Uskmouth coal power station was mothballed in April 2017 amid claims that it would soon be runon pellets made from mixed waste that would otherwise go to landfill. This briefing shows thatthese claims aren't credible, and that they may be masking plans to convert the site to run entirelyon wood pellets made from virgin wood. A proposal that would be as disasterous for the climateas it would for forests and local air quality.

The good news is that the company responsible, SIMEC Atlantis, also happen to own the UK'sforemost tidal lagoon experiments. Giving them a real choice as to where they put theirinvestment. By calling the current subsidy system to account now, there is potential to stop a badproject and ensure new jobs in genuine renewables.

February 2018

Uskmouth briefing • March 20181

In December 2017 The FinancialTimes announced that

“There are plans to convert theUskmouth plant to run on pelletsmade from a combination ofwood chip and waste”.1

The former coal power stationwas mothballed in April 2017.Ideas for its conversion had beenmooted for some years. In June

2015, the plant was bought bySIMEC, which is part of theGupta Family Group. The Groupalso owns nearby steel mill,Liberty Steel at Newport. InDecember 2017 ownership ofUskmouth passed to a newlycreated entity, SIMEC AtlantisEnergy Limited. The news wasgreeted by a number of nationalpress stories about it's plans to

deliver innovative local energysupplies of both tidal andbiomass for Greensteelproduction. There were reportsthat the power station would beused to provide low costsustainable energy directly to theneighbouring Newport arcfurnace, enabling the recycledsteel plant to expand, creatinghundreds of new local jobs. 2

UskmouthPower Station:What's going on?

The Claims

March 2018

Uskmouth Power station photo: Robin Drayton

More rigorous sulphur dioxide(SO2) emissions targets havemeant that for nearly a decadenow, operators of Britains coalfired power stations have beendesperate to find an alternativelow­sulphur fuel. Drax, the UK’slargest power station, has beenat the forefront of this. In recentyears Drax has invested moreheavily in upgrading theirinfrastructure to fire on'alternative fuels' than anyoneelse in the UK, as part of aproject that has been ongoing forthe last five years. They are nowthe single largest burner of woodin the world.3

Experiments carried out by Draxin 2012 show that their top of therange system is too sensitive totake even the wrong kind ofwood. As they rather demurelyexplain:

“The use of biomass forcombustion is not without itstechnical challenges. One of themost critical is that some of thenon­combustiable elements(such as alkalie salts) within thefuel can have deleterious impactswhen deposited upon metaltubing exposed within a boiler.”4

In trials during 2011 and 2012they found that even with just50% biomass (and 50% coal)“fault conditions were

encountered in terms of slagging,fouling and corrosion” In short,the wood feedstock they wereusing was clogging up and eatingaway at their boilers.

The operators of coal fired powerstations at Ironbridge5 andTilbury6 both tried to do coal tobiomass conversion on thecheap and ended up closing aftermajor repairs for serious fires.While the companies responsible

claim that no individual factorwas a key player in eitherdevastating blaze, wood pelletsare widely recognised to beassociated with risks of wooddust explosions as well as fires,including through self­ignition.These risks, and the costsassociated with making thepower stations compatible withthe stricter post­2015 EUstandards on emissions of airpollutants, resulted in their

Uskmouth briefing • March 20182

SIMEC have owned the siteuntil recently.

They are part of the GFGAlliance, an internationalgroup of businesses foundedand owned by the GuptaFamily.

The GFG Alliance also has anindustrial company calledLiberty House.

Liberty House are at theforefront of 'Greensteel' andbailed out Newports Steel plantin 2013 and rebranded itLiberty Steel Newport.

SIMEC group also already ownan interest in Tidal Lagoonplc, the company developingtidal lagoon opportunities inSwansea and the north­west ofEngland.

Atlantis Energy are a muchsmaller company withinvestments in Scottish tidalpower. These include theMeyGen project in northernScotland and the Wyre estuaryproject in Lancashire.

The nature of their partnershipappears complex. The

company they've sought tocreate as owners of Uskmouthis called SIMEC AtlantisEnergy Limited and waswidely reported as beingcreated in Dec 2017 but is yetto appear on the register atCompanies House. Thepartnership was effectedthrough a conditional sharepurchase agreement wherebyAtlantis agreed to acquire theentire issued share capital ofSIMEC Uskmouth PowerLimited in on the basis thatSIMEC recieve 49.99% ofAtlantis Shares.

