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Toxics – Northwatch Archives for 2001 to 2005

Federal Government Refuses to Clean Up their Toxic Radar Sites

First Nations, Residents Oppose Bennett Soil Incinerator in Belledune, New Brunswick

Nipissing Environment Watch Sponsors 4th Annual Batter Collection Competition

Bennett Environmental in the Accused Box

Bennett Sues New Brunswick Conservation Council Over Incinerator Comments

Falconbridge Imports Toxic Soils to Fault Lake Tailings Area

Bennett Environmental Inc. Makes a Move on Port of Belledune, New Brunswick

Ministry of the Environment Still Quiet on Trans-Cycle Industries Emissions

Bennett Environmental Inc. Withdraws EA for Haz Waste Incinerator in Kirkland Lake

PCBs in Kirkland Lake: Backgrounder on Bennett Environmental’s Proposed Haz Waste Incinerator

TCI Withdraws Request for MOE Approval of Facility Expansion

Northwatch Waits on Access to Information Request on TCI … 17 months and counting

Northwatch Calls for Full Environmental Assessment of TCI’s Proposed Expansion of PCB Operations

PCBs in Kirkland Lake: Backgrounder on TransCycle Industries and Proposed Expansion

Federal Government Refuses to Clean Up their Toxic Radar Sites

The First Nations of Mushkegowuk Council received word in early June that the Federal Government refuses to commit funding to clean-up their legacy of toxic waste on the shores of James and Hudson Bays.

In the 1950’s the Department of National Defense created 17 radar sites in Ontario as part of the Mid-Canada Line. These sites were abandoned and have since leaked large amounts of PCBs and hydrocarbons into the environment. The sites are all located in the traditional territories of First Nations, land the aboriginal people depend on for hunting and fishing.

All of the sites are situated in the traditional territories of Northern Ontario First Nations, with the southernmost site located near Ramore, another site south of Moosonee and the remainder of the sites located along the shores of James and Hudson Bays.

The passing of time has increased the rate and range of contamination; toxins continue to accumulate throughout the local plants and wildlife. Several studies have confirmed the presence of contaminants across different levels of the food chain. The Government has allowed the continued discharge of the contaminants into the environment even after publication of numerous reports outlining the environmental and health risks associated with the Mid-Canada Line radar sites. Since at least 1980, Mushkegowuk First Nations have pursued site remediation.

Only one of these sites, Fort Albany (050), has gone through a clean-up process, which included the removal of equipment and soils with high levels of contamination and the disposal of soils with low-levels of contamination in an engineered landfill.

The other sixteen sites continue to contaminate the environment as well as pose a health risk to First Nations people who live, hunt, fish and trap within the vicinity of the abandoned radar sites. The provincial and federal governments are fully aware of the Mid-Canada Line radar site contamination yet continue to permit the pollution.

In March of this year the Provincial Government finally offered to pay half of the clean-up costs if Ottawa would pay the rest.

In early June Mushkegowuk Council received a letter from the Honourable William Graham, Minister of National Defence that “land management was returned to the Province … Therefore, the responsibility for this issue rests with the provincial government.”

Grand Chief of Mushkegowuk Council, Stan Louttit was surprised by the federal response. “For more than 25 years the First Nations have been asking for the sites to be cleaned-up. Now we have received an offer by the Province to pay half the costs, but the Federal Government refuses to deal with their toxic mess. Whatever happened to the policy of “polluter pay”?

Source: Mushkegowuk Council Lands and Resources

Northwatch News, Summer 2005

First Nations, Residents Oppose Bennett Soil Incinerator in Belledune, New Brunswick

Residents of a polluted region of northern New Brunswick known for its high incidence of cancer were in court in early June seeking an environmental review of a controversial soil incineration plant they say would cause more health problems.

Bennett Environmental Inc., based in Oakville, Ont., has already constructed the $30-million facility in Belledune, N.B., a community of nearly 2,000 near the Quebec border, and received provincial approval after conducting its own environmental review.

But a loud outcry from area residents has spurred Ottawa to impose its own demand for an environmental assessment.

Lawyers for the federal government and concerned residents were on hand for a Federal Court hearing in Toronto in early June to obtain a federal review of the incinerator’s possible health effects.

”We have enough pollution in our area,” said Junia Culligan, president of the Belledune Citizen’s committee.

