Enter content here

Enter content here

Enter content here

Part I

ERG REPORT Volume 2, No 1, Autumn 2002


The following is a compilation of correspondence and summary of meetings, listed in reverse chronological order, related to the Steam Reformer at Norampac in Trenton.

We became interested in this matter when in August 2001 it was reported that the manager of Norampac had announced that their new Steam Reformer, now under construction in Trenton, would process not only pulp liquor waste but also general waste including hazardous waste. The company has since withdrawn from that position and to date a Certificate of Approval has only been issued by the MoE for treatment of pulp liquor waste at the facility. In an unusual move the MoE also simultaneously issued to Norampac a CoA for biodegradation of the pulp liquor waste as a backup system apparently to be used in the event of the failure of the Reformer system.

Quinte Watershed Cleanup
P.O. Box 20069
Belleville, ON
K8N 5V1
Tel: 613-394-3915 ext. 13
Fax: 613-394-5226
E-mail: communication@bqrap.ca

November 1, 2002

Honourable Elizabeth Witmer File No 75633
Deputy Premier, Government of Ontario
Queen's Park
Toronto, Ontario

Re: Reformation at Norampac

Dear Madame Minister,

Thank you for your letter of February 18, 2002 in which you called for a meeting between our group, Quinte Watershed Cleanup Inc and your MoE officials in the matter of the Trenton Steam Reformer.

This meeting took place on Wednesday October 30 from 2:00 to 5:00 pm at the MoE office in Belleville. It was chaired by Mr. John Tooley, the local MoE manager, and was attended by Mr. Steve Klose, Manager of the Certificate of Approval Review Section of the Environmental Assessment and Approvals Branch; Mr. Dennis Maftei and Ms. Quynh Nguyen , engineers from the Approvals Branch; Mr. Brian Hancock, manager of the Peterborough office of the MoE (in place of Mr. Brian Ward of the Kingston MoE office who was not able to attend.)

Our group was represented by A. Goddard-Hill, MD , Eastern Lake Ontario Environmental Research Group; Mr. Manfred Koechlin, chairman of Quinte Watershed Cleanup Inc; Mr. Steve Medd , geologist, and member of the (Richmond Landfill) Committee of Concerned Citizens; Mr. Terry Cassidy, elected Counsellor with the City of Quinte West; Dr. Paul Connett, chemist from St. Lawrence University in Canton , New York.

The meeting was interesting.

The questions that we put in advance to your officials were:

1. Given the evidence (provided in transcript and video format) from the Trenton November forum and the European Community, does the MoE now acknowledge that the facility is a type of incinerator?

2. The Minister has stated that the facility was "thoroughly assessed" by ministry staff. Where is the data and evidence to support this? In particular as the facility is ultimately designed to eliminate dioxins from pulp waste where is the data with respect to dioxin emissions?

3. Does the MoE still believe that the collection of a single data point for emissions will satisfy the Minister's undertaking that the facility will be "closely monitored".

The answers which we received were approximately as follows:

1. Prior to this meeting the MoE's position was emphatically that the Reformer is not a type of incinerator. After being presented with our evidence the MoE officials changed their position insofar as they now declined to give a direct answer to the question.

2. It appears that although the engineering aspects of the Reformer may have been "thoroughly assessed" by the MoE staff, the public health implications were not.

In the first instance the Reformer was revealed to be an experimental unit for which no equivalent pilot project exists anywhere in the world. MoE officials confirmed that there is literally no data in existence on dioxin emissions for this facility. Dioxins are the very chemicals that the facility has been built to eliminate from waste pulp liquor.

Further it seems the MoE methodology for monitoring dioxin and furan emissions from incinerators is some 17 years out of date inasmuch as their method fails to account for the post combustion formation of dioxins predicted to occur in the combustion boiler of the Reformer. Ironically this phenomenon was first described by a chemist with the Ontario MoE in 1985 but has not been allowed for in current Ontario stack monitoring methods.

