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Air Pollution Regulations? |
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Excerpted from Monitoring Pulp and Paper Mills in British Columbia - A
Citizens' Handbook by Stefan Ochman, 1997 ISBN 0-9680431-1-9, 118 pgs.
$12.50 ($10 to Members) - a Reach for Unbleached! publication.
Air emission regulations (or lack thereof) explained by Reach for Unbleached!
Government air pollutant emission regulations are virtually
non-existent. Polluters pay according to the amount they dump into the
environment. They are 'permit'-ed to disperse these wastes in our water
and air. When changes to current practices are made, they must seek a
change in license. Any environmental tests are to be paid for by the
client.
Unfortunately, there appears to be no regulation that these tests be
done by an independent third party. Simply, the fox is in charge of the
henhouse. Because the MWALP has been consolidated and then gutted,
there are no staff to suggest test methods or analyze the data. The
company reports with its conclusions drawn from its own data.
From the Reach for the Unbleached Web site, www.rfu.org :
Air Emissions
The major gaseous emissions from Kraft mills are Total Reduced Sulphur
(TRS), Oxides of Sulphur ( SOx) and oxides of Nitrogen (N0x). Mills
also emit large quantities of Particulate Matter (PM) into the air. The
most dangerous to human health is PM10 (Particulate Matter smaller than
10um) which are particles emitted by the mills that are inhaled deep
into the lungs. Air emissions can be separated into 3 different
categories: * emissions from the stack, * emissions in the mill
(indoors and on site), and * ambient air quality away from the mill.
Who Regulates Air Emissions?
There are no federal or provincial regulations for air emissions from
pulp mills, nor for indoor air quality, nor for ambient air quality.
Permits are issued by the regional provincial Ministry of Environment
offices authorizing mills to discharge contaminants into the air. Both
the Government of Canada and of B.C. have developed Objectives,
Guidelines and Standards for stack emissions and ambient air quality
for major air contaminants. However, these objectives are not legally
binding standards, but are only guidelines.
Emission from Stacks Permits are issued by the regional BC Ministry of
Environment offices authorizing mills to discharge air contaminants.
Typically, specifications under these permits include criteria for
emission rates and Particulate Matter for the recovery boiler(s), power
boiler(s), lime kiln(s) and smelt dissolving tank(s). (Table 2). Some
Permits also set limits from various sources for Total Reduced Sulphur
(TRS), Sulphur dioxide (SO2) and nitrous oxides (NOx). Table 2 clearly
shows that the limits for the various types of emissions vary greatly
from mill to mill. Even the same units are not used for the same
emission from one permit to another. For example, for Particulate
Matter from smelt dissolving tanks, units include mg/m3, kg/ADt and
kg/d.
The permits seem to be set in a way to fit the emission "capabilities"
of the particular equipment of the particular mill. Very few mills have
SO2 and NOx limits set on their power boilers. Howe Sound Pulp and
Paper stands out in this category. It has limits set on both SO2 and
NOx emissions. It is noteworthy that some permits even specify limits
on emissions of Chlorine dioxide and Chlorine from the stacks. The time
and reasons for routing non-condensible gases to the venting stacks
(instead of being burnt) must be reported and is specified in most
permits. However, as for the effluent and solid waste permits, the
consequences for exceeding the limits specified in the permits is not
specified.
The National Emission Guidelines and Standards can be used to establish
limits on specific sources of air pollution. Under a formula developed
by industry-government task forces organised by the Canadian Council of
Ministers of the Environment (CCME), the Best Practically Achievable
Technology (BPAT) is targeted. These guidelines vary from sector to
sector based on the appropriate best practically available technology
for a specific sector.
Similarly, a draft "Policy on the Development and Application of Waste
Discharge Criteria Based on Best Available Technology" was issued by
the B.C. Ministry of Environment, Lands and Parks in 1993. It proposes
that waste discharge criteria be based on a number of considerations
that include, among other things, the emissions levels attainable by
best available control technology for various sources of emissions.