A Mi’kmaq chief on the Quebec side of the border said he feared the plant – which has yet to receive an operating licence – would send carcinogenic furans and dioxins into the air.

Other aboriginal communities in the area include the tiny First Nations of Pabineau and Eel River Bar and the Listuguj First Nation of nearly 3,000 people.

“We fish, we hunt, we use the medicinal plants; it’s a big concern to us that another layer of pollution would be added,” Martin said.

Bennett lawyer Andrew Roman said the federal government had its chance to intervene when the facility was in the planning stages and going through an environmental assessment that was approved by the New Brunswick government in 2002.Construction had begun in September 2003.

Bennett Environmental Inc. previously attempted to site the incinerator in Kirkland Lake, but never completed the environmental assessment process.

Northwatch News, Summer 2005

Nipissing Environment Watch Sponsors 4th Annual Batter Collection Competition

Nipissing Environmental Watch is hosting its fourth annual Used Household Battery Collection Competition. The competition diverts used batteries from the local landfill site and educates students about hazardous household waste. The school that collects the most batteries per student will win a $500 prize. The second place school will win a $200 prize. The competition ends on Friday, May 27, 2005.

All types of household batteries including AA, AAA, C, D, 6-volt, and 9-volt batteries, both rechargeable and non-rechargeable, are being collected as well as button batteries, such as are used in watches and hearing aids. The batteries will be taken to the local Household Hazardous Waste Depot for safe disposal.

Organizer Trevor Schindeler says that, “The battery collection competition is a way to get hundreds of students and their friends and family doing something to help the environment. We hope that if someone stops throwing batteries into the garbage, he or she will think twice before putting other hazardous waste into the garbage.”

In the last competition students collected a total of 5,711 pounds (2,590 kilograms) of batteries. The winning school alone, St. Joseph-Scollard Hall of North Bay, collected some 2,387 pounds (1,083 kilograms).

There are eight schools participating in the competition. The Battery Collection Competition is generously funded by TD Friends of the Environment Foundation.Northwatch News, Winter/Spring 2005

Bennett Environmental in the Accused Box

Seven Quebec environmentalists from La Terre d’Abord made a first court appearance in early March, facing charges stemming from a peaceful occupation of the Paul Martin’s riding office in Montreal requesting a moratorium and an independent environmental study of the Bennett project. The environmentalists have accused Bennett Environmental of “non respect of Environmental Norms in Quebec” for actions of one of its subsidiary, Récupère Sol inc. in Saint-Ambroise. At a media conference in late February Stéphanie Leclerc, one of the arrested, explained the reason why they carried out their actions: “All we are demanding is that a moratorium be imposed on Bennett Environmental Inc. toxic waste incinerator project in Belledune, New Brunswick and an independent environmental impact study of the project.”

According to Florian Levesque, from Environment Vie, the New Brunswick government approvals to date of the Bennett project is unacceptable and is “showing the contempt for the citizens this government has while pretending to represent them.” Bennet is now preparing to carry out their test burns which, if approved, will get Bennett its required Operating Permit.

Bennett Environmental has previously tried to site a toxic waste incinerator in Kirkland Lake. That project and its environmental assessment are currently on hold. For more information on Bennett and the Belledune incinerator visit http://www.stopbennett.comNorthwatch News, Winter/Spring 2005

Bennett Sues New Brunswick Conservation Council Over Incinerator Comments

The Conservation Council of New Brunswick and its senior staff members David Coon and Inka Milewski are being sued by Bennett Environmental for comments made in the media and a letter to the editor concerning a hazardous waste incinerator the company is building in Belledune, New Brunswick. Bennett Environmental also has a proposal to develop a hazardous waste incinerator in Kirkland Lake, which has been the subject of intense local and regional opposition in northeastern Ontario.

What the Conservation Council saw as its duty to provide fair comment on a matter of significant public interest has resulted in this lawsuit which alleges the comments were defamatory and brought Bennett Environmental into hatred, ridicule and contempt resulting in injury to its character and professional reputation. The company is seeking general damages, special damages, punitive damages and its costs.

The Province of New Brunswick exempted the hazardous waste incinerator from a full public environmental impact assessment. The Federal Court of Appeal recently overturned the decision of the federal Minister of Environment to refer the project to a federal review panel following a judicial review brought by the company. Local property owners are currently appealing the company’s building permit.