The power station is due toopen in 2020 and will sell all itspower under two 20 year powerpurchase agreements to GFGAlliance companies. (ie, LibertySteel Newport).

The deal also states thatUskmouth will receive fuelunder a proposed 20 year fuelsupply agreement with a jointventure company to be partlyowned by a Liberty HouseGroup company and partlyowned by Dutch recyclinggroup N+P Group BV. N + Pare a small company whoproduce waste pellet fuel forcement production.

Are the Claims Credible?

The Trouble with Boilers

The problem is that no one has ever run a UK coal power station of the typethat exist in the UK on either pelletised waste. There are absolutely noindicators that it's possible to do so. Quite the opposite in fact.

Who's Who

So, what are they proposing toburn at Uskmouth? Theannouncement of the creation ofSIMEC Altantis Energy Limited8

suggests that the plant willreceive fuel under a proposed 20year fuel supply agreement with ajoint venture company to be partlyowned by Liberty House Groupand partly owned by Dutchrecycling group N+P Group BV.

Liberty House group have norecord of, or assets related to, theproduction of fuel. Which leavesthe likely manufacturers as N + PGroup BV.

So what are N + P proposing toburn? The only product availableon their current website that couldpossibly be expected to be usedas a coal substitute is calledSubcoal, which is made of SolidRecovered Fuel and RefuseDerived Fuel, both of themderived from Muncipal SolidWaste9.

N + P talk about how theycarefully select individual wastestreams, yet there is nodescription of how their chemicalcontent would make them viableas an alternative to coal in UKpower stations. While an article inthe cement industry press loudlyvaunts the two tests of theirproduct in cement production,there are no examples of thembeing used in any plant designedfor electricity generation.

When asked to expand on theunique features of Subcoal, thecompany says:

“First and foremost they are,obviously, solid fuel pellets. …our pellets look more like anengineered fuel than SRF orRDF... It helps convincegovernments and the wider publicthat this is a 'fuel' not 'waste'. …Subcoal pellets are very dry incomparison to other alternativefuels, with around 5% moisture”10

By the companies ownadmission, the key novel factorsof the product are essentially thatit is dried squished togetherrubbish.

Not Enough Fuel

Assuming that unpublished trialshave been conducteddemonstrating the feasibility ofusinge of Subcoal in UK coalpower stations, how ready areN+P to roll the project out? Howmuch fuel would they need to beproducing? The current projectedoutput from both N + P's plants in2018 (one still under constructionin the UK) would amount to268,000 tons11.

It is notable however, that despitetheir readiness to be direct aboutthe markets they have in theirsights, and the publicannouncement of the deal withLiberty Group, N + P appear tohave made no mention of theirplans to supply Uskmouth. Theydo make one carefully couchedreference to supplying a powerplant in a recent article:

“For example, we have had

discussions with a power plant inEurope to supply it with Subcoalpellets. If the plant converted justtwo of it’s 110MW units to use thepellets, it would need 1Mt/yr ofpellets.12” [1 million tons per year]

If it is Uskmouth they are referingto then it seems N + P are at farfrom certain about the deal andare yet to achieving little morethan a quater of the the capacitythey would require to supply apower station of Uskmouths size.

Uskmouth briefing • March 20183

Subcoal by Jennesson2014

Dried Squished together Rubbish

permanent closure.

Drax found that waste wood,wood with a lot of bark or woodfrom fast growing trees, corrodedtheir equipment to such an extent

that it wasn't viable. They arecurrently burning highlycontentious imports of pelletssourced from clearcut biodiversecoastal hardwood forests in theSouthern United States7.

Given their distinctly lacklustreenvironmental reputation, it issafe to assume that they wouldhave avoided doing so if theycould in any way change thissupply.

Not Enough Money

Uskmouth has been regarded assomething of a financial liabilityfor some time. in May 2014,SSE, the power station owners atthe time announced that it wouldclose. In the press release theyconceeded that:

"Uskmouth's future operationalregime had been an area ofuncertainty for SSE over the past12 months as the asset nearedthe end of its working life and theongoing financial position of thestation continued to bechallenging... Built around 50years ago, Uskmouth is theUK’s oldest and least efficientcoal fired power station13.”