When canvassed individually, MoE officials each expressed complete satisfaction with the current stack monitoring methodology for dioxin measurement. However when presented with recent data from the Canadian Food Inspection Agency which reportedly found levels of dioxins (referred to by CFIA as "carcinogens" that have as their source waste incineration and chlorine based industries ) in Canadian foods at some 10 times over acceptable levels, MoE officials could not reconcile their confidence in their dioxin monitoring methods with the apparent continuing contamination of Canadian foods.

3. The "single sample" referred to by Mr. Ward was clarified to mean the collection of 3 separate 6 hour stack samples in one day, done annually during the life of the Reformer.

Our group presented evidence that this method is outdated, having been shown to underestimate actual dioxin emissions by a factor of 50 if compared to a 2 week continuous sampling method which is currently being used in Europe.

Our group recommends that the MoE consider adopting this 2 week sampling method.

Madame Deputy Premier, we thank you again for arranging this meeting.

It seems that long term health effects may potentially accrue in our region from this experimental project if adequate monitoring methods are not implemented.

We ask you to take up our suggestions with the MoE staff in order to move forward in the protection of the public health in Eastern Ontario.

You will find a complete summary of the correspondence on this matter dating back to last August at website www.salu.net/gh, under the ERG Report, Volume 2, No 1, Autumn 2002.

Sincerely yours,

Terry Cassidy
Counsellor, City of Quinte West

A. C. Goddard-Hill, B.Sc, M.D
Director, Eastern Lake Ontario Environmental Research Group

Manfred Koechlin
Chairman, Quinte Watershed Cleanup

Stephen Medd, geologist
Member, (Richmond Landfill) Committee of Concerned Citizens

cc. Honourable Chris Stockwell, Minister of Environment

P. W. Munt, Chief, Division of Respiratory Medicine, Queen's University and
Kingston General Hospital
Mr. Brian Ward, MoE Eastern Region Director
Mr. Steve Klose, MoE Approvals Branch


The Globe and Mail
September 16, 2002 (TRANSCRIBED FACSIMILE)


By Rheal Seguin, Quebec

An alarming level of carcinogens has been found in food sold in Canada, according to a study conducted by the Canadian Food Inspections Agency to be released next month.
A copy of the report, obtained by the Montreal daily La Presse, shows furans, dioxins, and PCBs present in abnormally high levels in samples of foods such as beef, pork, eggs and cheese.

The presence of toxic agents can be traced throughout the food chain. The source of pollutants found in air, water and plants has been traced to waste incinerators and manufacturing industries that use high levels of chlorine. The contamination is then passed on to humans. The study notes that once the toxic agents enter the human body they weaken the immune system and can cause tumours.

Hundreds of food samples tested showed the presence of toxic agents eight times out of ten. Dioxins, some of the most dangerous substances, were present in various degrees in most samples.

The standard measurement set by the World Health Organization allows for a maximum 5 picograms of toxic agents (or 5 parts per trillion) per gram of fat in foods, at which point they should be withdrawn from the market. According to the study, levels as high as 53 picograms of dioxins were found in pork samples, 20 in Canadian eggs, 23 in beef and 12 in cheese.

The study examines various food samples throughout 2001 and was completed earlier this year. When compared with studies conducted in the European Community, eggs from the US and beef produced in Canada were far more contaminated than those tested in Europe. Canadian poultry was found to have the lowest levels of toxic agents, with levels of dioxins two or three times lower than those in Europe.


A. C. Goddard-Hill
Belleville, Ontario

June 12, 2002

Mr. John Tooley, District Supervisor
Belleville Area Office, Eastern Region
Ministry of Environment & Energy
Bayview Mall
Belleville, Ontario

Re: Meeting with MoEE, discussion of Pulse Enhanced Steam Reformer

Dear Mr. Tooley,

Thank you for your letter of May 29.

Our questions are:

1. Given the evidence (enclosed in transcript and video format) from the Trenton November forum and the European Community, does the MoE now acknowledge that the facility is a type of incinerator?

2. The Minister has stated that the facility was "thoroughly assessed" by ministry staff. Where is the data and evidence to support this? In particular as the facility is ultimately designed to eliminate dioxins from pulp waste where is the data with respect to dioxin emissions?