A complete copy of Bennett’s Statement of Claim can be obtained by contacting the Conservation Council for full details on what the company alleges were defamatory statements. Following are paraphrases of two of the statements.

In response to a question from a New Brunswick Telegraph Journal reporter in August 2003, David Coon told him that toxic pollutants are released from incinerators which treat hazardous waste and that these end up as contaminants in the environment. In its Statement of Claim, Bennett alleges that the statement was false and defamatory of their company, and maliciously stated.

In an October letter to the editor of the New Brunswick Telegraph Journal last year, Inka Milewski noted that months had passed since the Conservation Council had written to the Ministers of Environment and Health detailing what it believed were deficiencies in the company’s air pollution and human health risk assessments. In its Statement of Claim, Bennett alleges the statement was false and malicious.

The Conservation Council has had a long-standing policy of opposing the importation of hazardous wastes for treatment in New Brunswick and the high temperature incineration of toxic chemicals on environmental grounds.

To make a donation to the Conservation Council Legal Defence Fund, be listed as a Friend of the CCNB Legal Defence Fund, order a copy of the Statement of Claim, or if you are willing to host a fundraising event, please contact the Conservation Council of New Brunswick, tel(506) 458-8747 fax (506) 458-1047 or email ccnb@nb.aibn.com. Further information about the issue can be found at http://www.conservationcouncil.ca
Northwatch News, Fall 2004

Falconbridge Imports Toxic Soils to Fault Lake Tailings Area

Building on their decade-long tradition of taking contaminated materials for “treatment” on their mine tailings areas in Falconbridge, Noranda-owned mining giant Falconbridge Limited has upped the ante with a new class of toxic waste; this time it is soil contaminated with diesel fuel and oil.

Reportedly, Falconbridge has been accepting contaminated soil from Ottawa-based Environmental Management Solutions Inc. for almost a decade, although the first notice on the Environmental Bill of Rights electronic registry goes back only to 2000. That approval was for the “treatment” of “non hazardous impacted soil” at the Fault Lake Tailings area.

Environmental Management Solutions Inc recently won a $6-million contract for a soil treatment plant it operates on property owned by Falconbridge Ltd.

Bennett Environmental Inc. Makes a Move on Port of Belledune, New Brunswick

Bennett Environmental Inc. announced in late January that it was shifting its sights to New Brunswick, where it is now pursuing a permit to construct and operate an incinerator for hazardous wastes near the Port of Belledune, in the north east part of the province.

In the style of “we’re taking our toy trucks and going home” (or not), Bennett announced that they would be taking the Unisphere tire recyling and Lignol wood treatment plant with them to New Brunswick.

In early November of last year, BEI withdrew their request for an environmental assessment approval to build the facility in Kirkland Lake, after the Ontario Ministry of the Environment issued a deficiency statement which served as a damning statement on the quality of work done by the hazardous waste operators in preparing their EA studies. Bennett indicated at the time that it would be resubmitting in the new year, and expected it would be in receipt of a final approval by mid 2003.

With the same corporate optimism previously displayed by BEI in Ontario, Bennett now says he anticipates the plant in New Brunswick having construction permits in place by the end of March, and the plant operational by the end of 2003.

While moving ahead with the new Brunswick project, Bennett says they are still working to get the facility approved in Kirkland Lake, and are “pushing hard” on MOE to downgrade require- ments associated with the Bennett proposal, such as the as operating temperatures in the incinerator’s aferburner before resubmitting their EA.February 2003

Ministry of the Environment Still Quiet on Trans-Cycle Industries Emissions

In August 2001 Northwatch filed an Access to Information request for records of emissions from Trans- Cycle Industry’s PCB facility in Kirkland Lake. Eight months later, the Ministry of the Environment responded with a cost estimate of $740; Northwatch paid the required amount.

In October 2002, the Ministry of the Environment indicated that it had to contact TCI to “determine if the records submitted contain confidential information”and that TCI had until November 20, 2002 to respond. TCI was then given an extension until December 20th, after which MOE would have 10 days to make a decision about disclosure.

