Dec 7, 2003
" It is one thing to be open to "new ideas", but burning burn
coal, creosoted railway ties and old tires in the hog fuel boilers at
the Crofton Mill, as NorskeCanada is planning to do, is not a "new"
idea. It's a very old, dirty, and potentially dangerous idea."
From: Guy Dauncey <>
To:
Cc:
Subject: NorskeCanada Permit - regulatory input
From Guy Dauncey, 395 Conway Road, Victoria, V9E 2B9
Editor of EcoNews
Author of "Stormy Weather: 101 Solutions to Global Climate Change"
www.earthfuture.com
Sunday December 7th 2003
NorskeCanada Permit to Burn Creosote etc. at Crofton
Public Input, prior to Dec 13th 2003
Dear Joyce,
It is one thing to be open to "new ideas", but burning burn coal,
creosoted railway ties and old tires in the hog fuel boilers at the
Crofton Mill, as NorskeCanada is planning to do, is not a "new" idea.
It's a very old, dirty, and potentially dangerous idea.
It sends all the wrong signals to people who are looking to BC, and the
Georgia Strait water, as a source of clean air, clean water, and
unrivalled ecotourism activities.
I am strongly opposed to the issuance of this permit. As a minimum, I
would like to see MWLAP extend the deadline for public input by three
months, and for NorskeCanada to host a well publicized Public Meeting,
so that the public can find out more about the proposed trial. I gather
from those who were there that the recent Open House did not answer any
of the questions that are in the air.
Very specifically, the public needs to know what will be the impact of
the emission of:
*polycyclic aromatic hydrocarbons (0.5 kg per railway tie)
*volatile 2- and 3-ring polycyclic aromatic hydrocarbons (naphthalene,
acenaphthylene, acenaphthene, anthracene, fluorene, and phenanthrene),
and
*phenolic compounds (10g per tie)
Creosote is included in CEPA's List of Toxic Substances (Schedule 1).
*What does this mean, for operations that involve its incineration?
"Coal-tar creosote is a heavy, oily, liquid made up of over 300
chemicals, including alkylnaphthalenes, naphthalene, diphenyl,
acenaphthalene, fluorene, diphenylene oxide, quinoline base and indole.
Still widely used as a wood preservative, this toxic stew can enter the
body through the lungs, through the stomach and intestines after eating
contaminated food or drinking contaminated water, or through the skin.
Exposure to coal-tar creosote can cause harmful effects on the skin,
eyes, nervous system, and kidneys; produce abdominal pain and vomiting,
heart damage, anemia, and can result in death. It also makes the skin
more sensitive to the effects of the sun, causing burning, irritation
and swelling. Laboratory appraisal has shown that creosote is highly
teratogenic and carcinogenic; two of its components, benzo(a)pyrene and
higher phenols, are considered to be powerful endocrine disruptors.
When heated to decomposition, coal-tar creosote emits acrid smoke and
fumes that include a variety of powerful toxins including polycyclic
aromatic hydrocarbons (PAHs). Though relatively water insoluble, some
parts of the creosote mixture can enter groundwater or change into
various environmentally migratory substances while other parts persist
in treated wood products for decades."
(http://www.eany.org/capitolwatch/memos/2001/116.html)
And then there are the old tires. What happens, when they burn? What are
they made of?
"Tires are not benign substances to burn. According to information
supplied by both tire manufacturers and the cement kilns that burn them
in other states, the following is a partial list of what tires contain:
*aluminum, which is harmful to animal and plant cells;
*antracene, which is a probable carcinogen;
*aromatic extender oils, which comprise about 25% of most tires today
and which are known carcinogens;
*arsenic, a known poison;
*benzene, which can effect the blood and is a carcinogen;
*benzidine, a carcinogen;
*beryllium, which harms the respiratory system;
*butadiene, which is a carcinogen; and
*cadmium, which harms the liver.
This list only goes through the letter "C."
Tires also contain lead, and have a high sulphur content that, when
burned, produces sulfur dioxide.
All these substances are harmful in and of themselves when released into
the atmosphere. However, when tires are burned in a cement kiln (or a
NorskeCanada plant - GD) and even more deadly compounds are also
produced . The most deadly are dioxins. There are no safe levels of
exposure to dioxin." (http://www.meic.org/tires2.html)
To continue on the old tires problem:
"Proponents of tire-burning claim that air emissions are the same with
tires as with conventional fuels like coal. However, independent
scientific studies do not support that claim.
A University of California at Davis professor, Seymour Schwartz,
prepared an independent report for the California Integrated Waste
Management Board. The report looked at test results from four California
cement kilns burning tires as 20% of their fuel. The study of emissions
found that:
* dioxins and furans increased between 53% and 100% in all four cases;
* polycyclic aromatic hydrocarbons increased in three cases (between
296% and 2230%) and decreased in one;
* lead emissions increased in three cases by 59%, 388%, and 475%, and
decreased in one;
* hexavalent chromium increased in one case by 727%, and decreased in
two others.
A representative of the Scrap Tire Management Council spoke at the
Helena meeting. He claimed that tires do not contain chlorine. Burning
chlorinated substances is what leads to the formation of dioxins.
However, the Scrap Tire Management Councilís own web site lists the
chemical composition of tires, and includes chlorine on the list.
Furthermore, Schwartz‚s report found that a „content comparison
indicates that tires may contain as much as two to five times the
chlorine level of western coal.‰
Any increase in the formation of dioxin is of grave concern. Dioxin is
the most potent animal carcinogen ever tested. It causes tumors in every
species of animal tested. Studies have shown that it causes birth
defects, diabetes, learning and developmental disabilities,
endometriosis, and immune system dysfunction."
(http://www.meic.org/tires1.html)
I have further concerns, stemming from this report into the Kaiser
Cement Corporation's experience with burning old tires:
"Though Kaiser initially claimed that the use of tire derived fuel (TDF)
would reduce emissions of nitrogen oxide (NOx) which contributes to
smog, the test results showed increased emissions of NOx (6.6%), as well
as mercury (195%), particulate matter (17%), lead and benzene.
Also, during the experiment, emissions of dioxins increased over l994
levels. Dioxins are recognized by the Environmental Protection Agency as
the most potent man-made carcinogen. In their 1994 Reassessment on
Dioxin, the EPA concluded there was no safe level of exposure to dioxin,
and that exposure to dioxin at extremely low levels can cause a wide
range of serious health effects including: reproductive impairment,
developmental injuries, and increased risk of diabetes and
endometriosis.
A recent Kaiser Cement newsletter said that tire burning "poses no
health problems." Citing the 1 in 315 cancer risk in the Bay Area, the
Air District claims the health impacts of the tire-burning will be
"insignificant". The Air District also acknowledges that burning tires
at Kaiser increases the incidence of cancer."
(http://www.svtc.org/archive/kaiser/burntest.htm)
I am currently working on a new book on "101 Solutions to Cancer", and
one of the emerging results that is becoming apparent is that on the
financial side of the equation alone, the economic cost of treating
cancer far outweighs the financial benefits to the polluters. If
NorskeCanada had to pay into a "Pollution-Based Health Problems
Anticipation Fund", as a future government might require to cover the
rising impact of pollution-based health care costs, the cost of their
payments would probably exceed the financial advantage gained from
burning dirty fuel.
And on the human side of the equation, every additional cancer case will
bring more tears and suffering.
I do hope that you will not allow your Ministry to override these
concerns.
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