So, what investment is beingproposed to get this plant 'at theend of it's working life' back in aposition to burn unpredictablenew feedstock? A news articlefrom Feb 201814 states that £200

million has been set aside for thetask. This huge amount of moneyis laughably insufficient when itcomes to converting a formercoal fired power station in theUK.

Again, extrapolating from theDrax experience15, SCIMECAtlantis are setting aside lessthan a fourth of the fundsrequired to do the job – yet Draxis the newest coal power stationin the UK, and more efficientthan Uskmouth.

Would a waste powered station be a good thing?

Unfortunately, for every tonne ofwaste burned, typically more thanone tonne of CO2 is released intothe atmosphere. This means thatwaste incineration has a highercarbon intensity than theconventional use of fossil fuels.16

There is also evidence to suggestthat incineration of waste, ratherthan dealing with rubbish forwhich there is no other currentsolution, instead incentivisesagainst recycling.17

4

Uskmouth, the 'oldest and least efficent' power station in Britianphoto Nicholas Mutton

photo by Friends of the Earth Scotland

If dramatic leaps forward were made in this field, what would a fuelmade of mixed waste mean for sustainability, internationalemissions targets and local air quality?

Climate Change From Burning Waste

What might be released into thelocal atmosphere if waste wasburnt for fuel? The bestevidence to draw from in thisarea are modern wasteincinerators, which despite beingfitted with expensive filters stillemit significant levels of dioxins

Air Quality impacts from Burning Waste

and furans, NOx and ultrafineparticles that can be harmfulto human health. Dioxins area group of chemicals that arecarcinogenic and act asendocrine disruptors.18

Uskmouth briefing • March 2018

Would a Wood Burning Station be a good thing?

Uskmouth briefing • March 2018 5

Climate Change and the Problem With Burning Forests

Air Quality impacts from Burning Wood

Burning wood for electricity isalso no less disastrous for theclimate than burning coal. Perunit of electricity, biomass emitsmore CO2 from smokestacksthan burning coal does.20

Biomass supporters claim thatthis CO2 should be ignoredbecause it will be absorbed bynewly planted trees. But treestake decades to grow andminutes to burn. Clearcut forestsmay never be able or allowed toregrow.

Biomass pellet production isdriving the destructions of forests

which would otherwise helpmitigate against climate change,as well as destroying globalbiodiversity hotspots. Coastalhardwood forests in the southernUS ( currently the UKs mainbiomass sourcing region) areamongst the most diverse forestand aquatic ecosystems outsidethe tropics. These criticalecosystems are being clearcut,with increasing amounts of thewood being turned into pellets21.The communities around thesepellet mills suffer noise, dust andair pollution.

There is reason to believe that ultimately SIMEC plan to convert Uskmouth to run on burning wood.They certainly have form in terms of presenting it as a 'renewable' source of power. On 26th July 2016they formally opened a 9MW Peaking Plant to generate electricity from biomass at Liberty Steel’sfacility in Newport.19 It was proposed as one of 14 such stations under their 'Greensteel' plan. At thetime they expressly stated that they intended to convert Uskmouth to run on biomass in the future.

Burning wood has seriousimpacts on air quality. A Freedomof Information request to theEnvironment Agency in 2017revealed that small particulate(PM10) emissions by Drax hadmore than doubled since thepower station began itsconversion to biomass. 22

PM10 and the even smallerPM2.5 are tiny particles less than10 or 2.5 microns respectively inlength, and are especially

dangerous because their smallsize means they can travel deepinside your body, in some casesentering your bloodstream andorgans. They are linked to a widerange of health problemsincluding cancer, heart diseaseand neurological problems.However, they are poorlymonitored nationwide and legallimits in England and Wales are2.5 times the limit recommendedby the World HealthOrganisation23.

At the moment, all the evidence suggests that to reopening Uskmouthwould mean either its continued unsustainable use of coal, or aconversion to burning biomass from slow growing trees, in the sameway as Drax does. Neither of which are ecologically, socially oreconomically viable.

The Bottom Line

Southern US coastal forest under threat,photo Dogwood Alliance

photo Sharon Fjeldstrom

Uskmouth briefing • March 20186

It Doesn't Have to be This Way

They're not sure what they want to doThe good news is that it doesn'thave to be this way. In the lastthree years SIMEC have made anumber of announcements forhow they plan to go forward withenergy generation at the sitewhich vary quite considerablyand have some positive optionsin the mix.