As of February 10th, Northwatch was still waiting! Trans-Cycle Industries continues to operate in Kirkland Lake.February 2003

Bennett Environmental Inc. Withdraws EA for Haz Waste Incinerator in Kirkland Lake

In a terse 3 sentence response to the Ministry of the Environment, Bennett Environmental Inc withdrew their application for a toxic waste incinerator in Kirkland Lake on November 8th.

It had been a bumpy road for BEI as opposition had continued to build to their proposal to import and incinerate PCBs, dioxins, pesticides, and other hazardous wastes at a their proposed facility.

Area MP Benoit Serré, speaking at rally in August, said “this plant could pose a serious threat to the farming industry in Northern Ontario …. We cannot and must not jeopardize a $100 million industry for the sake of a few jobs.” Serré said he was moved by the deep opposition from all sectors of the riding including First Nations, municipalities, the District School Board and over 90% of the region’s medical community. More recently, the United Nations Special Reporter on Human Rights spoke out, expressing concerns about the public review process.

In early October, the Ministry of the Environment delayed the release of the government review, “because of the number and complexity of issues raised by the government review team and the public”. Then, in a November 1st letter to Bennett Environmental, MOE outlined a number of deficiencies with the Bennett EA and directed BEI to respond to the deficiencies and to “numerous errors”. Bennett must now respond to this direction, and identify clearly how they had done so, prior to MOE completing the government review. Bennett withdrew their EA “to permit Bennett a reasonable opportunity to address the … comments”, and have said they intend to resubmit, possibly in the January.November 2002MOE Notice of Bennett’s Withdrawal

Northwatch Comments on Draft EA, January 2002

Northwatch Submission on Final EA, September 2002

For more information visit Public Concern Temiskaming

Visit Highgrader Magazine’s “PCB Battles” Waste Page

PCBs in Kirkland Lake: Backgrounder on Bennett’s Proposed Hazardous Waste Incinerator

Bennett Environmental wants to set up and operate a PCB and hazardous waste incinerator in Kirkland Lake to treat up to 200,000 metric tonnes of contaminated soil, sludge and other debris from across North America. Last year, Bennett announced that they would undergo a full environmental assessment, but now they want a narrow review that leaves out alternatives and health impacts.

Polycholorinated biphenyls (PCBs) are a class of manmade organic chemicals produced by the direct combination of chlorine and biphenyl, a derivative of benzine. PCB’s have been banned in Canada since 1977 due to their adverse effects on the environment and human health. PCB’s bio-concentrate and bio- magnify, are extremely persistent toxics, and are known carcinogens.

Bennett Environmental Inc. is proposing to establish a “fixed soil treatment” facility on Archer Drive in Kirkland Lake. The proposed facility will be capable of receiving and treating up to 200,000 metric tons of contaminated soil annually from, according to Bennett, “a primarily North American market base”. Bennett says the proposed facility will be a scaled up version of the BEI owned Récupère Sol Inc. treatment facility in Saint Ambroise, Quebec which is a “high temperature thermal oxidiser”, more commonly known as an incinerator.

The proposed facility could accept soils and solids contaminated with chlorinated organic compounds (for example PCBs & PCP) as well as non-chlorinated organic compounds. Soils and solids will consist primarily of soil, sediment, concrete, brick, asphalt, sand, aggregate, roots, wood, and similar materials removed during the clean- up of contaminated sites. The proposed facility could also treat packaging material such as plastic liners, bulk bags, corrugated boxes and wood used to package delivered soils. The chlorinated and non-chlorinated organic compounds will include pesticides, herbicides, fungicides, wood perservatives, PCB, PCP, PCDF, PAH, PCDD, TCE, coal tars, hydrocarbons, creosote, and “others”.

The first steps in the Bennett system will be to screen, crush or shred the contaminated soil and other waste materials. Soil of similar contaminants may be homogenised to achieve a more uniform moisture level, contaminant concentration and granular (physical) consistency of the feed stock, which would allow, according to Bennett, the incinerator to function at peak efficiency.

The thermal process equipment consists of a rotary kiln primary combustion chamber (PCC), a secondary combustion chamber (SCC) and an emission control system. The emission control system consists of an evaporative gas conditioning chamber (GCC), a dry scrubber system, a fabric filter and a monitored emission stack. Contaminated soil is metered into the PCC where it is heated to 650 to 800 C, and the contaminants in the soil are vaporised. The vaporized gasses mixing chamber where air and fuel are injected, and the resulting gas mixture is directed to the secondary combustion chamber (SCC) where the “total oxidation” (incineration) takes place at temperatures over 1,000 C at a prescribed retention time of just over 2 seconds. The gasses exiting this chamber then move through an emission control system and are then released to the environment.

