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Part II

You have decimated the MoE. You had so many good people in that agency. They don't have the resources that they, even if they had the will, that they could monitor this facility. With that decimation has come an enormous amount of cowardice, inasmuch as you don't have a Ministry of Environment, you have a ministry which is subservient to economic interests. It should be called the Ministry of Economic Development. And they are going to rubber stamp whatever it is that industry wants to do. Mr. Harris and his friends. And now the MoE is simply a rubber stamp for economic interests in this province. That is very very sad. (applause)

I'm not happy about that, but I witnessed it in Cornwall, where when I closed my ears I could not tell the difference between the lawyers which were representing the companies which were burning up to 30,000 ppm of PCBs in a little rinky dink Mickey Mouse copper recycling furnace, you need a, in the United States you have to get a TOSCA permit to burn over 50 ppm of PCB's, in Cornwall they gave a permit to a little copper recycling furnace to burn 30.000 ppm, and when we went to the public hearings the MoE was working for the Company, so we had the lawyers for the company and experts for the company, then you had lawyers with the MoE working for the company and experts for the MoE testifying for the company, and then we had citizens flailing there.

To come back to where was I was leading with this point the game plan so often, and I've seen it all around the world, is when they come through with these magic machines there is a huge amount of sales talk and very little substance, the strategy is (mimicking another voice here) Oh Well, if only you knew as much as our experts, and you should realize that you are being hysterical, emotional, irrational, and you are essentially just being hysterical housewives, whilst our engineers, out men in their white coats, our Ph D's and our P E's, they know all about this. If you knew as much about this as they did you would realize that this is the strategy. Right. That is the strategy. YOU ARE STUPID! And they are very very clever.

Now the counter ploy to that is to challenge them to debate. Produce your data. Produce your evidence. Get into the same room with someone who can challenge you on the data, on the science, and that's when they don't show up. And that is how we level the playing field. So so much for their expertise. That's their expertise (holding up rubber chicken tie) They can defend it in one sided press conferences, they can defend it in pretty bits of paper, but put them on the same platform as someone who knows a LITTLE bit about it, not necessarily a lot, but a little, they run for cover, they are out of town, they can't make it. It doesn't speak very well of their machines. And it doesn't speak very well of their agencies.

What do I suggest then in the face of this thing. Uh, two things. Uh. One, I don't think that you should mess around with the Ministry of the Environment. They are not going to be able to protect you. Forget it. Even if they wanted to they don't have the money, they don't have the manpower to come here to check up on what they are doing. They are talking about ONE DATA POINT. GIVE ME A BREAK. That is not only lousy science it is lousy mathematics. How can you do statistical analysis on one data point? How do you know the variation on one data point? (audience laughter) And this reading taken under ideal circumstances, on one data point. Give me a break. It's pathetic. Anyway, so forget the Ministry of Environment. What you want is a signed contract between this company and the community which states categorically that "we will not burn any waste in this facility or destroy any waste in this facility, other than this pulp liquor." That's the contract. In other words they will not import medical waste, other hazardous waste, etc etc etc. A signed contract between you and them. Don't worry about the Ministry of Environment. And sue the pants off them if they break the contract. At least you'll have some money out of it.

The second thing is, and this is where the Ministry of Environment may come in, if they are going to do it, for goodness sake do it scientifically. Uh, (going to overhead projector to illustrate the following point with diagrams), this paper was presented in Stockholm , sorry, I'm going over time, I was supposed to be finished 4 minutes ago, I'll be finished in 2 minutes, in Stockholm Sweden in 1998 at the Dioxin Symposium by Dupre and Weaver (?) two scientists from Belgium, and what they did was to do the typical tests on the gas from an incinerator, the typical 6 hour test. What that means is they put a probe half way up the stack and then tested the gases coming out of the stack from the burning process for 6 hours. Typically in the United States when you are testing an incinerator you do that 3 times, you put the probe in, test for 6 hours, put the probe in again test for another 6 hours, and put the probe in again and test for another 6 hours. The filters are sent away to a laboratory and a few months later you find out what happened on that particular day. Remember the company gets about a 30 day notice prior to sampling. Now what they did was they put a probe in ay the same time and tested for 2 weeks. They did that for 2 weeks. They put the probe in, collect a sample over 2 weeks and send the filter away. Collect a sample for another 2 weeks and send the filter away.

At the beginning, what they found was when they normalize this, you're testing concentration now, not total, what they found is that you get 30 to 50 times the concentration of dioxin was being collected per cu m in the 2 wk sampling than in the 6 hour sampling. So here (pointing to a chart on overhead) you are looking at the ideal measurement, collected when the company knows you are coming, and collected as specific conditions. It has to be steady state conditions. This on the other hand picks up (another graph) upset conditions, including startup, shutdown, everything, when you have been collecting it for 2 weeks.

