COSCO Presentation to the Town of Gibsons on the HSPP Mill Permit Amendment Application to Allow Burning of Construction and Demolition Waste
The Council of Senior Citizens Organizations (COSCO) Sunshine Coast Branch seeks the support of Gibsons Council in prohibiting or limiting the Howe Sound Pulp and Paper (HSPP) mill from burning certain toxic materials. The amended permit requested by HSPP must specify these prohibitions and limitations explicitly. COSCO believes that a letter from the town to the Ministry of the Environment (MoE) would be most helpful.
Background on Waste Burning
Early in 2009 a Coast Reporter article indicated that the HSPP mill had been burning construction and demolition (C&D) waste including plastics for about three years. MoE had become aware of the practice in December of 2008 and began an investigation. Eventually in October 2009 MoE issued a Variance Order valid for up to a two years allowing the mill to burn one barge (5200 cubic metres) per week of C&D waste. The order specified a strict regime of emission sampling and monitoring during the period as well as an air shed modelling program. Reports and public consultations were also specified. Near the end of September 2010 HSPP held public open houses in Gibsons and Squamish as required by the variance order.
Background on Coal Burning
It’s important to note that the mill’s managers have behaved very badly with respect to their permit over the last few years. The first coal burning trial started without any consultation with MoE in late 2006. Subsequent trials occurred in the spring and in the fall of 2007.
The mill’s managers contended that because their permit was silent on burning coal, it was not prohibited. A document entitled Cronology of Events posted by MoE in October 2007 outlines the tainted interactions between the mill managers and MoE regarding these trials. Data to be provided were withheld by HSPP even after these were requested. Additionally, the mill stated that it would not collect certain data requested by MoE for the proposed fall trial. MoE also asked management not to resume a fall trial until public concerns were addressed and an amended permit was issued. The mill responded that a new coal burning trial would start in late October 2007, and it actually began on October 16th.
An Initial Review of the March 2007 trial posted on the web by MoE confirmed that extra Sulphur and Nitrogen Oxides, and heavy metals resulted from the coal burning. Simple calculations also indicate that an additional 35,000 tons per year of CO2 would be released into the atmosphere. Throughout the trials Mr. Strang, the mill’s Environmental Manager, continued to assert that no significant additional emissions would result from the trials, and that as a citizen of the Sunshine Coast he was as concerned as anyone with healthy air and climate change.
MoE finally prohibited any further coal burning with an amended permit in December 2007. HSPP filed a “stay” on the amended permit with the BC Environmental Appeal Board (EAB) pending a full appeal of the new permit. The mill managers claimed that the mill would have to shut down if it could not burn coal. The EAB turned down the stay and HSPP subsequently dropped its appeal entirely.
The AEB’s written decision on the stay was quite exhaustive and pointed out the importance of community opposition to the practice of coal burning. We believe that the Howe Sound Community Forum memo sent to the Environmental Protection Manager of MoE in Surrey in November, 2009 played a significant role in that decision.
Results after Burning C&D Waste One Year
The open house held by HSPP in Gibsons on September 22 was well organized with large posters and glossy handouts. Informed experts from Leveltron Consultants Ltd. and from MoE were on hand to help interpret the results of the trial of the C&D waste burning and the modelling conducted by the consultants. The C&D waste during the trial consisted of 91% wood; 7% pressboard and plywood; 1% paper, fabric and formica; and 1% plastic and vinyl.
Minimum Requirements for the Amended Permit
COSCO wrote an article after the open house to indicate that our communities in Howe Sound could be reasonably assured of their safety from any potentially hazardous emissions from the C&D burning provided that a limited number of conditions were met. Our article urged MoE to ensure that the following conditions were implemented as part of their new amended permit:
- Install independent monitoring of potentially hazardous emissions in Gibsons;
- prohibit the burning of treated woods, painted wood, asbestos, railway ties and old tires;
- specify a maximum amount of plastics (1-2%) and a maximum amounts of plywood or pressboard (5-7%) to be burned;
- include asbestos in the monitoring regime;
- specify a new monitoring protocol with dioxins and furans measured on a quarterly rather than an annual basis, and also specify the monitoring PM2.5 instead of PM10; and
- order a new modelling trial to be conducted once the upgraded boilers have been installed.
Submitted by Louis Legal