Summary of Expert Qualifications & Conclusions
This is a summary of the expert’s report prepared for the Clean Environment Commission (CEC), by The Boreal Forest Network and the Concerned Citizens of the Valley, on the Louisiana Pacific application to remove the RTO pollution controls from their license. The CEC concluded that it was alright for LP to operate without controlling emissions and allowed them to increase the toxics coming out of the Swan Valley plant. The groups have launched an appeal.
Dr. Charles Simon – Dr. Simon was retained to discuss the level of hazardous air pollutant (HAP) and volatile organic compound (VOC) emissions from the flake dryers and board presses at LP Swan Valley with and without the operation of the RTOs to treat emissions. He was also asked to consider alternatives, if any, to the LP proposal.
Dr. Simon holds a Doctor of Philosophy degree in Physical Chemistry from the University of Florida. For the last 15 years, Dr. Simon has provided technical consulting services to the United States Environmental Protection Agency’s Office of Enforcement and Compliance Assurance (USEPA-OECA), the US Department of Justice Environmental and Natural Resource Division (USDOJ-ENRD), and the Ontario Ministry of the Environment (MOE). Dr. Simon has interacted extensively with forest product industry representatives, as well as consulted extensively with EPA personnel responsible for publication of panel board facility emission factors, and EPA personnel working to develop the plywood and composite wood products National Emission Standards for Hazardous Air Pollutants (PCWP-NESHAP) utilizing Maximum Available Control Technology (MACT).
Dr. Simon’s conclusions:
Instead of replacing or refurbishing the RTOs, LP is requesting the Manitoban Government to allow a permanent 33-fold increase in actual VOC emissions from the dryers and press at the Swan Valley mill, from about 25 tons per year (tpy) with properly operating RTO controls, to 825 tpy when operating only wet electrostatic precipitators. (Based on testing their new dryers and press in 2006, actual VOC mass emissions can be expected to be greater than 1,100 tons per year.) The LP request of the Manitoban Government will also allow a 100-fold increase in actual emissions of hazardous air pollutants from the dryers and press, from about 4 tpy with properly operating RTO controls, to over 400 tpy when operating only wet electrostatic precipitators.
It is understandable in the recent economic environment that LP would propose to eliminate controls for VOC and HAP emissions from the flake dryers and board press at the Swan Valley OSB mill. Like all other industries in Canada and the United States, LP management has a fiduciary responsibility within the laws and regulations where it operates to seek maximum profits and sustainability for its owners, its principals, its employees and its shareholders.
In my experience with forest products companies, the strong motivation to externalize air pollutant costs can only be overcome by regulation.
In the United States LP OSB flake dryers and board presses are required to use best available control technologies to control VOC and organic HAP emissions.
A modern bioreactor may be able to perform as Best Available Control Technology at Swan River for less than the cost of replacing the RTOs, and about one-fourth of the cost of operating the RTOs and WESPs.
A modern bioreactor may be able to replace the existing wet electrostatic precipitators (WESPs) at Swan River for control of particulate matter emissions. If this is possible, it would be cheaper to operate the modern bioreactor than to operate the WESPs, and the cost of operating the RTOs would be eliminated along with their carbon dioxide and nitrogen oxide emissions.
LP-Swan River should be required to obtain bids from one or more modern bioreactor vendors with the intention of installing one or more units to control dryer and press emissions.
Dr. Gordon Brown – Dr. Gordon Brown of Intrinsik Environmental Sciences Inc was asked to conduct a peer review of the application with a focus on potential human health risks associated with decommissioning the RTOs. Dr. Brown has a PhD in Environmental Science. He has an extensive track record of conducting best practice human health risk assessments for both industry and government.
Dr. Brown’s general comment is that the human risk calculations provided by Louisiana Pacific do not represent current accepted practice for human health risk assessment in Canada and the US.
Dr. Brown made several specific conclusions:
Ambient air quality monitoring locations were improperly placed.
Background air concentrations were not added to modelled OSB mill predictions. This results in cumulative ground-level air concentrations being underestimated, which means that many of the conclusions regarding “negligible health risks” made by LP are not valid.
Incremental health risk increases could not be quantified due to lack of an appropriate and current “base case” with RTOs operating. In order to properly assess the incremental health risks posed by the decommissioning of the RTOs at the LP OSB mill, ground-level air concentrations and associated health risk
calculations (including background) should be provided at the present time using similar assessment models and methods for both (i) the existing case and (ii) the amended case for which LP is applying. This was not done, only the amended case without RTOs was presented.
Risk estimates were not generated for nearby human receptor locations.
The potential for odour generation, which can generate health concerns, was not assessed.
A scientific rationale was not provided for the exposure limits that were assumed, some of which may be inappropriate. The exposure limits used by LP were typically not Health Canada limits and were frequently not the most “stringent” of the available limits.
Inclusion of country food and water ingestion pathways would likely provide additional predicted health risks, but were not assessed. The LP reports only address the potential health risks associated with the “inhalation exposure
pathway”. Non-volatile chemicals can be deposited in the local environment and may accumulate in soils, vegetation, fish and wildlife.
Mr. David Chadder – Mr. Chadder of RWDI Air Inc. (RWDI) was retained to conduct a peer review of a number of documents produced by Louisiana Pacific. He was asked to provide an expert opinion with regard to their technical merit from an air quality standpoint. Mr. Chadder is Vice President, Western Operations and Project Director at RWDI. His experience in environmental consulting dates to 1978. Mr. Chadder’s area of specialty as Project Director involves the technical supervision of engineering teams involved with air quality, hazard and risk assessments, stack emissions testing and ambient air quality monitoring studies.
Mr. Chadder’s general comment is that the air quality impacts have not been properly documented or accounted for by Louisiana Pacific.
In particular, Mr. Chadder concluded that Louisiana Pacific has failed to:
Meet the minimum industry submission requirements and/or those detailed in the Manitoba Conservation Draft Guidelines for Air Dispersion Modelling in Manitoba;
Account for all of the hazardous contaminants of interest in their normal maximum plant emissions;
Include all types of emissions sources such as fugitives in their dispersion modelling;
Complete a cumulative impact assessment that properly accounts for and includes background ambient measurements in their predictions; and
Consider potential nuisance odour impacts from the emitted contaminants.