Incineration Harms the Environment

Around the world, PCBs have been disposed of primarily by incineration. When PCBs are burned, they create dioxin, an even more potent toxic chemical with a wide variety of adverse health effects. The United States Environmental Protection Agency has found that the average body burden of dioxins and PCBs among U.S. citizens are already sufficient to place all of them at or near those levels at which human health effects are known to occur. A recent survey by the United Nations Environmental Programme (Inventory of World-wide PCB Destruction Capacity, 1998) listed 37 incinerators that are used to burn PCBs. The health threats to the local communities surrounding these incinerators are significant, but other areas of the world are threatened as well. For example, a report by the Center for the Biology of Natural Systems in New York, USA, concluded that dioxin emissions from incinerators in Texas, Florida, Utah, and Louisiana migrated long distances and contaminated the Great Lakes. People living near the PCB incinerator in Swan Hill, Alberta have been warned against eating local game.

Problems Measuring Emissions

PCBs typically are incinerated at facilities that can purportedly achieve a destruction and removal efficiency (DRE) of 99.9999%. This means that no more than .0001% of the PCBs that enter the system escape through air emissions “up the stack.” Even this level of efficiency could mean substantial releases of PCBs and dioxins over time. However, there are several flaws with this way of measuring emmissions. First, the DRE is not measured during daily, routine operations when actual PCBs are being burned. Instead it is measured during a one-time-only “trial burn” of selected substitute chemicals under carefully controlled conditions.

Second, the DRE only takes into account air emissions. A high DRE tells us nothing about the amount of PCBs/dioxins transferred into ash, left in the residual, or discharged in waste water as a routine part of the incineration process

Finally, not all PCBs that are intended for incineration actually are. While stack emissions and contaminated ash and waste water are serious concerns, losses during transportation, storage, and processing may be an even greater problem.

Bennett’s Environmental Assessment

In May 2000, Bennett Environmental “volunteered” for a full environmental assessment of the proposed PCB incinerator. But when Bennett produced draft terms of reference for the EA a few months later, an examination of the need for the project and alternatives was excluded, as was a full examination of the health impacts (instead, Bennett wants to include a ‘risk assessment’).August 2001

TCI Withdraws Request for MOE Approval of Facility Expansion

under construction – visit this site again soon!

Northwatch Waits on Access to Information Request on TCI … 17 months and counting

On August 1, 2001, Northwatch mailed a written request (and the $5 processing fee) to the Ministry of the Environment Access to Information office for information related to emmissions from the Trans-Cycle Industry PCB facility in Kirkland Lake, Ontario. Eight months later, the Ministry of the Environment responded with a cost estimate of $740, and on May 7th 2002 Northwatch forwarded payment to the Treasurer of Ontario. On October 30 2002 the Ministry of the Environment Freedom of Information and Protection of Privacy Office informed Northwatch that “it is necessary to contact the third party pursuant to Section 28 of the Act to determine if the records submitted contain confidential information as outlined in Section 17 of the Act”. The letter indicated that TCI would have until November 20, 2002 to provide reasons for the claim of confidentiality and then the Ministry would have until November 30, 2002 to make a final decision about disclosure of the records. But no word yet!January 7, 2002

Northwatch Calls for Full Environmental Assessment of TCI’s Proposed Expansion of PCB Operations

April 10, 2002

Ariane Heisey, Project Officer
Environmental Assessment and Approvals Branch
2 St. Clair West Suite 12A
Toronto, Ontario, M4V 1L5

Sent by fax (416) 314-8452
EBR Registry Number: RA02E0005

Dear Ms Heisey:

RE. Proposal to Designate Trans-Cycle Industries Inc. (TCI) Expansion of existing PCB Recycling Facility in Kirkland Lake under the Environmental Assessment Act

Trans-Cycle Industries (TCI) has been operating a hazardous waste facility in Kirkland Lake since December 1998, with the facility approved to remove polychlorinated byphenyls (PCBs) from electrical equipment by stripping PCB contamination from the metals. The facility also receives PCB wastes for bulking; all PCB wastes are to be transferred off site for final disposal. The Ministry of the Environment is proposing that the expansion be designated under the Environmental Assessment Act; Northwatch strongly supports this proposal, and urges the Ministry to proceed with the designation, and require a full environmental assessment of the project, including need, alternatives and cumulative effects.

