Standards

Overall, we are concerned that unsafe levels of harmful substances are being released into the air, water and onto the land from Northern Pulp.

In their discussion of the health effects of pulp mill emissions, Soskolne and Sieswerda (2010) stated,  “given the known hazards and the potential for both environmental and human exposure by any of a number of pathways, vigilance on the part of governments for regulation and for ongoing workplace and environmental monitoring remains a health imperative.”

Yet, there has been strong criticism of federal regulation in Canada.  Tilman (2008) has prepared a comprehensive argument of federal government negligence in identifying and enforcing pollution standards with respect to the pulp and paper industry.  Generally, our group is concerned that the current standards may be insufficient, particularly in light of the apparent lack of enforcement of regulations.

Thus, our specific concerns have been separated into

i) concerns about the standards themselves and
ii) concerns about monitoring and enforcement.

Our specific concerns about standards are as follows:

1. The National Pollutant Release Inventory (NPRI), maintained by Environment Canada, provides an online searchable database of self-reported emissions from every pulp and paper mill in Canada. Using these values, one can theoretically identify what our mill is emitting into the environment. However, the accuracy of reports published by NPRI are questionable for a number of reasons, not the least of which is that direct measurement of emissions in not a part of the process.  Instead, most values reported to NPRI by Northern Pulp have been determined based on calculated estimates as indicated by an ‘E2’ designation.  Specifically, Tilman (2008)identified the following issues with NPRI standards:

“Several issues related to data quality, reporting thresholds, ease of public use, coverage of pollutants etc. need to be addressed. Above all, the lack of directly measured data or for that matter, any requirement that data be directly measured, is a very serious hindrance to developing and enforcing any policy or regulation that can only be based on accurate data. Only 31 of the 83 CEPA-toxic substances are even listed on the NPRI.” (p.55)

 

2. We have a letter from the NS Department of the Environment (DOE) that states that biomass from the Boat Harbour treatment facility is being burned (see attached ‘Department of the Environment biomass.pdf’ – PDF coming soon!).  Although this letter is undated, it appears to have been written in late 2009 or early 2010. Mr. Don Breen from Northern Pulp has stated that the biomass is not being burned at the Northern Pulp facility, but instead is being spread on mill property (Brannen, 2013).

Either of these options is a concern because:

– The sediment at Boat Harbour would contain decades worth of toxic chemicals as many are non-biodegradable.  In fact, “repeated tests have shown the sediments contain some of the most toxic chemicals known to science: dioxins, furans, mercury and cadmium.” (University of Kings College Jounalism Students, 2009)

– There are numerous unresolved questions about burning such biomass and there are currently no standards for this practice  (http://www.awf.com/pdf/Pulp_Mill_Sludge8_06.pdf)

– If the biomass was burned as NS DOE stated, it was burned at a time when there was no functioning scrubber on the power boiler (discussed in Monitoring and Enforcement).  Therefore, we wonder if the emissions values calculated and reported to NPRI account for the lack of scrubber and what those emissions would actually entail if they were directly measured.

– If the biomass is being spread on vegetation on mill property as Mr. Breen stated, does this mean that it is being spread on seedlings that will eventually be transplanted into our forests?

3. The NS Department of the Environment has policies for industrial landfills http://www.gov.ns.ca/nse/dept/docs.policy/Guidelines-Industrial.Landfill.pdf yet it remains unclear how those regulations apply to NP with respect to spreading biomass on site and also with respect to asbestos disposal. Mill employees have anonymously identified to us that asbestos has been improperly discarded on mill properly and that the biomass from Boat Harbour is being dumped on top of the asbestos.  This has not been confirmed, but the report certainly raises questions about which standards apply to Northern Pulp and how they might be enforced.

Condition 14(f) of the attached ‘Timelines for terms and conditions of industrial approval.pdf’ (PDF coming soon) provided to a journalist in April 2011 does indicate that Northern Pulp was required to and did provide confirmation that ‘Asbestos Disposal area Meets 14’, but it is unclear what kind of confirmation was required and provided (i.e. Was it a self-reported confirmation or an independent inspector that verified compliance?).  Our insiders reported open discarding of asbestos on site after the date of this report.

4. ‘Treated’ effluent is ultimately deposited in the Northumberland Strait.  McMaster, Hewitt and Parrott (2006) reviewed a decade of Canadian research on pulp mill effluent effects on fish and concluded that after two cycles of the Environmental Effects Monitoring program, pulp mill effluent still had affected local receiving environments.  And, as mentioned elsewhere, at the end of cycle 4 of the program, almost 70% of Canada’s pulp and paper mills’ effluent still had confirmed biological effects on fish, fish habitat and some fisheries resources (Environment Canada, 2012).

Furthermore, the mill tends to dismiss questions about the brown water that emerges by explaining that the discoloration is a natural output from the bleaching process referred to lignins.  Academic inquiry into these outputs supports those claims made by the mill, but there is evidence to suggest that while naturally occurring, lignins are not harmless. Specifically, the dark brown color suppresses photosynthesis, directly and negatively affects the aquatic ecosystem and other consumers within the food chain, and contributes to algal blooms.  Further, Schnell et al (2000) stated, “The toxic effects of these compounds are diverse and deleterious to the general human health and can cause severe metabolic aberration.”

There appear to be no standards for lignins in treated effluent discharged into open water and in light of this evidence, benchmarks should likely be employed.  And, while there do appear to be standards and monitoring of pulp mill treated effluent discharges, they are not reported at the facility level and a number of questions remain.

 

Outstanding questions on treated effluent release monitoring include:

– What are the standards for emissions to local receiving environments?
– Is there public access to EEM reports?
– What specific kind of testing is being conducted in the Northumberland Strait where treated effluent is released?
– What substance concentrations are being tested?
– Is this a comprehensive list of harmful substances?
– Are the tests independent?
– Why are fines not issued to pulp mills for polluting waterways similar to the attached example? (See attachment – ‘Environment Canada fines other company for polluting waterways.pdf’.)