are known to be high in Methane content, and are at a considerable depth - (the excavation is >600 ft currently) - the pressure at such depths holds the Methane in the coal seam [[1]]; then there is much scope for further significant volumes of Methane to be emitted during the operation.

The Nant Llesg opencast coalmine is following the same coal seams as Ffos-y-fran over into the next valley, and as we have seen no proposal to vent or control the gas. We conclude that the same circumstances will apply there. There is much scope for significant Methane emissions if planning permission were ever to be consented.

Particulates

At Ffos-y-fran the mining company purchased the largest earth-moving machinery on the market. The massive Komatsu PC3000 Super Shovel diggers and the complimentary sized Cat 777 lorries producing vast amounts of emissions. Scant regard has been paid to fuel efficiency, diesel emissions, and noise pollution; their choice was driven by capacity alone.

As the mine wasn't subject to the Welsh technical advice note, 'MTAN2: Coal', safeguards, there is no 500 Metre buffer zone, and the mining operation is very close to the heavily populated Merthyr community, (32-37 Metres at its nearest). This negates the argument for atmospheric dispersion of the particulates before they reach the community.

These particulates have fractions that are small enough, (PM2.5), to reach deep into the lungs and cause long-term health issues. The particulates are also coated with burnt, and partially burnt hydrocarbons that are toxic to the human body.

Aberthaw

This is our local power station and we have included details here, as it is our best-understood example of the issues we are exploring here. The power station is in the UK TNP, and has so far attracted 2 years generation under the Capacity Market Auction, (but at least another year is likely for 2017-2018).

Toxic Emissions

The plant emits a mix of toxic gasses and particulates with the more significant toxins being Nitrogen Oxides (NOx), Mercury, and Particulate Matter (most especially the PM2.5 fractions).

The most contentious NOx member is Nitrogen Dioxide (NO2). This is emitted in large volume from Aberthaw power station with figures of 31,000 Tonnes in 2015 at a density of circa 900 to 1,000mg/NM3 max. The EU emissions regulations extant from 2008-2016, the Large combustion Plant Directive - LCPD, were 500mg/NM3 max, and since January 2016 the maximum limit was reduced to 150mg/NM3 in the EU Industrial Emissions Directive - IED. It can be seen that the power plant is breaking the EU regulations by some way; almost double the older EU regulations (LCPD) and nearly 5 times the new regulation (IED). This was confirmed in September 2016 when the European Court of Justice (ECJ) successfully prosecuted the UK Government for failing to control emissions from Aberthaw power station [[2]].

The reaction with other pollutants, water vapour, and sunshine in the atmosphere creates a chemical cocktail in the environment surrounding the power station's sphere of influence. This creates further harmful NOx (Nitrogen Dioxide, NO2, especially) emissions such as Ozone (O3) and Nitric Acid (HNO3). NOx is toxic to human health, Ozone, especially at ground level is toxic to human health, and Nitric Acid is toxic to health and to the environment causing the classic 'acid rain'.

Mercury (Hg) figures are hard to come by as they are not controlled by EU emissions regulation but we have seen figures of between 30Kg and 200Kg per annum being used in reference to Mercury emissions from Aberthaw power station. This is a particularly toxic heavy metal which bioaccumulates - i.e. it builds up in the body faster than it can be excreted. This has the potential to cause serious long-term health problems.

Greenhouse Gas Emissions

Aberthaw power station emits circa 8.5 Million Tonnes of Carbon Dioxide (CO2) gas per annum (2013 figures). This is the most prolific greenhouse gas, by volume, and this is a massive contribution to Wales' carbon footprint and to global warming and climate change.

The NOx emissions are also contributors to global warming with the Nitrogen Dioxide (NO2), and Ozone (O3) gasses being particularly damaging.

Aberthaw as a Standby Power Station

Since the ECJ judgment the UK government and RWE Npower, the operators of Aberthaw, have had to demonstrate how they are going to comply with EU emissions regulations. There was one uncorroborated statement from RWE Npower at the time, then very little (nothing!?) since.

RWE Npower stated that their strategy to tackle the issues with Aberthaw involved implementing a 'low-NOx' boiler/burner upgrade, coupled with a change from low-volatility to high-volatility coal burning, and by reducing the plant's operating hours.

The latest EU emissions regulations, the Industrial Emissions Directive (IED), have made provision for power plants to run on reduced hours. It is called 'peak-plant derogation' and allows the plant to run for a maximum of 1,500 Hours per annum that comes with reduced emissions limits for NOx of 450mg/NM3. We have no idea how the hours of operation would be distributed at Aberthaw.

The UK Government has selected Aberthaw to be a backup, or standby, power station for the winter months of 2018-2020. To this end they have awarded RWE Npower a £27 Million subsidy for their efforts. There is also now an option to bid for 2017/2018 and Aberthaw will surely bid for, and secure this extra generation capacity and they will gain a further subsidy of circa £10-15 Million. We are not sure whether this money is to come from public money (taxes), or somehow from the consumer/bill payer through an increase in electricity costs. We are not sure how that would work; possibly a UK Government surcharge or levy added to the electricity bill?

The capacity market auction scheme will cost around £2 Billion to £3 Billion per annum for the 4 years of its operation. That's up to £12 Billion to keep these old power stations sitting idle for the bulk of the year just to be there on-call in case they are needed in the winter months.

We have concerns as to how the standby will be implemented at Aberthaw. For the plant to operate on a call-off basis, at times of peak demand, the 46-year-old coal fired power plant would have to be brought online at short notice by staff who would have to be retained, inactive, on full wages for the rest of the year. Also, does an old, massive coal-fired power station lend itself to being switched on-and-off at short notice? It doesn't make too much sense to us; it sounds plausible in theory, but the practicalities of the scheme raises many questions.

The Low-NOx boiler upgrades are also questionable as they were specifically rejected as a solution to reduce NOx emissions at Aberthaw when the Environment Agency commissioned a report on the subject in 1999 [[3]]. They concluded that owing to Aberthaw power station's unique design it was unsuitable for this solution. RWE Npower fitted a low NOx burner on one of its three boilers in 2016 to test its effectiveness, but no information as to its efficacy has been released since. We are concerned that this is because, as the Environment Agency indicated, the upgrades effectiveness was less than expected.

Excerpt from the report by Mitsui Babcock Energy Limited (MBEL) on behalf of the Environment Agency:

The NOx reduction method, Selective Catalytic Reduction (SCR), is the best available technique, (BAT), industry standard that would remove 90+% of Nitrogen Dioxide (NO2). RWE Npower have already indicated, to the UK Government, that they would not fit SCR due to its high-costs; estimated to be >£200 Million. Despite stating that this method was not considered economic i.e. too expensive [[4]], RWE Npower applied for planning permission in 2012 to fit SCR to Aberthaw. They submitted detailed plans and secured planning permission. Despite using this as a powerful public relations statement to leverage continued operations they failed to fit SCR and have only spoken about fitting the Low-NOx boiler upgrades since. The cost of this work varies between £5 Million and £12 Million per boiler; a much cheaper option than SCR. This is nowhere near as effective as SCR and would only reduce NOx by 50%-60% under the very best conditions, which would not to be the case at Aberthaw power station.