Background
In March 2001, TCI submitted two applications to amend its Certificates of Approvals for discharges to air and to operate a waste disposal site. The purpose of the application for amendments was to allow TCI to “include new non-incineration technology referred to as the continuous thermal desorption unit process. The continuous thermal desorption unit decontaminates soils, sludge and debris contaminated with chlorinated organics and non-chlorinated organics. After treatment, a minor contaminated residual sludge remains to be transferred off-site for final destruction. Facility emissions to atmosphere are from a carbon column stack serving an existing degreasing operation, a boiler stack providing heat for the above degreasing operation, a continuous thermal desorption unit (CTDU) stack and CTDU natural gas stacks” and for “an increase in the receiving and storage capacity at the facility to include soils and sludge; approval to expand waste receiving categories to include chlorinated organic and non-chlorinated organic waste soils and sludge; and expand existing site area due to acquisition of adjacent lands”.

Harm to the Environment
TCI proposes to import into the Kirkland Lake facility soil, sludge and debris contaminated with chlorinated organic and non-chlorinated compounds such as PCBs, PCP, PCDF, PAH, CDD, TCE, hydrocarbons, creosote, pesticides, herbicides, wood preservatives, fungicides, and other organic compounds. Each and all of these substances are recognized as harmful to human health and to the natural environment. TCI proposes to treat these contaminated materials with a thermal desorption technology, the application of which will result in releases of harmful compounds to the environment through both air and water. It must be noted that many of these substances are known carcinogens, are directly related to a number of reproductive, health and development concerns, and are considered to be harmful at even very low levels or exposure, ie there is no safe level of exposure.

In addition to the release of these contaminants through the operation of the CTDU process, a residual of these contaminants will remain in the treated soil, which is intended to remain on-site for an indefinite period of time. Further, the transport of the materials into the region/area/facility has attached to it a factor of risk of greater release to the environment due to accidents, and there is a relatively high risk of release of contaminants – above those anticipated – throughout the operating lifetime of the facility, due to process and technical failures in the treatment of the waste streams.

Contravention of Provincial Policy
In 1999, TCI applied to expand its service area for its existing operation. This application was refused, on the grounds that “the Director decided to refuse this application because it is not in the public interest and may result in a hazard to the health or safety of the public in that it will import PCB’s into the Province of Ontario”. When TCI appealed this decision, the Ministry further documented and confirmed that such an expansion was unacceptable, in that it “represented a fundamental change in policy direction in that the Ministry is committed to reducing the inventory of PCBs and PCB waste in Ontario”.Clearly, the TCI proposal to expand its facility to allow import into Ontario of contaminated soil, sludge and debris is also a contravention of Ontario’s policy, in that it is similarly not in the public interest, may result in a hazard to the health and safety of the public, and will increase the inventory of PCBs and PCB waste in Ontario.

Use of Thermal Desorption
We have a number of concerns with the selected technology, both in terms of its effectiveness and the appropriateness of the technology for use in the manner proposed by TCI.

While the information provided by TCI or through the Ministry of the Environment has been extremely limited, we have surmised from that information which was made available for reviewing at the Kirkland Lake Municipal Office that the specific equipment proposed for use at the TCI facility is that which was employed for the in situ treatment of waste materials, soils and sludges at an abandoned wood treatment facility in Hollywood, Maryland which had become a U.S. Superfund site. We wish to note that the application of a technology for in situ treatement of one set of wastes does not, by extension, qualify that same technology as appropriate for the treatment of a much broader set of wastes being treated ex situ.

