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CACG Request for Public Process on Permit Amendment |
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September 26, 2005
..We believe that several issues need to be addressed in the re-writing
of the permit and that such a re-writing would constitute a major
amendment to the permit. A major amendment both requires and
benefits from a process for public and stakeholder input. ...
September 26, 2005
Ministry of Environment
Vancouver Island Regional Office
2080-A Labieux Rd
Nanaimo BC
V9T 6J9
Attention: Randy Alexander
Regional Manager of Environmental Protection
Re: Permit PA-01902
It has come to our attention that permit PA-01902, issued under the
provisions of Section 13 of the Waste Management Act to NorskeCanada
for operation of the Crofton division pulp and paper mill, is currently
in the process of being amended.
The current permit issued in 1976 is an outdated document that no
longer accurately reflects the operations of the mill nor the present
day awareness with regard to the range of contaminants and
environmental and health issues associated with the facility.
We believe that several issues need to be addressed in the re-writing
of the permit and that such a re-writing would constitute a major
amendment to the permit. A major amendment both requires and
benefits from a process for public and stakeholder input.
Among the most critical issues to be considered in the permit amendment are:
- The current lack of definition and specified composition of
allowable fuels results in a legally ambiguous and unenforceable
permit. There is currently no definition for ‘wood waste’ and no
criteria for incinerated sludge composition resulting in a document
that is open to interpretation and consequently facing severe
limitations in enforceability.
- The range of contaminants specified and regulated in the
permit is incomplete. Currently the permit effectively regulates
only Total Reduced Sulphur compounds and Particulate Matter. A
much broader array of contaminants are known to be emitted from the
mill with over 40 compounds reported to Environment Canada (NPRI) and
70 compounds of concern identified in the only emissions inventory
available (Jacques Whitford air quality modeling study). It is
also known that some of the greatest health and environmental threats
from a facility of this nature are persistent organic pollutants and
that there are a variety of sources for volatile and semi-volatile
organic compounds throughout the mill. It is critical that the
permit address the range of known atmospheric pollutants being emitted
from the mill.
- ·The documentation of progress and projected milestones for
improved environmental performance as the economics and technology for
greater pollution prevention within the mill evolves should be included
in the permit. We view various practices of the mill as being
unsustainable for the ecology and for human health. Energy and
water usage, salty hog fuel burning and chlorine compound bleaching are
among the mill practices that require long term planning to mitigate,
reduce or phase out.
As members of the public directly effected by operations of the Crofton
mill, and as organizations established for the protection of the
environment and human health, we submit that it is crucial that this
amendment be open to public scrutiny and input. We request that
the permit amendment process be made public with access to drafts and
supporting information, and with opportunity for input from
interested public, organizations and other stakeholders.
Sincerely,
Rob Wiltzen
Crofton Airshed Citizens Group
Delores Broten
Reach for Unbleached
Cc: Honourable Barry Penner, Minister of Environment
Bernard Bintner, Senior Pollution Officer, Industrial, Ministry of
Environment
Michelle Vessey, Environmental Manager, Crofton Division, NorskeCanada
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Air Pollutants