3. Does the MoEE still believe that the collection of a single data point for emissions will satisfy the Minister's undertaking that the facility will be "closely monitored".

As noted, video and written material is enclosed. This material is the exclusive property of Quinte Watershed Cleanup Inc. If the MoEE wishes to purchase the material the price is $1000. Videotape of the other part of the Trenton forum meeting which dealt with Zero Waste is available for an equal amount.

As indicated in the Minister's letter, we expect that Mr. Klose and Mr. Ward will be in attendance. Dr. Paul Connett will be invited.

The preferred time for a meeting would be a Wednesday afternoon. Please suggest some alternate dates.

Sincerely yours,
A. C. Goddard-Hill


Ministry of Environment (TRANSCRIBED FACSIMILE)
Office of the Minister
135 St. Clair Ave West, 12th floor
Toronto ON M4V 1P5
File No 75633
February 18, 2002

A. C. Goddard-Hill, MD

Dear Dr. Goddard-Hill:

Thank you for you letter of January 21, 2002 regarding the ministry's assessment of the steam reformer Norampac intends to use to eliminate Dombind as a dust suppressant.

I understand that your source of information believes the steam-reformer technology should be classified as an "incinerator", contrary to the opinion of ministry staff. In an effort to resolve this difference of interpretation, I have asked Mr. Steve Klose, Manager of Certificate of Approval Review Section with the ministry's Environmental Assessment and Approvals Branch, and Mr. Brian Ward, Director of our Eastern Region, together with the appropriate staff members, to meet with you to hear your concerns.

I would ask that you contact Mr. Ward at 613 548 6901 to arrange the meeting at your convenience.

I trust this meeting will resolve the matter.



Elizabeth Witmer, MPP

A.C. Goddard-Hill
Belleville, Ontario

January 21, 2002

Honourable Elizabeth Witmer
Minister of Environment, Government of Ontario
135 St. Clair Ave West, 12th Floor
Toronto, Ontario M4V 1P5

Re: Reformation at Norampac

Dear Madame Minister,

Thank you very much for your reply of January 11 to my letter of December 1 on the matter of the MoE and the Norampac Steam Reformer.

Both the proponent and the MoE have vigourously denied that the Reformer is a kind of incinerator. Apparently from a regulatory point of view this is an important issue. In his letter of September 14 Mr. Michael Williams, Director of Standards & Approvals, MoE states that "Should the process involve incineration, a hearing before the Environmental Review Tribunal would be required before approval could be provided."

We now have evidence from a credible American academic who participated in the Trenton November Forum. He indicated that the facility should be classified as an incinerator. This opinion is consistent with a European Parliament directive of December 2000 which states that an " 'incineration plant' includes other thermal treatment processes such as pyrolysis, gasification or plasma processes insofar as the substances resulting from the treatment are subsequently incinerated".

With respect to your comment about the non attendance of the MoE at the citizen's forum there was never any "agreement" with QWC that written answers to a few questions would be an acceptable alternative. I first broached the subject of holding a public forum with our local MoE official on September 13. He immediately made it clear that such an event was completely unnecessary and that under no circumstances would MoE be represented. Subsequent events bore him out only in the matter of MoE (and proponent) non attendance. The forum itself was very productive.

You assert that the Reformer technology had been "thoroughly assessed by ministry staff". Evidence received at the Trenton November Forum was to the contrary. Both the proponent and the MoE claim that emissions from the facility will be safe. However what is quite stunning about this case is that no scientific data has been presented in support of this claim.
In particular in the matter of dioxin emissions, the very chemicals that the facility is supposed to eliminate, there has been no data presented.

The inference is that none exists.

You note that "the operation will be closely monitored". However, and almost unbelievably, the MoE's proposal for monitoring is to take a single stack sample when the $30 million facility, currently under construction, is completed. If judged acceptable this will be deemed by the MoE to be sufficient sampling for the life of the facility.

Madame Minister, if this case is an example of the state of environmental regulation of chemical emissions from waste management facilities in the Province of Ontario then we have reached an appalling juncture. Unfortunately this instance is only one of a half dozen examples in our area which suggest a pattern of practice on the part of the MoE over the past half dozen years.

