Comments on the Amended Pope and Talbot Permit

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:

CO14.52from provincial inventory 2000

NOx72.68from provincial inventory 2000

SOx0.43from provincial inventory 2000

VOC50.0from NPRI submission

TSP62.0from MoE monitoring data 2006

PM 1054.0from MoE monitoring data 2006

PM 2.534.0from 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:

CO30.78

NOx18.11

SOx1.25

VOC2.25

TSP0.77

PM 100.77

PM 2.50.72

CO22111.4

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