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ERG REPORT Volume 2, No 2, Autumn (Supplement)2002

STOCKWELL AS ORWELL: AN INCINERATOR (BUT NOT AN INCINERATOR); CONTINUOUS MONITORING (BUT NOT CONTINUOUS MONITORING); PILOT PROJECT (BUT NO PILOT PROJECT)

The following is a transcribed facsimile of a letter received on December 16, 2002 from the Minister of the Environment, Mr. Stockwell.
For a history of earlier communications on the matter see ERG Report, Vol 2 No 1.
(http://eloerg.tripod.com/waupoos)
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Ministry of the Environment
Office of the Minister
135 St. Clair Ave West, 12th Floor
Toronto ON M4V 1P5

December 12, 2002 File No 79257

A. C. Goddard-Hill, B.Sc, M.D
General and Family Physician
306-210 Dundas Street East
Belleville ON K8N 5G8

Dear Dr. Goddard-Hill:

Thank you for you letter of November 1, 2002 summarizing the details of the October 30th meeting between Quinte Watershed Cleanup Inc and Ministry of the Environment staff with respect to Norampac's steam reformer at Trenton. I want to assure you of the ministry's continued interest in this matter.

As outlined in your letter, your primary concerns continue to be for issues relating to public health, and adequacy of the emissions monitoring program. The ministry believes that all public health issues related to the use of the steam reformer at Trenton have been adequately considered and addressed. Theoretical considerations do not lead the ministry to believe that dioxins will be a concern for this equipment. The original assessment of the process by staff of the ministry's Environmental Assessment and Approvals Branch and the Standards Development Branch, found that the operating temperatures are such that dioxins in the Dombind should be destroyed and should not allow the formation of dioxins in the process.

There was no actual data provided as a result of the pilot project in Baltimore, Maryland in December, 2001. Staff assessed the operation against known criteria for successful destruction of dioxins.

The Certificate of Approval (C of A) for Norampac's steam reformer imposes very stringent operating and monitoring conditions, and requires initial and annual compliance testing for an extensive list of contaminants. That list includes several types of dioxins and furans as well as polyaromatic hydrocarbons, and heavy metals including mercury. Initial source-testing results, based on a ministry pre-approved test protocol, must be reported to the ministry.

There is to be continuous monitoring of the operation of the Steam Reformer while the equipment is operating. All records must be retained for a minimum of two years and be made available to ministry staff.

In addition to the ongoing monitoring requirements outlined in the C of A, the ministry has various mandatory abatement tools that will be used if there is a violation of the terms and conditions of the C of A. The operation of the steam reformer at Norampac's Trenton facility will be subject to routine inspections and compliance monitoring reviews.

With respect to the monitoring program, dioxin sampling for compliance monitoring in Ontario follows accepted, validated standard methods. The ministry is also of the opinion that the standard reference method which we recommend for determining the maximum emission levels of dioxins by operating at the maximum production levels is appropriate in this situation. The ministry specifies testing at the mouth of the stack in order to obtain an accurate image of actual releases to the environment. While other jurisdictions may follow different methodologies, those used in Ontario are deemed appropriate to safeguard both public health and the environment.

Regarding the classification of the steam reformer facility, the ministry's position is unchanged, the process is not incineration. In the context of approvals required under the Environmental Protection Act, "incineration" refers only to "the processing of a waste which is brought in from off-site, using a thermal process, for the purpose of final disposal of the waste under and/or energy production". From a legal perspective then, the term "incineration" is not applicable to the steam reformer. Recovery of pulping chemicals in the black liquor is an industrial process associated with the typical operation of pulp and paper mills and falls outside the definition of incineration.

I would like to clarify that the steam reformer at Trenton is not a pilot project, and that a smaller steam reformer unit in Baltimore, Maryland was the pilot.

If you have any further questions regarding this matter, please contact Mr. John W. Tooley, District Supervisor of the ministry's Belleville Area Office at 613 962 9208, Extension 29.

Thank you for sharing your concerns with me.

Yours sincerely,
(signed)

Chris Stockwell
Minister of the Environment