And so, that's what you should ask for. You should ask for this system, you know, that you want, that is is an experiment, that they haven't got one of these things running anywhere in the world, this will the be the first, anywhere in the world, therefore it is an EXPERIMENT If you are going to do a bloody experiment in the community, at least you owe it to the people who live here to do the experiment properly. This would be meaningful data. Now you can argue about whether you want to do this for 6 months or for a whole year. Then you will see the FULL RANGE of emissions, under the FULL RANGE of operating conditions, startups, shutdowns, upsets. This gives a measure of total dioxin emissions under the full range of conditions. If you get that then you will have some idea of the animal that you are dealing with.

And those are the two things that I would recommend.

Thank you."



Terry Cassidy.

Well done Paul. You give a new idea for the whole concept of rubber chicken.

(Proceed to questions, answered by Dr. Connett and by Bob Argue.


Ministry of Environment (TRANSCRIBED FACSIMILE)
133 Dalton Ave, PO Box 820
Kingston, ON

November 20, 2001

A. C. Goddard-Hill

Dear Dr. Goddard-Hill

Re: Reformation Forum

Thank you for your e mail of November 13, 2001.

As was indicated in Mr. Tooley's letter to you, we both have commitments for that date which were made prior to your invitation being received and we are not able to attend. I am uncertain about Norampac's attendance.

The questions you raise in your e mail with respect to the proponent's claims for the environmental safety of the process could have been made at the time of the posting of the Application for a Certificate of Approval in the electronic Environmental Bill of Rights registry. In fact, the only comment made during that process was from one of the members of the Bay of Quinte Restoration Council. As Mr. Tooley mentioned, that comment resulted in additional testing requirements for the facility.

Mr. Tooley's response on page 2 of his letter to your question about the environmental safety of the process seems clear. Based on information we received at the pilot demonstration, our knowledge of the type of process, together with the information accompanying the application and the Ministry's assessment of that application, we are confident that the process will operate within standards set out for emissions from the process. The process will not create dioxins since there is no oxygen involved in the process and the operating temperature is sufficiently high to destroy existing dioxins.

With respect to the stack testing, one sampling event is felt to be sufficient to assess the emissions from the process. The Certificate of Approval requires that the testing is to be carried out under conditions which yield the worse case emissions within the approved operating range of the equipment. Based on the results of the testing, additional testing may be required if deemed necessary.

Yours truly,


Brian R. Ward
Director, Eastern Region


Ministry of Environment (TRANSCRIBED FACSIMILE)
Bayview mall, 470 Dundas St E
Belleville, ON

November 9, 2001

A. C. Goddard-Hill

Dear Dr. Goddard-Hill:

Re: Steam Reformer Public Panel Discussion, Invitation to Participate

Thank you for your invitation to attend a public panel discussion tentatively scheduled for November 28, 2001 at the Knights of Columbus Hall in the City of Quinte West. While it would have been a worthy event in terms of first-hand sharing of information, I regret to say that we are not able to attend due to previous commitments.

However, I will endeavour to answer your questions as you put forward in your letter as well as provide an overview of the situation.

Q. Is this Steam Reformer a type of incinerator?

A. The process is not an incinerator by definition since, while the waste is being processed and will provide heat and recycle process chemicals, there is no oxygen involved in the process. Traditionally, incinerators are considered to be reactors where a substance is oxidized and organic substances release carbon dioxide and water. In this process, superheated steam reacts with the organic portion of Dombind to produce hydrogen and carbon monoxide in the absence of oxygen. The hydrogen rich gas will used as a fuel in a boiler.

.(Answers to 4 other questions, and seven pages of the history of Dombind also included.)..

Yours truly,
John W. Tooley, District Supervisor
Belleville Area Office, Peterborough District, Eastern Region, MoE


A. C. Goddard-Hill

October 15, 2001

Mr. John Tooley,
Area Supervisor, Belleville Area
Ontario Ministry of Environment
Bayview Mall
Belleville, Ontario

Re: Steam Reformer Public Panel discussion: Invitation to participate

Dear Mr. Tooley,

On the evening of Wednesday November 28, 2001 a public panel discussion sponsored by Quinte Watershed Cleanup is to be held from 7 to 9 pm at the Knights of Columbus Hall in Quinte West.

The subject will be the Pulse Enhanced Steam Reformer as proposed by Norampac.

QWC believes that it would be helpful to sponsor a panel discussion to answer the following questions: Is this Steam Reformer a type of incinerator? Will the facility once constructed for the purpose of pulp liquor disposal inevitably lead to the use of the facility for general hazardous waste disposal ? What would the public health implications of such an expanded facility be? What would the impact of such a facility be on the local Quinte Waste Solutions program of High Grade Waste Reduction? What is the evidence to support the proponent's claims for the environmental safety of the process?