H.A. Simons Ltd. released: "A Technical Background Information Document
on Pulp and Paper Mill Air Emissions" in October 1994. This document
presents various control technologies for various emissions from
various equipment and sources in pulp and paper mills. This report was
supposed to be used to assist establishing air emissions criteria for
B.C. mills and recommendations were to be included in the National
Emission Guidelines. Two years after the release of this report, there
still hasn't been much tangible developments on these two fronts.
What gets monitored?
All pulp mills have installed air monitoring devices on mill stacks for
collecting data on emissions at the source and present this data to the
Waste Management Branch of the regional BC Ministry of Environment
office usually every month. Source monitoring includes (usual sampling
frequency is indicated in parentheses):
• Discharge (quarterly),
• Particulate Matter (monthly, quarterly),
• TRS (continuously, monthly or annually)
• and sometimes sulphur dioxide (continuous) and nitrogen oxide (continuous).
For more details concerning the various emissions levels and sampling
frequencies for a number of mills in B.C., see summaries in the
Appendix to Monitoring Pulp and Paper Mills in British Columbia - A
Citizens' Handbook. The time and reasons for routing non-condensible
gases to venting stacks is also be monitored and reported.
Indoor Air Quality
There are no guidelines for air quality in pulp mills where gases such
as chlorine dioxide and chloroform can cause harm to workers except for
Workers Compensation Board limits. There is no ongoing monitoring of
indoor air quality. No information is provided to government on indoor
air quality.
Ambient Air Quality
There are no federal or provincial regulations concerning ambient air
quality. However, in most permits, ambient air quality monitoring
requirements are specified.
The National Ambient Air Quality Objectives and Standards have been
established under CEPA for only seven conventional pollutants in which
maximum desirable levels, maximum acceptable levels and maximum
tolerable levels are specified (Table 3). No guidelines exist for PM10.
A federal-provincial advisory committee on Ambient Air Quality
Objectives has developed "an active list of chemicals" for inclusion in
the further development of the ambient air quality objectives.
The B.C. Air Quality Objectives and Guidelines specify desirable levels
(Level A), interim levels (Level B) and maximum levels (Level C) for
various time periods (Table 3). Apart from objectives/guidelines for
the following air contaminants: Carbon monoxide, hydrogen sulphide,
lead, PM10, sulphur dioxide, TRS and total suspended particulate,
objectives/guidelines also exist for: zinc, total dustfall, chlorine
and chlorine dioxide Apparently, there are also 24 hour and 1 year
average interim guidelines for PM10.
The National Air Pollution Surveillance Programme is a joint programme
of the federal and provincial governments since 1969. Data from 50
cities and 117 monitoring sites across the country is collected, and
compiled every two years. Only six conventional pollutants are
reported: SO2, CO, lead, ozone, TSP, NO2. To date, public access to
this information has been weak to non-existent.
What gets monitored?
Mills have installed at their own cost one or two, sometimes 3 or 4,
continuous ambient air monitoring stations. Measurements include:
particulate matter as total dustfall and suspended particulate or PM10,
TRS and SO2. For an indication of what pollutants are measured in
certain mill town areas, please refer to the mill summaries. Data from
one or more meteorological stations such as wind speed, direction and
temperature is also reported. The data from these monitors is sent to
the BC Ministry of Environment offices on a quarterly basis and in some
cases, data from the monitors is sent directly via modem to the BC
Ministry of Environment regional offices. This data is not readily
accessible to the public. BC Ministry of Environment uses this
information to issue air quality advisories in the local media.
Excerpted from Monitoring Pulp and Paper Mills in British Columbia - A
Citizens' Handbook by Stefan Ochman, 1997 ISBN 0-9680431-1-9, 118 pgs.
$12.50 ($10 to Members) - a new Reach for Unbleached! publication.
The Handbook provides an overview of federal and provincial regulations
and monitoring requirements for effluents, air emissions and solid
wastes.
Tables summarizing effluent and air emissions for 13 mills in British
Columbia Canada are published for the first time. Other sections deal
with compliance and the harmonization agreement on effluents.
Regulation and monitoring of pulp mills in Ontario and the United
States are also presented.
This handbook is intended to foster communication between grassroots
groups and technical experts. It will increase the efficiency of local
citizens in their efforts to lobby government and industry to protect
environmental and health conditions in their communities.
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Regulations?