Your Ministry officials, having recused themselves from attendance at the November Forum, have made no effort to date to review the received evidence from that meeting. I request that they do so at the earliest opportunity.

Further, I now formally request that you conduct a review of the regulatory process as it was applied to the granting of a Certificate of Approval for the Norampac facility. It appears to have been completely inadequate. If left unchallenged such dysregulation will only be perpetuated.

We at Quinte Watershed Cleanup Inc would then like to meet with you and your officials to review what can be learned from this matter for the benefit of the citizens of Ontario.

Sincerely yours,
A.C. Goddard-Hill

cc. Mr. Brian Ward, Director, Eastern Region, MoE
Dr. P. W. Munt, Chief of Staff, Kingston General Hospital; Director of
Respiratory Medicine, Queen's University at Kingston
Mr. Justice Dennis O'Connor, Walkerton Commission


Minister of Environment (TRANSCRIBED FACSIMILE)
Office of the Minister
135 St. Clair Ave West, 12th Floor
Toronto Ontario M4V 1P5

January 11, 2002

A. C. Goddard-Hill
Belleville, Ontario

Re: File Number 75292

Dear Dr. Goddard-Hill:

Thank you for your letter of December 1, 2001 and the interest you express in a number of environmental issues.

With respect to the November 28, 2001 public forum sponsored by the Quinte Watershed Clean-up, the primary individuals from the ministry had prior commitments and were unable to attend. I understand that this was agreed to by your associate Mr. Cassidy. I also understand that the questions you posed in writing were fully answered and provided at the meeting.

The Steam Reformer technology, although innovative and largely untested on a commercial scale for this use, was thoroughly assessed by ministry staff and it is Norampac's opinion that the technology will operate as designed and intended. The operation will be closely monitored and, if necessary, steps will be taken to correct problems.

I assure you that the Province views protection of the environment as a high priority and we will continue to promote initiatives to maintain our commitment.



Elizabeth Witmer, MPP


A. C. Goddard-Hill
Belleville, Ontario

December 1, 2001

Hon Elizabeth Witmer
Minister of Environment
Government of Ontario
Queen's Park
Toronto, Ontario

Dear Minister,

On the evening of November 28 a public forum was sponsored by Quinte Watershed Cleanup Inc, a local citizen's group, and held in Trenton/Quinte West, Ontario.

The hall was filled to capacity with citizens who came to hear about the new Steam Reformer which is currently being built by Norampac Inc to process hazardous pulp waste. They also heard about the concept of Zero Waste, a comprehensive approach to resource management which when implemented (as has been done now in a number of jurisdictions around the world) vastly reduces dependence on landfills and incineration for waste management.

The two participants in the evening's panel were Mr. Robert Argue, the founder of the current Quinte Waste Solutions high grade waste reduction program and an international waste management consultant, and Dr. Paul Connett, a university chemist from New York State and a proponent of the Zero Waste concept.

Although the proponent, Norampac, and the regulator, the MoE were repeatedly invited to attend in order to expand on the Steam Reformer technology their chairs remained empty that evening. Apparently neither party had the time or the interest to participate.

The significance of their absence was not lost upon the audience.

In reply to questions that we posed in a written format to the MoE prior to the forum I did receive written answers from Mr. John Tooley, the manager of the Belleville office, Mr. Brian Ward, the Eastern region MoE director, and Mr. Michael J. Williams, the director of the Standards Branch.

Their position with respect to the Steam Reformer was in essence that (a) it is not an incinerator, (b) that there is good evidence that it is environmentally safe and in particular will not produce any dioxin emissions, and that (c) once the $30 million dollar facility is complete and operational that one (1) air sample from the stack may be sufficient to verify the lack of emissions from the facility for all time.

We at QWC found all three of these assertions to be incredible. Therefore we organized the evening to allow all parties to discuss their positions in an open meeting.

Important evidence was obtained at the forum that all three assertions are wrong.

This evidence is now available in both videotape and in published format.

