Ground Woodmill EIA
Technical Environmental Review of the EIA & Major Project Review Pertaining to the Chemi-Pressurized Ground-Wood Combined Northern Softwood Bleached Pulp Mill Proposed for the Lakelse-Kitimat Corridor
Executive Summary jormabio@hotmail.com
The Orenda MPRP review is flawed technically and administratively.
Key issues are raised in every aspect of which I examined and had I examined more, I would undoubtedly have found more.
The most important conclusions I reached are these:
i) Air pollution will be harmful to the ecology, health, recreation and tourism and zero effluent means increased air pollution returned as water pollution in other locales.
ii) The water supply is not a certitude in the long term.
iii) Special waste management problems will occur in the long term and these were not dealt with.
iv) Proper planning steps have not been taken in north and south Kalum TSA RMP or LRUP planning by MOF and public review of these plans would impact on Orenda's proposal if they were not being disallowed by an improper MOF review schedule.
v) A precedent will be set by Orenda which will launch the eventual degradation or pollution of Lakelse river and Kitimat river and Kitimat estuary.
vi) A precedent would be set by Orenda mill, which would eventually result in the alienation of prime forest lands between Terrace and Kitimat.
vii) Pressures placed upon regional fish and wildlife and plant life, both common, game and non-game, and rare and endangered, have not been properly considered in the MPRP though these would be impacted by the type of demands and or pollutants placed on their habitats.
viii) The timber supply is probably not there to meet Orenda'sneeds and all future uses of the forest in an integrated planning framework and in the light of new ecological forest management planning beyond 2001 and almost certainly not beyond the projected fall down time frame.
ix) The MPRP process is unfair administratively by the Ombudsman's criteria and undesirable by a democratic yardstick for there was apparently a rejection of the mill at this location by a majority of the northern public who attended public meetings on the mill impacts.
In conclusion, from the sheer weight of evidence of errors, over-sights, and failures to consider and so on, I recommend that this proposal be rejected until proper planning steps taken in both south and north Kalum TSA be completed, and reconsidered only after all of the technical and other concerns I identified in this critique are effectively addressed.
Jorma Jyrkkanen, President JEC Consulting.
Terrace, BC
Technical Critique of the Orenda Pulp Mill EIA & MPRP
Introduction
I was asked by the Alec Bolton on behalf of the Tsimshians and Haisla to critique various aspects the Orenda Groundwood Mill Proposal planned for the Cecil creek area south of Terrace.
I conducted an independent company based review at our expense without Intervenor funding or MPRC Committee sanction.
Upon review of the available literature pertaining to this proposal, which includes the original proposal by Orenda for the Terrace-Kitimat Cecil creek site, and the review documentation available to the Haisla as of the 24th February, based on documentation provided by the proponent, I have reached some important conclusions pertaining to the Environmental Impacts of this development proposal.
This is my in depth analysis and critique of the Orenda MPRP and the proceedings of MPRC committee.
1.0 Mill Emissions
According to Orenda, Discharges to the air will include from the mill, particulate matter (PM) (.22 t/yr), hydrogen chloride, sulfur dioxide (8.7 t/yr), nitrogen oxides (218 t/yr), hydrogen fluoride, carbon monoxide (372 t/yr), carbon dioxide (143543 t/yr), hydrocarbons including VOC's (93 t/yr) and PAH's, phosphorous pentoxide, opacity, trace metals including class I- Pb, Sb, cu, Mn, V, Zn, and Class II-As, Cr, Co, Ni, Se, Te, and Class III-Tl, Cd, Hg. Additionally, some of the chemicals generated by slash-burning cited next will probably also be generated in the mill incinerators.
1.1 Slash-burning Emissions
Slash-burning generated by pulpwood harvesting for the mill will generate the following chemicals minimally (USDA-Forest Service General Technical Report WO-9; Effects of Fire On Air; A State of Knowledge Review of National Fire Effects Workshop {Badly needs update}): CO, CO2, SO2, NOx, Hydrocarbons (hundreds or more varieties),oxidants like ozone, numerous oxygenated gases and vapors including acids, aldehydes, and furans {Recently, dioxins finding detectable levels in burning wood-Bob Wiseman, 1992, Pers. Comm.}.