In June 2015 when they boughtthe plant SIMEC announced thatthey intended it to be:“converted to use biomassenergy generation using thelatest pyrolysis gasificationtechnology, as well as looking atdeveloping solar and wind powerfor the UK grid.”24

In March 2016 the South Wales

Argus reported that SIMEC’sstrategy for Uskmouth. 25

"centres on the creation of majorpower­generating capacity basedon Advanced ConversionTechnology, that turns waste intosyngas... This is in addition tobiomass generation and tidallagoon power from theneighbouring Severn Estuary.Later this year the companyhopes to begin thermo dynamiccracking at the site, convertingauto­waste into energy. ”

Despite the confident assertionsand timeframe, thermo dynamiccracking has never apparentlymaterialised. Neither did

Pyrolysis Gasification, which wasmentioned in 2015 and thendropped.

Along side these there seems tobe both a flexibility of thinking,and at least a mention of solarand wind. The joining of SIMECand Atlantis also makes thegroup responsible for the UK'stwo foremost Tidal Lagoonexperiments. These projects inthe Seven Estuary and thePentland Firth are innovativepower generators that may proveto be genuinely sustainable.Critically, the biomass basedschemes, and the no burnrenewables projects, rely ongovernment subsidy.26

Subsidies for new solar andonshore wind were scrapped in2016, and the government is stilldeliberating on it's backing fortidal lagoon work. The ScottishGovernment has accusedWestminster of reneging onpromisng to ringfence support forwave and tidal technologies.27

Subsidies for biomass aredependent on the wider public notbecoming aware of the anomalythat carbon emitted from burnt

trees isn't counted in emissionsbudgets.28

SIMEC have said that they wouldrequire government subsidies togo forward. In March 2016 theSouth Wales Argus reported that.

“the Group explained that thespeed at which the ambitiousplans progress will depend on UKgovernment support forrenewable energy projects. ...”29

Subsidies for What?

At the moment the future ofUskmouth is uncertain. It seemsthat its new owners are openlyseeking subsidies to proceed,and talking a big game in doingso.

Yet their current proposal aroundwaste doesn't appear credible,and any back up plans to usebiomass more than loose theirgreen veneer under scrutiny.

The people of Newport andsurrounding areas have a lot togain and a lot to loose from thefuture of Uskmouth.

Calling SIMEC Atlantis to greateraccount now could not only detera damaging and high risk forayinto waste and wood burning, itcould also provide furtherleverage to secure subsidies forrenewables experiments like theSwansea Tidal Lagoon. A timely

project that, if effective, couldboost the economy along theSouth Wales coast as well ascontributing to the national gridwhich is currently powering theNewport steelworks.

SIMEC Atlantis are after all thecompany who have everything: aterrible current plan, and thepotential to help drive forwardlocal employment and genuinerenewables.

Conclusion

Artists impression of the Swansea TidalLagoon. credit 10:10

https://www.ft.com/content/e8279f30­e0ba­11e7­a8a4­0a1e63a52f9c

South Wales Arugus 2nd February 2018, article Uskmouth Power Station Conversion Will Lead to

Hundreds of New Jobs accessed from

http://www.southwalesargus.co.uk/news/15916943.Newport_power_station_conversion_will_lead_to_hu

ndreds_of_new_jobs/

Identifying the sustainability of Biomass – assuring stakeholders of the sustainability of their supplies

access from http://www.arena­international.com/Journals/2013/02/25/u/x/d/IPS2013­­­Drax­Power.pdf

http://biofuelwatch.org.uk/docs/DECC%20FoI%20EIR%2013­

0340%20Q1%20Documents%20Drax%20etc%209May%202013.pdf

End of an era: Ironbridge Power Station is Shut Down accesss from

https://www.shropshirestar.com/business/shropshire­business/2015/11/20/ironbridge­power­station­to­

shut­at­2­30pm­today/

June 2012 RWE's Tilbury biomass plant restarts after fire accessed from RWE's Tilbury biomass plant

restarts after fire accessed from https://uk.reuters.com/article/uk­tilbury­biomass/rwes­tilbury­biomass­