Further, we have the following concerns with respect to the use of this technology:

TCI has not identified if the process they intend to use is high temperature or low temperature; this is an important aspect of the process description
thermal desorption units appear to have been used in a number of situations for in situtreatment of wastes; we have found no examples or case studies of the use of this technology for ex situ treatment of wastes
Ministry staff we spoke with (Timmins District and Air and Noise, Approvals Branch) were unaware of any performance tests that had been conducted in Ontario to evaluate this technology and its proposed application, or of any performance tests done elsewhere or by other agencies which the Ministry had reviewed
there are a number of fire hazards related to this technology, including risks of vaporized contaminants catching fire in the desorption unit; the vitrification of of solid waste into a large hot mass within the unit at certain temperatures, possibly causing a fire or explosion; ignition by sparks generated with the blade of the dozer contacts rocks during excavation or movement of waste materials with low flash points; and treatment of high BTU value waste feed, which can result in a fire or explosion. These fire hazards are extremely significant, given the on-site storage of large volumes of liquid PCBs and PCB contaminated wastes.
thermal desorption is not applicable or appropriate where there are metals in the soil; the presence of metals may complicate the offgas treatment
the U.S. EPA has identified concerns with emissions of dioxins, furans and mercury, and have concluded that thermal desorption of mercury contaminated waste is not appropriate
it appears that TCI intends to rely largely on the soil analysis provided by the waste generator; given that the effectiveness – and safety – of the thermal desorption process relies on a thorough and detailed understanding of the waste stream, a careful management of the waste stream, and an adjustment of treatment times and possibly temperatures in response to variations in the waste stream, the approach proposed by TCI is inadequate at best, and almost certainly reckless

Assessment under the EAA

The thermal desorption unit proposed by TCI for their Kirkland Lake facility is a new project. While it will occupy the same property as TCI’s current property and will be owned by the same company, and is expected to have some of the same environmental hazards associated with it (fugitive and permitted release of contaminants into the environment), it is a new project, and one which is not reliant on the current operation. It will have its own building, its own stack for air discharges, its own water discharge. It is also a different project in that it uses a new technology, involves new and different waste streams, will result in new and different discharges to air and water. As such, the thermal desorption unit proposed by TCI should be assessed as a new project and designated as such under the Environmental Assessment Act for a full review.

On March 12th, the Ministry of the Environment proposal to designate the project under the Environmental Assessment Act (EBR Registry Number), based on their review of the requests that the project be so designated. We support the Ministry’s recommendation, and the reasons provided, including:

It is a major undertaking (treating 977 tonnes/day at capacity) using new technology.
TCI may not be able to clean the contaminated soil to background levels in which case, TCI may trigger the 200 tonne/day threshold for hazardous waste processing/transfer facilities. It has been ministry practice to designate under the EAA hazardous waste processing/transfer facilities that produce more than 200 tonnes/day of residual waste.
There is the potential for significant negative environmental effects including: air emissions, potential impacts of additional trucks along haul routes, bio-accumulation of contaminants in plants, water and soil, potential cumulative effects of this facility relative to similar facilities in the area, safety and emergency preparedness.
The preferred site is located within 500 m of a residential area which is closer than the 1500 m separation recommended in the CCME guideline for hazardous waste incinerators. While not considered an incinerator, this facility may generate air emissions similar to incinerators, and therefore should follow the recommended separation distances of the CCME guideline.
The potential social/economic effects of the proposal on the residential area need to be assessed under the EAA.
Other legislation can address a number of issues, but none can fully address the potential environmental effects of the proposed undertaking.
There has not been an adequate examination by TCI of alternative technology for hazardous waste processing and alternative pollution control systems for the exhaust stack.
Designation under the EAA will allow the proponent to engage in meaningful public consultation and to address the above issues. The EA process allows the public to appeal to the Minister if their concerns are not adequately addressed.

We support the above stated reasons, as provided in EBR Posting RA02E0005, and fully support the proposal to designate the TCI expansion, along with the existing operation, for a full environmental assessment.

Summary

Trans-Cycle Industry is proposing to establish a new project in Kirkland Lake which would result in the import of large volumes of hazardous materials into the area, for treatment of PCBs and other contaminants using a thermal desorption unit. There are a number of serious concerns related to this project, some of which have been summarized above. In view of the number of uncertainties and concerns, the project should be designated for an individual environmental assessment under the Environmental Assessment Act. The assessment should include an examination of need, alternatives to the undertaking, alternative technologies, and cumuliative effects of TCI’s operations in Kirkland Lake, including their existing operation – which has not yet been subject to an environmental assessment and which has exhibited numerous operational and health, safety and environmental problems – and the proposed thermal desorption unit.