1.1.a. Volatile Organic Compounds
Organic vapors (Volatile Organic Compounds, VOC's) found in burning Loblolly pine included the following (Ryan and McMahon, 1976):
isopentane, l-pentene, furan, n-pentane, isoprene, acetone, isopropanol, cyclopentadiene, alacetyl, I-hexene, methyl vinyl ketone, 2-methylfuran, n-hexone, 2,4-hexadiene, 1,3,5-hexatriene, 3-methylbutanol, benzene, cyclohexane, 4-methylpentene, 2,4-dimethylpenatane, 1-trans-2-dimethylcyclopentane, xorbaldehyde, 2,5-dimethylfuran, n-heptane, cis-2-heptane, 2-vinylfuran, 2,3-dimethyl-2-pentane, 2,4-dimethylhexane, toluene, l-octene,2,3-dimethylhexa-1,4-diene, n-octane, 2,3,5-trimethylfuran, furfural, ethyl benzene, p-xylene, 2-propionylfuran, styrene, Q-xylene, n-nonane, 2-isoprpylfuran, anisole, 2-methyl-5-isopropenylfuran, cumane, n-decane, camphene, n-propylbenzene, m-ethyltoluene, p-ethyltoluene, l-decane, benzofuran, m-diethylbenzene, limonene, p-alpha-dimethylstyrene, n-undecane, n-dodecane. In addition, ligno-cellulosic fires can generate low molecular weight oxygenated species hard to assess, including caboxylic acids like formic acid, and acetic acids as well as reactive aldehydes like formaldehyde, acetaldehyde, and acrolein etc.. They are significant CARCINOGENIC constituents of smoke and may have other toxicological properties as well.
1.1.b. Polycyclic (or Polynuclear) Aromatic Hydrocarbons, PAH's
In addition, polynuclear aromatic hydrocarbons (PAH'S) are present in wood smoke as they were in gases from burning pine needles as studied by McMahon and Troukalas (1978), and these are formed optimally by pyrosynthesis in the temperature range 700-850 Celsius. PAH's can be generated also by vehicular emissions.
They will be mostly in the gas phase in summer and in particulate phases in winter.
PAH's include:
anthracene/phenanthrene, methyl anthracene, fluoranthene, pyrene, methyl pyrene/fluoranthene, benzophenanthrene, crysene/benz(a)anthracene, methylchrysene, benzofluoranthenes, benzo(a)pyrenes, benzo(e)pyrenes, perylene, methylbenzopyrenes, indo(1,2,3-cd)pyrene, benzo(ghi)perylene.
PAH's are CARCINOGENIC or MUTAGENIC or both as a class of chemicals and may have other toxicological properties as well.
Particulates are also generated by wood fires and these are a complex mixture of soots, tars and volatile organic substances. SOOTS and TARS are well known carcinogens. Fines less than 3 micrometers have a greater affect on human health and are often associated with BAP's. An acronym for these fine PARTICULATES is PM10.
1.2 Link to KRAFT Pollution
Use of initially 25% and subsequently 20% KRAFT fiber will lead to air pollution increases elsewhere by a KRAFT mill of the types typical to KRAFT mills. Completed upgrades can be expected to reduce the existing impacts but increasing demand can be expected to increase them in future, though not to their former levels. {See Appendix I for KRAFT air impacts}
1.3 Effluent is Altered to Solid Waste and Air Emissions and the Problem is Simply moved Geographically.
Zero effluent technically translates into increased air and solid waste disposal with probable production of novel toxins in the incineration of combined waste streams.
Increased potential for novel air pollution will result from diverting effluents into other forms. The effluent mass has merely been transformed into more air pollution and more solid waste thereby increasing disposal problems for these other two waste streams.
Efficient combustion of sludge and fuels will produce a large amount of carbon dioxide (by burning the bulk of hydrocarbons, though not all, to CO2 and water), perhaps the most important greenhouse gas. The experience is that aerial transport can deposit pollutants into ecosystems as far as the arctic and once there, disperse them into the fish and wildlife and human habitants. We are also finding anthropogenic chlorine in the stratosphere, lifted there via the polar vortex. The problem has simply been moved geographically. In addition, CO, CO2, NOx, SO2, Ozone and organic peroxides, Particulates and VOC's and PAH pyrolysis products generated by slash burns associated with pulp harvesting increases atmospheric pollution and most of these products eventually find their way into biota via hydrological and nutrient cycles.
