December 18, 2007
Michael J. Reiner
For Director, Environment Management Act,
Kootenay and Boundary Regions
Dear Mr. Reiner,
Re: Comments on the Amended Pope and Talbot Permit PA-01951(02)
As Chair of the Boundary Air Quality, I would like to make the following comments on
the proposed amendment to the Pope and Talbot Permit PA-01951(02).
At the December 4th meeting of the BAQC, the committee decided not to hire the
services of Dillon Consulting to do a ‘peer review’ of the proposed amendment. This was
a difficult decision for the committee as it temporarily leaves the committee without
independent professional advice on a permit that may be critical to the sustained health of
the airshed. Nevertheless, the committee made this decision for the following reasons:
1. P&T is not in a position to really negotiate this permit as it is under the
direction of a CCAA monitor. Nevertheless, the company did ask for this
amended permit and is trying to get it together as part of the 'due diligence'
process of the potential new owner - Interfor. Moreover, the sale of this property
as a mill is not guaranteed and the amended permit may be just a paper exercise.
2. The BAQC is going to complete a dispersion modeling study this spring,
which would be assisted by the terms of the amended permit if a new owner does
take over. Furthermore, this study may indicate that further modifications to the
P&T permit may be necessary and that a peer review of any additional permit
would be quite timely then.
3. The BAQC has little current funding for the year 2007, but anticipates more
monies that it could spend this spring on a peer review or a 'best practices'
statement.
The committee hopes that it will have the opportunity to deal constructively with the
future owner of the lumber mill and together set goals in 2008 for an air quality
management plan.
The BAQC and the Ministry of the Environment are now in possession of the SENES
Consulting Emissions Inventory of the Grand Forks airshed. This inventory gives
valuable insight and guidance into the management of the airshed. These comments will
refer to the data within this document as well as the information sources that the
Emissions Inventory (EI) is based upon.
Point Source Emissions
According to the EI, the Pope & Talbot operation is responsible for the following
amounts of Common Air Contaminants in metric tonnes:
CO
NOx
SOx
VOC
TSP
PM 10
PM 2.5
14.52
72.68
0.43
50.0
62.0
54.0
34.0
from provincial inventory 2000
from provincial inventory 2000
from provincial inventory 2000
from NPRI submission
from MoE monitoring data 2006
from MoE monitoring data 2006
from MoE monitoring data 2006
Of particular concern are the NOx and PM 2.5 emissions. P&T accounts for 18% of the
total NOx in the airshed. The fact that the most recent data on NOx is from the 2000
provincial inventory would indicate a need for more current monitoring of this particular
CAC.
This lumber mill is the source of 11% of the total PM 2.5 while point source industry
emissions account for 59% of this CAC in the airshed. This is the dominant health
concern in the airshed and in spring 2007, MoE used the following formula to apportion
the airshed based on the Canadian Wide Standards for PM 2.5 of 30ug per m3:
30 ug per m3 would the maximum allowed
minus 6 ug per m3 for natural background
12 ug per m3 would be municipal
12 ug per m3 would be assigned to industry
Thus each of the three major industries would get 4/30 or 13% of the allowable PM 2.5
load. This would seem to indicate that the lumber mill is within this limit except that the
EI has shown that industry accounts for more that 50% of the PM 2.5. Moreover, the EI
shows that industry also contributes to the total PM 2.5 load in the atmosphere through its
mobile and area contributions which are discussed next in this letter. It is highly probable
that a Dispersion Model of the airshed will indicate that the lumber mill operation will
have to make improvements to stay within the apportionment.
Mobile
Although these emissions are not covered by the permit, it is important to note them at
this time as we examine the lumber mill’s load on the airshed. According to the SENES
EI the lumber mill operation has the following mobile contributions in metric tonnes:
CO
30.78
NOx
18.11
SOx
1.25
VOC
2.25
TSP
0.77
PM 10
0.77
PM 2.5
0.72
CO2
2111.4
These figures are for P&T equipment on the lumber mill site. The numbers increase if
the highway traffic coming to the mill in the form of logging trucks is also taken into
account. The Green House Gas CO2 is of special concern as GHG’s are not covered by
the permit, but are being targeted by the provincial and federal governments for
improvement as part of the Climate Change program. P&T ‘s contribution to CO2
emissions in the airshed accounts for 3% of the total. This may become an important
figure to improve over the next few years.
