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CACG Letter to MWALP, Jan 25, 2004 |
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Lists findings and demands. "It is unconscionable that
NorskeCanada, a major industrial company which purports to be
transparent and to have high environmental standards, should knowingly
place populations at risk. MWLAP, as the regulatory agency, appears to
be complicit through blind neglect."
Crofton Airshed Citizens Group
http://www.croftonair.org
January 25, 2004
The Minister
Water, Land and Air Protection
P.O. Box 9047, Stn. Prov Govt.
Victoria, B.C. V8K 9E2
fax: 250-387-1356
Dear Minister,
Re: NorskeCanada Crofton Mill
An overflow crowd of about 500 people attended the January 20th public
meeting at the Crofton Community Center organized by the Crofton
Airshed Citizens Group (CACG) to discuss toxic emissions from the
NorskeCanada Crofton pulp and paper mill. The meeting included
presentations from NorskeCanada, the Ministry of Water, Land, and Air
Protection, an air emissions and toxics expert from the US, a
representative of an environmental group specializing in pulp and paper
issues, a physician, and myself.
People sat quietly listening without a break for three and a half
hours. One by one a continuous line of citizens moved to the
microphone, almost all of them expressing concern with NorskeCanada
emissions. A young woman from Crofton asked to be reassured that her
pregnancy would not be affected by pollution from the mill, a long-time
Duncan physician questioned the ethics of carrying out a massive
experiment with humans used unknowingly as lab rats; others demanded
that the government do its job in overseeing and regulating the
mill. Media reports of the meeting can be found at
www.croftonair.org. MWLAP will be receiving transcripts of the meeting
as soon as they are available.
What was clear from that meeting is that citizens of this region have
had enough, and that the time has come for their concerns in relation
to the mill to be heard and acted upon.
The Company reports that every day approximately 24 million cubic
meters of exhaust gasses come from the Crofton pulp mill, carrying with
them a tonne of fine particulate matter, plus a tonne of volatile
organic compounds. We have strong reason to believe that the actual
numbers are considerably higher than those reported. The plume contains
some of the most dangerous substances known to life: dioxins and
furans, chlorine dioxide, formaldehyde, PCBs, hexavalent
chromium, in addition to large quantities of sulphur dioxide,
nitrous oxides, carbon monoxide, hydrochloric acid, and fine
particulate matter. The latter, especially when associated with metals,
is now known to be responsible for serious health impacts, including
respiratory disease, strokes and heart attacks.
Seeing that cloud moving towards your home and your family as many of
us do, smelling that acrid smell, experiencing burning eyes, breathing
difficulties, subsequent headaches, and not really knowing, is a
terrible thing. There is nothing worse than wondering what you will
find out in five or ten or twenty years. Those very real experiences
and concerns, we believe, are as valid a basis for precautionary action
as is all of the research and scientific data we have been able to
muster.
CACG was formed out of concern about Norske’s proposal to burn railway
ties, coal, and tires, but our research revealed that the mill’s
current practices are of serious concern. The following are a few
things we discovered after analyzing existing data and consulting with
experts in the fields of medicine, air emissions, industrial
engineering, meteorology, and toxicology:
• There is no thorough independent baseline study in place on the
mill’s current emissions and their health effects and therefore no way
to determine whether a new fuel trial will improve air quality or make
it worse.
• Power boiler #4 at the Crofton Mill, the subject of the current
permit application, acts like a toxic waste incinerator, burning
salt-laden bark, effluent treatment sludge and contaminated wood waste.
• Power boiler #4 is a gas boiler never designed for solid fuel. The
residence time (the time the combustion products stay in the boiler) is
too short to adequately break down toxic products. The boiler is
antiquated, subject to upsets and ongoing problems. It cannot be
depended on to safely burn current materials let alone treated railway
ties, coal and tires.
• Power boiler #4 lacks adequate pollution controls. The electrostatic
precipitator installed in 1991 and upgraded in 2001 has been described
by technicians who have worked on it as “undersized”, “the cheapest the
Company could find”, and as “never having functioned properly”.
• While higher temperatures could reduce emissions of dioxins and
furans, emissions of other dangerous substances will increase as a
result of adding the proposed new fuels. Thus we risk, at best,
exchanging one set of toxic emissions for another—sulphur dioxide and
heavy metals, including mercury, lead, hexavalent chromium, and zinc.
• Contaminated ash from the boilers is being transported on public
roads in open trucks to an old, overflowing waste disposal site.
• Data used by the company to claim success in trials for these fuels
in other mills have been called inconclusive and misleading by several
independent experts who tell us that normal scientific protocol is
absent, that averages based on anomalous numbers are used, and that key
data are missing.
We believe that the relationship between Norske and this community
should be guided and governed by the precautionary principle, language
that is now central in the Canadian Environmental Protection Act,
language that is the basis for the International Treaty on Persistent
Organic Pollutants:
"When any activity raises threats of harm to the environment or human
health, precautionary measures should be taken even if some cause and
effect relationships are not fully established scientifically."
The key element of this principle is that it incites us to take
anticipatory action in the absence of scientific certainty. In this
context Norske who is the proponent of a polluting activity, rather
than the public, should bear the burden of proof. On that precautionary
basis we demand the following:
• That the permit application for a trial to burn tires, railway ties
and coal be denied outright by the Ministry of Water, Land, and Air
Protection.
• That MWLAP investigate and review the content, process and
enforcement of all NorskeCanada Crofton’s permits, including those
relating to solid waste disposal.
• That an independent baseline study of air and water quality, and
their health impacts, be produced for the communities surrounding the
mill. The study to include computer modeling of the airshed, and soils
testing of school playgrounds and agricultural lands.
• That permanent ambient air testing stations be expanded and upgraded
in all of the communities in the airshed of the mill. And that a system
be established to inform the public immediately when emissions are too
high for health and safety so that residents can protect themselves.
• That an independently managed toll-free hotline be established for
citizens in the region to report problems emanating from the mill. That
those complaints, and how they were responded to, along with data from
the ambient air testing stations, be published each week throughout the
year by the papers in the region.
It is unconscionable that NorskeCanada, a major industrial company
which purports to be transparent and to have high environmental
standards, should knowingly place populations at risk. MWLAP, as the
regulatory agency, appears to be complicit through blind neglect.
MWLAP’s mission states that it is “committed to protecting and
enhancing the quality of British Columbia’s water, land, and air in a
way that contributes to healthy communities”. We believe that the
Ministry has not fulfilled its stated mission in regards to the Crofton
Mill. We, the residents of the Crofton airshed will not rest until this
matter is fully addressed.
We look forward to your immediate response.
Sincerely,
Michael Ableman for The Crofton Airshed Citizens Group
Cc —Russell Horner, CEO NorskeCanada
—Jan Oskum, Chairman of the Board, NorskeCanada
—The Hon. David Anderson, Minister, Environment Canada
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Air Pollutants