plant­restarts­after­fire­idUKBRE85K16Y20120621

See Wood Pellet Feedstock Observation in Ahoskie, North Carolina: December, 2014 accessed via

http://www.biofuelwatch.org.uk/wp­content/uploads/Enviva­Investigation.pdf

Proposed Acuisition of SIMEC Uskmouth power Limited, creation of a renewable energy planform and

change of name to SIMEC Atlantis Energy Limited accessed from

https://www.atlantisresourcesltd.com/2017/12/14/proposed­acquisition­simec­uskmouth­power­limited­

creation­renewable­energy­platform­change­name­simec­atlantis­energy­limited/

http://www.np­recycling.nl/en/alternative­fuels/subcoal.html

Article in Global Cement Magazine Feb 2018, article Plant Visit N + P Subcoal accessed from

http://www.globalcement.com/pdf/3d/gcfeb18/index.html?page=16

Article in Global Cement Magazine Feb 2018, article Plant Visit N + P Subcoal accessed from

http://www.globalcement.com/pdf/3d/gcfeb18/index.html?page=16

Article in Global Cement Magazine Feb 2018, article Plant Visit N + P Subcoal accessed from

http://www.globalcement.com/pdf/3d/gcfeb18/index.html?page=16

Press Release 9th May 2014 SSE Uskmouth Power Station to Close accessed from

http://sse.com/media/227259/UskmouthPowerStationClosure9May2014.pdf

South Wales Arugus 2nd February 2018, article Uskmouth Power Station Conversion Will Lead to

Hundreds of New Jobs accessed from

http://www.southwalesargus.co.uk/news/15916943.Newport_power_station_conversion_will_lead_to_hu

ndreds_of_new_jobs/

Endnotes:

1.

2.

3.

4.

5.

6.

7.

8.

9.

10.

11.

12.

13.

14.

7.Uskmouth Briefing • March 2018

Green Investment Bank Case Study Drax Power Station Biomass Conversion Project

http://greeninvestmentgroup.com/media/25297/108675­gib­case­study­drax­final.pdf

http://zerowasteeurope.eu/downloads/the­potential­contribution­of­waste­management­to­a­low­

carbon­economy/

http://ukwin.org.uk/2014/10/22/ukwin­welcomes­efracoms­incinerator­caution/

http://ukwin.org.uk/oppose­incineration/

http://www.simec.com/news/simec­delivers­first­stage­of­renewable­power­network/

see studies listed at http://www.biofuelwatch.org.uk/biomass­resources/resources­on­biomass/

Dogwood Alliance Report, The Sustainable Biomass Program: Smokescreen for forest Destruction and

Corporate Non­ Accountabilty accessed from https://www.dogwoodalliance.org/wp­

content/uploads/2017/06/Sustainable­Biomass­Program­Report.pdf

http://www.biofuelwatch.org.uk/2017/briefing­draxs­coal­to­biomass­conversion­increases­levels­of­

dangerous­small­particles/

British Society for Ecological Medicine Report 2008 accessed from

http://www.bsem.org.uk/uploads/IncineratorReport_v3.pdf

Wales Online Uskmouth Power Station Reopens in a move securing 40 jobs as owners confirm

ambitious energy hub plans 25th June 2015 accessed from

https://www.walesonline.co.uk/business/business­news/uskmouth­power­station­reopens­move­

9516527

South wales Argus 21st March 2016 accessed from

http://www.southwalesargus.co.uk/business/14372761.South_Wales_renewable_energy_hub_set_to_s

pearhead_UK_drive_for____green_steel___/

Finanacial Times Dec 4 2017 Sanjeev Gupta buys into UK tidal energy access from

https://www.ft.com/content/e8279f30­e0ba­11e7­a8a4­0a1e63a52f9c

accessed from https://www.ft.com/content/

False accounting for Biofuels Science in Society access from http://www.i­

sis.org.uk/falseAccountingForBiofuels.php

South Wales Argus 21 March 2016 South Wales Renewable Energy Hub Due to Spearhead Drive for

Clean Steal accessed from

http://www.southwalesargus.co.uk/business/14372761.South_Wales_renewable_energy_hub_set_to_s

pearhead_UK_drive_for____green_steel___/

15.

16.

17.

18.

19.

20.

21.

22.

23.

24.

25.

26.

27.

28.

29.

Uskmouth Briefing • March 20188.