One of our major concerns is the proponent's stated intention of expanding the facility at a later date for treatment of general hazardous waste. One strong recommendation made at the forum was that ideally this should never happen, and certainly not without first conducting multiple continuous stack emissions tests and residue sampling in a way which allows valid conclusions to be drawn based on the principles of science.

Madame Minister, I am concerned that in Eastern Ontario there has lately been a pattern of practice on the part of the MoE that suggests that corporations are out of control in the matter of chemical pollution accruing from waste management methods.

I refer specifically to six corporations in the Bay of Quinte area namely Canadian Waste Services, Quinte Health Care Corporation, City of Belleville, Nortel Inc, Azurix Corp, Norampac Inc. and further afield in Eastern Ontario, Material Resources Recovery Inc in Cornwall. I would be pleased to provide you with details.

Environmental chemical pollution is an important matter. The public health significance of this type of pollution is just as important as (micro)biological pollution about which recently we have heard so much. Unlike biological pollution human health effects from chemicals are much more difficult if not impossible to track. This is because such effects are manifest over a much longer term and are often diverse and subtle but important. The medical literature has made this clear over the past decade.

The MoE's assessment of the Steam Reformer in Trenton is clearly inadequate and does not pass scientific scrutiny. This is a disappointing performance from a Ministry which previously enjoyed a sterling reputation for good scientific work. Although our local MoE people are first class individuals there are very few of them left and they have obviously been placed under tight political control by the current government.

Madame Minister, I make two requests:

First, will you please review what has transpired in the regulatory process as it has been exercised in the Trenton case and explain what is going on there.

Second, will you and your Ministry undertake to make a serious commitment to Zero Waste initiatives in this Province so that we may ultimately be rid of the injury that communities are sustaining as they continue to dance with the dual devils of incineration and landfilling in a failed attempt at effective resource and waste management.

Sincerely yours,
A. C. Goddard-Hill

Cc Brian Ward, Director, Eastern Region MoE
John Tooley, Manager, Belleville Office MoE
Mr. Michael J. Williams, Standards Branch MoE
Dr. P. W. Munt, Chief of Staff & Head of Division of Respiratory Medicine,
Kingston General Hospital
Zero Waste Web site: www.grrn.org

Prince Edward Safewater Group web site: www.safewatergroup.org

GH web sites: www.salu.net/gh



(The following is a transcription from a videotape of the portion of the meeting in which Dr. Paul Connett addresses the matter of the Steam Reformer. The earlier, and longer, portion of the meeting addressed the theme of Zero Waste, and included a presentation by Mr. Robert Argue and Dr. Connett. The panel chairs assigned to Norampac and the MoE remained empty.)

Paul Connett , Ph. D, Professor of Chemistry, St. Lawrence University, Canton New York, at Trenton, on the Norampac Steam Reformer Nov 2001. 15 min on videotape

(This is part of a speech given to an audience of a room full on people, approximately one hundred, in attendance at a meeting hall in Trenton . The earlier, and longer, part of the speech was devoted to the theme of Zero Waste)

"Now I 'd like to go over to this machine that you are considering here.

Now Alban here will confirm that when he first asked me about this I asked him what size he was talking about and he said 115 tons per day. I said what's the waste stream, he said paper pulp liquor. He then told me what they had been doing with that, dumping it into the Trent River for umpteen years, and then it , the gooey stuff, was spread as a dust suppressant on the roads and it did seem like the lesser of three evils, if you like.

And, I said , you know, don't sweat it.

Then the next thing that happened was that he found out that the company was talking about not only destroying this stuff, this pulp liquor, but also going to import all kinds of other kinds of waste, hazardous waste, medical waste, and all kinds of other waste to burn in this magic machine, in Excelsis.

Well first of all, (looking at the glossy binding) their material is pretty thin. ..confusing I have here the Trenton process schematic which shows an input of spent liquor, natural gas and air. Well that looks like a burner, if you are putting in air, gas and spent liquor.

Elsewhere the company talks about heating coils, electrical heating coils. And we've got a lot of semantics about this not being an incinerator (as he looks through the glossy binder provided by the company)..