Fugitive Dust
Emissions that are mentioned in the permit are the fugitive dust problems that P&T
equipment and mill operation causes. In the EI these emissions are classified into the
Area contributions and again they are significant. The major source of the lumber mills
contribution to Area dust is the loader machine. According to the EI, this machine
contributes 48.2 tonnes of Total Suspended Particulate. Of that 13.72 tonnes is PM 10
and 1.37 tonnes is PM 2.5. This single machine is responsible for almost 2% of the total
fugitive dust load in the airshed. When summer operations are taken into account as the
driest time of the year this contribution increases. More diligent monitoring of fugitive
dust extending beyond the boundaries of the mill will be needed to set goals and to chart
improvements in the years ahead.
Other Environmental Concern
One other environmental impact of the lumber mill operation is its impact on the riparian
sections of the river it borders. Although it is not part of the amended permit and is not
mentioned in the SENES EI, it is an important concern for the community. Pope &
Talbot has been expanding its lumber yard and rail yard operations as part of its
expansion. This has put a great deal of pressure on the river front to the north and west of
the mill. It is hoped that pedestrian access to the South Ruckle subdivision can be
provided with the decking of the Black Train Bridge and paving of city lands bordering
P&T lands on the flood plain just to the north and west of the lumber yard and rail
loading area.. Currently the lumber mill is expanding its rail yard by loading yard wastes
onto riparian lands that are on the flood plain.
Recommendations
1. Authorized discharges should be more descriptive in the amended permit. The phrase
‘Typical emissions from lumber dry kilns’ used in Section 1.7 should be replaced with
more accurate wording to reflect the actual expected discharges.
2. Similarly the phrase ‘ Typical emissions from natural gas-fired boilers’ used in Section
1.8 should be replaced with the actual expected discharges.
3. With the growing concern on climate change and the availability of federal and
provincial subsidies to reduce Green House Gases this permit should require the operator
to annually report the total of GHG’s emitted and to set in place a plan to reduce these
emissions.
4. Section 2.1 is a major improvement on the fugitive dust problem that currently haunts
this operation. It could be furthered strengthened with the requirement that the permittee
must report on the actual steps taken to ‘address visible cyclone particulate emissions or
deposition of dust’.
5. Sampling requirements should include measurements of CO, NOx, and SOx as these
CAC’s have gone unreported for some time and monitoring must be in place if the
expectation is that the operation will improve on these emissions.
6. Section 3.2 needs to be strengthened so that it is a requirement of the permittee to
monitor total mill particulate at the mill boundary and report those measurements every
two weeks to the Director. This operation is a significant contributor to TSP in the
airshed and in order to set goals and chart improvements constant monitoring must be in
place.
7. Section 3.3 also needs to be strengthened. In particular the cyclones related to the new
planer have become major sources of fugitive dust and fine particulate. Improvements to
these cyclones should be a requirement of the permit.
8. Section 3.7 should also be strengthened. The requirement for the first reporting period
to be January 31, 2011 puts this data out of reach for too long. Once again, in order to
set reasonable goals and to monitor improvement, more frequent monitoring and
reporting is necessary.
9. Section 3.8 is also a major improvement as it may require the permittee to participate
in ambient air quality monitoring, air advisory committees and to do advanced
dispersion modeling. It is only hoped that the word ‘may’ can be replaced with ‘ shall’.
It is with the greatest respect for the job that the Ministry of the Environment is doing in
our airshed that I forward these comments to improve the amended permit. I look
forward to working with MoE and the owner of this lumber mill in the years ahead to
complete an air quality management plan that will safeguard our airshed in to the future.
Sincerely Yours,
Chris Moslin, Chair
Boundary Air Quality Committee