On behalf of Quinte Watershed Cleanup Inc I have been asked to invite you or your representative to sit on the panel. I have already had a discussion with Mr. Dennis Maftei of the Standards Branch during which he indicated that he would be willing to participate should you consider this appropriate.

The panel will be chaired by a respected individual from the community. There will be four participants: representatives of the proponent (Norampac Inc) , the regulator (MoE), an expert from the waste reduction community in Ontario (yet to be named), and Dr.Paul Connett, a chemist from New York State who has a wide experience in waste management issues who is particular interested in waste incineration and zero waste.

A background information sheet is enclosed.

Quinte Watershed Cleanup Inc is a non profit citizen's environmental group which has evolved from the Public Advisory Committee to the Bay of Quinte Remedial Action Plan. The current chair is Ms. Louise Livingstone.

The mission of QWC is to work for the community by investigation, interpretation and alerting on environmental issues.

The subcommittee which is arranging this panel evening consists of myself, Mr. Terry Cassidy (chair of Quinte Waste Solutions) and Mr. Mannfred Koechlin.

On behalf of QWC I would like to thank you in advance for your cooperation in this matter and also for your ongoing accessibility and willingness to answer questions regarding local environmental issues that we at QWC direct to you from time to time.

I look forward to your reply.

Sincerely yours,
A. C. Goddard-Hill

cc. Mr. Michael J Williams
Director, Environmental Assessment & Approvals Branch, MoE, Toronto


Ministry of Environment (TRANSCRIBED FACSIMILE)
2 St. Clair Ave West
Toronto, ON

September 14, 2001 File No 73982

A. C. Goddard-Hill

Dear Mr. Goddard-Hill

This will acknowledge receipt of your letter dated August 12, 2001. The Minister has requested that I respond on her behalf.

Further to your inquiries, the Ministry of the Environment regulated Norampac Inc's pulp waste management system in Trenton, under amended Certificate of Approval (Air) Number 1881-4QTKFJ issued under the Environmental Protection Act (EPA). This certificate allows Norampac to process their own pulp liquor waste. According the ministry files, Norampac does not have approval to process hazardous waste materials at their Trenton facility. Should Norampac Inc propose to process hazardous waste material, they would be required to obtain approval under the EPA. Should the process involve incineration, a hearing before the Environmental Review Tribunal would be required before approval could be provided.

Thank you for your interest in this matter.

Yours sincerely,

Michael J Williams
Director, Environmental Assessment & Approvals Branch


A.C. Goddard-Hill, M.D
Eastern Lake Ontario Environmental Research Group
450 Dundas Street East
Belleville, Ontario 613 968 8692

August 12, 2001

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

Dear Minister,

In an article which recently appeared in a local newspaper (Buzz bomb turns into high tech waste system, Kate Everson, Community Press, Quinte Edition, Friday August 10, 2001), Mr. Gary Hodgins, general manager of Norampac Inc of Trenton, is quoted as describing as "unbelievable" the Pulse Enhanced Steam Reform waste management system now approved for the disposal of black liquor pulp waste at the Trenton mill.

According to Mr. Hodgins, this is "ground breaking technologyfor which Quinte will serve as the testing groundsfor the first commercial application in the world. of the most remarkable technological innovation of the centurywhich will convert all kinds of biomass including municipal solid waste, medical waste, tires, sewage sludge, industrial waste, agricultural waste, pulp mill waste and hazardous wasteinto nothing more than distilled water, with a residue of carbon char mixed with calcium carbonate!"

Mr. Hodgins is correct. This is unbelievable.

Hazardous waste incinerators, of which this technology is clearly one subspecies, are notorious for polluting the regions in which they are located.

Interestingly this project has already been permitted for operation by regulators from your Ministry without opportunity for public hearings or an Environmental Assessment.

Furthermore the MoE Approvals Branch reports that there is no data available regarding potential dioxin emissions from the proposed plant. Dioxins are the very chemicals that have prompted Norampac, with the encouragement of your Ministry, to search for alternate methods of pulp liquor waste disposal.

Should the proposed plant be used solely for pulp waste management then it may be that emissions would be of relative insignificance.

However should Norampac be planning, as their literature and the newspaper article suggests, to accept general and hazardous waste for treatment at the facility then the long term implications for public health in this region could be very serious.

In such a case I call on you, in order to protect public safety, to arrange public hearings and an Environmental Assessment prior to construction rather than relying on occasional monitoring after the fact.

The Quinte Region, now struggling to deal with residues from coal gasification processes of the last century, should not be eager to adopt hazardous waste gasification systems now being brought forward from the same era. Quinte residents should be asking questions about the long term public health implications of the construction of such a facilty in our area.

Enclosed is some background material.

I would appreciate it if you could telephone me in order that we can discuss this matter.

Thank you for your consideration.

Sincerely yours,
A.C. Goddard-Hill

cc. Community Press; Belleville Intelligencer