Well let me describe for you a dual chamber incinerator.

The dual chamber incinerator in the first chamber heats the garbage up in a starved air mode, very little air. It heats the garbage up (as he holds out both hands spread side by side to illustrate the two chambers) and the object is to drive off the volatiles into a second chamber where it is burned. We call that an Incinerator.

Now is this place, I believe what is happening although as I say the evidence for this is very thin,we heat up the material, the liquor, drive off the volatiles, which they call Gas, and burn the gas in a boiler.

What's the difference between a dual chamber incinerator and what we've got here?

You're certainly burning here. You're burning the gases that you produce in Stage I, we call it stage I, you produce the gas, than in Stage 2 you burn the gas.

Now if life was as simple as what they are talking about and this gas only consisted of hydrogen and methane and CO carbon monoxide , which are typical materials , methane and hydrogen from a Pyrolysis unit, I haven't seen the word Pyrolysis (as he looks at the company literature) but we have so many companies offering this strategy, 'Pyrolysis, Gasification, It's not an incinerator'. The gases that come off get burned.

Now as I said if it was a simple as burning hydrogen or methane or CO, that would not be a problem in my view. However, what are the chances that the gaseous stuff that gets to the boiler is only hydrogen and methane and CO. I think that it's very small. And the way that you would tease that out.if you had some data.

There is no data here, we have no data. Some ministry official went down to Baltimore and saw something. We don't know what he saw. It was some pilot thing. But we have no data. We have no dioxin measurements which is a big issue here. But the question that I would have is if there is Chlorine in the waste stream, Chlorine is an element. Where is that element going to go to? It's not going to be destroyed. Is it going to be converted to Hydrogen Choride in the Pyrolysis stage , in the gasification stage, in the fluidized bed stage, and if it is what happens when you burn H Cl with anything contain Carbon, normally you get Dioxin. The critical question is where does the Chlorine go?

Secondly,and this becomes much more relevant if this machine is used to burn other waste streams, where do the Toxic Metals go to that are going to be in other waste streams, in medical waste, in hazardous waste, in municipal waste?

Where does the Mercury go to? Even at the relatively low temperatures of pyrolysis you are going to vaporize the Mercury. How do you capture the Mercury? Where does the mercury go?

So those are two technical questions that I would like to see the answers to.

Where does the chlorine go to, Ministry of Environment? (pauses and listens for answer, none is forthcoming). Oh, they're not here.

I seem to support the reverse tourist industry. Whenever I go to a community the people on the other side seem to leave town very rapidly. No matter how muchNo matter how much time you give them, they tend to be out of town, the experts. (Tying on neck tie with rubber chicken on the tie, audience laughter)

Let me explain why this is really important, I can't debate real people, Why I have to debate rubber chickens. This (the tie) is a waste reduction scheme, it saves real rubber chickens. I can now debate this rubber chicken. Ok. The Ministry of Environment is now dangling around my neck. (gobbles like a chicken, audience laughter). Ministry of Environment would you please tell me where the Mercury goes.(Listens for answer). They don't know. Where does the Chlorine go. (listens) They don't know.

Um, I'm afraid what has happened in your fine province. You had a world famous agency here. The M o E in Ontario was world famous. It did some absolutely very important work They did measurements around the country. It was Mr. Oswajec (?spelling) who actually demonstrated the post combustion theory of dioxin formation. He was the one who did measurements of dioxins in PEI, he found that there was no dioxin coming out of the furnace but they found dioxins in the stack, where dioxins were being formed somewhere between the furnace and the stack.. This was a theory until these measurements were made by the MoE's man, Mr. Oswajec. That was 1985. That was the year that I got involved in this issue. It was very very important. You also had another important thing in Ontario. Whenever there was a dispute of some kind over anything pertaining to the environment, people that go involved could get Intervenor financing to hire their own experts. That is now gone. That is a tragedy. I used to site Ontario as being a leading example of that financing of experts, so that the companies could have experts, but the citizens could have experts too. It was excellent. That is gone.

(continued, Part II, ELOERG Vol 2, No 1, Autumn 2002