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CACG Letter to Provincial Health Officer on Mill Statements |
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June 06, 2005
Dr. Kendall,
I would like to take this opportunity to direct your attention to
erroneous statements found in the 2003 Provincial Health Officers
Annual Report. Specifically, the information found in the box on page
66 of the report entitled “Community Concerns over the Crofton Mill”
requires correcting since information provided to you by NorskeCanada
has been found to be in serious error....
June 06, 2005
Dr. Perry Kendall
Provincial Health Officer
4th Floor, 1515 Blanshard Street
Victoria BC V8W 3C8
Dr. Kendall,
I would like to take this opportunity to direct your attention to
erroneous statements found in the 2003 Provincial Health Officers
Annual Report. Specifically, the information found in the box on
page 66 of the report entitled “Community Concerns over the Crofton
Mill” requires correcting since information provided to you by
NorskeCanada has been found to be in serious error.
We at the Crofton Airshed Citizens Group (CACG) have been engaged in
processes and dialogue with NorskeCanada over the air emissions of the
Crofton pulp mill since late 2003. An important part of that
communication has focused on the air quality modelling research and
human health risk assessment that the company committed to
undertake. As you note in your 2003 annual report, NorskeCanada
hired consultants Jacques Whitford (JW) to perform the research,
modelling and risk assessment. Two peer reviews of the report
have also been completed.
The results of the peer reviews and subsequent meetings have
demonstrated clearly that the Norske funded JW report was inadequate in
several significant aspects. The peer review raises serious concerns
over the lack of transparency and the absence of basic risk assessment
protocol, among dozens of other deficiencies.
JW consultants are on record at a Community Advisory Forum of May
19, 2005 as saying that the report was not, nor was it ever intended to
be, a human health risk assessment. The admission came as a
result of the peer review performed by RWDI Air / Pioneer Technologies
which highlighted many fundamental flaws in the report. The
executive summary of the peer review report is attached and the entire
report may be found online at
http://www.croftonair.org/air/rwdi-peer-review-final-050428.pdf. The
executive summary and a critical review can be found at www.rfu.org.
It should be noted that the following statement of page 66 in the 2003 Provincial Health Officers Annual Report is in error.
“Residents raised concerns over possible health effects and in 2004
NorskeCanada, owners of the Crofton Mill, conducted a study of the
emissions and provided an assessment of the potential health impacts.”
The RWDI / Pioneer peer review concluded the following, which was
agreed to by Jacques Whitford consultants in the May 19th public forum.
“The JW Report does not constitute a Baseline Human Health Risk
Assessment because it does not evaluate all complete exposure pathways
and sensitive subpopulations. The JW Report only evaluates the
inhalation pathway for adults. Indirect exposure pathways (e.g.,
ingestion, dermal) and sensitive sub-populations should have been
evaluated in the JW Report.”
RWDI/Pioneer Peer Review
The importance of considering multiple pathways and exposures is also
addressed in your annual report so I’m sure that you will appreciate
the serious flaw that this presents in terms of health risk assessment.
Likewise the following statement cannot be found to be true in light of
the above-noted deficiencies of the report and admission by JW that no
baseline health risk assessment has been done.
“Overall, the review concluded that the emissions from Crofton Mill did
not pose health threats to those communities with significant
populations in the vicinity of the Mill.”
The statement below from the same information box is also a very questionable characterization of the mill.
“Although the Crofton Mill was considered to be one of the cleanest
mills in BC, it was noted that even within stack emission standards, it
was possible for weather conditions to trap and concentrate pollutants
at ground level, causing emission levels to exceed ambient standards.”
I would ask who considers Crofton Mill to be one of the cleanest
mills in BC and on what basis and criteria such a statement could be
made. We have only an incomplete emissions inventory and
inadequate dispersion modelling to base any judgements over the
cleanliness of Crofton emissions. Clearly this is insufficient
information.
The Crofton Airshed Citizens Group is representative of the ongoing
community concerns over air quality and the health and environmental
effects of the mill. In no way does the report provided by the
mill assuage local community concern over these issues. The lack of
transparency and misrepresentation of the report by NorskeCanada as
determining that the mill posed no health threats, in fact, heightens
concern over what the health impacts of the mill could be.
We continue to seek a truly independent air quality modelling study and
baseline health risk assessment of the Crofton Mill. The new study must
address the deficiencies identified in the RWDI-Pioneer peer review of
the JW report. A technical committee, including representatives from
regulatory agencies, health and environmental sectors, and local
residents, will be needed to direct the work.
I understand that your report has already been published and
submitted. We would ask that you update your information to
reflect the current state of affairs with regard to the Crofton mill,
undertake whatever post-publication correction processes available to
you for the 2003 report and/or present the updated and correct
information in the next report.
I would further respectfully request that you please respond and inform
the Crofton Airshed Citizens what measures can be or have been taken to
correct the misinformation provided by NorskeCanada.
Thank you for your attention.
Regards,
Robert Wiltzen
Crofton Airshed Citizens Group Coordinator
cc: Russell Horner, CEO, NorskeCanada
Graham Kissack, Environment Director, NorskeCanada
Stuart Clugston, Vice-President, Corporate Affairs and Social Responsibility, Norske Canada
Don McKendrick, Vice-President, Norske Canada Crofton Division
App.
Excerpt from
Provincial Health Officers
Annual Report 2003
p. 66
Community Concerns Over the Crofton Mill
The Crofton Mill, situated on the east coast of southern Vancouver
Island, was a focus of attention in the Capital Regional District’s
Healthy Atmosphere 2000 report (1992), which suggested that emissions
from the mill were noticed by residents throughout the region,
particularly on the Saanich Peninsula and Saltspring Island.
Although the Crofton Mill was considered to be one of the cleanest
mills in BC, it was noted that even within stack emission standards, it
was possible for weather conditions to trap and concentrate pollutants
at ground level, causing emission levels to exceed ambient standards.
Residents raised concerns over possible health effects and in 2004
NorskeCanada, owners of the Crofton Mill, conducted a study of the
emissions and provided an assessment of the potential health impacts.
The study, which was reviewed by a third party, Senes Consultants Ltd,
reported that of the 106 pollutants, 102—includingPM10 and total
reduced sulphur—were at levels within Canadian and international
guidelines. The study recommended further monitoring of four
pollutants- sulphur dioxide, hydrogen chloride, nitrogen oxides, and
hydrogen sulphide - that had higher predictedconcentrations close to
the fence line of the mill property. Th e review concluded the
following about the potential for health effects:
• Sulphur dioxide – health effects are unlikely but cannot be ruled out at this point.
• Hydrogen chloride – very unlikely to cause health effects.
• Nitrogen oxides – no acute health effects expected.
• Hydrogen sulphide – unlikely but cannot be ruled out at this point.
The review also reported on polycyclic aromatic hydrocarbons (PAHs) and
concluded that there was no increased cancer risk above a bench mark of
1 in 100,000.Overall, the review concluded that the emissions from
Crofton Mill did not pose health threats to those communities with
significant populations in the vicinity of the Mill. (NorskeCanada,
2004)
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Air Pollutants