Thank you for this opportunity to comment. We look forward to receiving a positive response to this request, and would be pleased to provide any clarification of our views or concerns, should that be of assistance to the Ministry or Minister in the course of arriving at a favourable conclusion.

Yours,

Brennain Lloyd
Northwatch

cc. Hon. Elizabeth Witmer, Minister of the Environment
Mr. Gord Miller, Commissioner of the Environment
Mr. Paul Muldoon, Canadian Environmental Law Association

ENDNOTES
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PCBs in Kirkland Lake: Backgrounder on TransCycle Industries and Proposed Expansion

TCI Wants to Expand its Operations

In March 2001, TCI submitted applications to the Ministry of the Environment to amend its operating permits for the Kirkland Lake operation. The amendments will allow TCI to add a “new non-incineration technology referred to as the continuous thermal desorption unit process”. The application summary states that the “unit decontaminates soils, sludge and debris contaminated with chlorinated organics and non-chlorinated organics. After treatment, a minor contaminated residual sludge remains to be transferred off-site for final destruction. Facility emissions to atmosphere are from a carbon column stack serving an existing degreasing operation, a boiler stack providing heat for the above degreasing operation, a continuous thermal desorption unit (CTDU) stack and CTDU natural gas stacks” . TCI is also proposing “an increase in the receiving and storage capacity at the facility to include soils and sludge; approval to expand waste receiving categories to include chlorinated organic and non-chlorinated organic waste soils and sludge; and expand existing site area due to acquisition of adjacent lands”.

TCI’s Proposal will Harm the Environment

TCI is proposing to import soil, sludge and debris contaminated with chlorinated organic and non- chlorinated compounds such as PCBs, PCP, PCDF, PAH, CDD, TCE, hydrocarbons, creosote, pesticides, herbicides, wood preservatives, fungicides, and other organic compounds. Each and all of these substances are recognized as harmful to human health and to the natural environment. Many of these substances are known carcinogens, are directly related to a number of reproductive, health and development concerns, and are considered to be harmful at even very low levels of exposure, ie there is no safe level of exposure. Some of these contaminants will be released as a result of the CTDU process, and some of the contaminants will remain in the treated soil, which TCI intends to keep on-site for an indefinite period of time. In addition, there are risks of accidental release while transporting the wastes through Timiskaming, and a relatively high risk of release of contaminants – above those anticipated – throughout the operating lifetime of the facility, due to process and technical failures.

Use of Thermal Desorption

Thermal desorption uses heat to physically separate contaminants from soil. The contaminants then require further treatment. Thermal desorption is a technology that treats soils contaminated with hazardous wastes by heating soils so that contaminants with low boiling points will vaporize, turning into gas, which causes them to separate from the soil. The vaporized contaminants are then condensed and collected for treatment. Thermal desorption units have been used elsewhere for the treatment of wastes on-site, but there are few if any cases of the technology being used to treat a wide range of wastes shipped to a single facility, such as TCI is proposing. The equipment TCI is proposing to use at their Kirkland Lake site was purchased from the U.S. Army after being used to treat contaminated soils and sludges at an abandoned wood treatment facility in Hollywood, Maryland.

Other concerns with the TCI proposal include:

there are a number of fire hazards related to this technology, including risks of vaporized contaminants catching fire in the desorption unit; the vitrification of of solid waste into a large hot mass within the unit at certain temperatures, possibly causing a fire or explosion; ignition by sparks generated with the blade of the dozer contacts rocks during excavation or movement of waste materials with low flash points; and treatment of high BTU value waste feed, which can result in a fire or explosion. These fire hazards are extremely significant, given the on-site storage of large volumes of liquid PCBs and PCB contaminated wastes.
thermal desorption is not applicable or appropriate where there are metals in the soil; the presence of metals may complicate the offgas treatment
the U.S. EPA has identified concerns with emissions of dioxins, furans and mercury, and have concluded that thermal desorption of mercury contaminated waste is not appropriate
it appears that TCI intends to rely largely on the soil analysis provided by the waste generator; given that the effectiveness – and safety – of the thermal desorption process relies on a thorough and detailed understanding of the waste stream, a careful management of the waste stream, and an adjustment of treatment times and possibly temperatures in response to variations in the waste stream, the approach proposed by TCI is inadequate at best, and almost certainly reckless

Full Environmental Assessment Needed

Toxics – Northwatch Archives for 2001 to 2005

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