Burning of solid wastes as is planned, will channel the effluent and solid waste streams into primarily air pollution. Solid wastes that are left after combustion become a long term storage and leaching control problem.
1.4 Ecological Impacts of Emissions
There are greenhouse gases (CO2, NOx, methane, and unknowns) and acid generating gases (SO2, NOx, CO2) and ozone eating gases (probably HCL) and carcinogenic and mutagenic PaH's and VOC's and SO2 etc.) and ecotoxic chemicals going to be generated by the mill and by forest activities associated with fiber supply.
The impacts are not properly viewed as small compared to other sources, but are more correctly viewed as global and incrementally cumulative in harmful impacts. These impacts are now widely known to be globally and cumulatively significant and bringing a new source into line at this time when the evidence of greenhouse, acid rain and ozone destruction may be regarded by some as environmentally irresponsible. Each source could argue as Orenda has done that their source is but a small percentage of the total, and all deny culpability for the earth's ecological problems, and of course, they are all culpable.
1.5 Particulates Impact on Human Health
Particulates generated by the mill are best viewed in the context of their known health effects. They will lead to poorer health locally, and impact on local ecology. I recommend the model;
Deaths per 100000 Population = 0.615 x PM (J.S. Evans et al. Environ. Int. 10, 55 (1984)) to be viewed in conjunction with existing ambient air particulates during worst case (inversion) conditions as measured in Terrace and at Lakelse lake and at Kitimat.
1.6 Dioxins and Furans Generated By Mill and Forest Activities
Dioxins and furans will be generated by burning wood (Bob Weizman, 1992, Pers. Comm.) if and when and where and at those times when temperatures in the boilers are down to 200 to 350 Celsius due to high moisture content of sludge, simply from the endogenous phenols and salts present in the wood and also because chlorine is a natural constituent of wood and salts present in woods, and these can be expected to be released to the air shed. The same will occur during slash burns.
1.7 Aesthetics of the Terrace-Kitimat Corridor & Recreation
Visual Quality Objectives as assessed from potential recreation analyses using the ROSS spectrum have not been properly carried out in an Integrated Planning Framework for the valley as viewed from the potential view-shed.
1.8 Defective Model for Impacts on Air Traffic
A proper model defining prospective impacts on air traffic of varying conditions brought about in part by the air effluents hasn't been properly evaluated by failure to consider inversions and fumigation and fog generation by photochemical dissociation and particulate seeding.
In addition Orenda's model for plume visibility used zero values for soot, particulate and NOx which would of course lead to errors in projection as regards opacity.
In many respects this mill is experimental, since no other mill exists in the world which has all the components planned for this one. Because it is novel, there is no way to validate parameters used in models which leads to great uncertainty in projecting future air emission dynamics.
1.9 No Concern of Health Ministry
The health effects of the chemicals emitted to the air were dismissed trivially and should have been modeled by clearly showing how many extra deaths and how much morbidity would result from bronchitis, emphysema, asthma, and lung cancer and all cancers and causes combined. I have enclosed a bibliography of health effects and two analyses carried out on this subject (See Appendices 1 & 3).
1.10 Health Based Pollution Guidelines
BC Air pollution guidelines are not based upon health criteria which have undergone any proper academic, public and medical profession review. For example, PM10 regulations which are health based proposed by UBC have not been adopted.
1.11 Fugitive Air Emissions
There is a failure to properly address Fugitive Air Emissions. Fugitive emissions could originate from hogging of bark, pulpwood ends, clay handling, and storage, starch handling and roll grinding. Environment Canada has identified this as an area that needs to be addressed before development.
1.12 Ozone a Concern
Ozone guidelines are lacking for BC, despite the overwhelming evidence that it increases human morbidity and mortality. Many have experienced the eye irritation, chest discomfort, headache, mild cough and sore throat that it causes and for others, in heavily polluted areas, death from this pollutant (Jane V. Hall et al. 1992. Valuing the Health Benefits of Clean Air. Science (255):2812-817.).
1.13 Lack of Plain English
Obfuscating jargon was used widely and models were used in generating the impact study and the public has no way of checking the validity of the assumptions or equations inherent therein, a check which is vital for acceptance of the conclusions of those models. Examples of jargon; `Precipitation-weighted wind frequency'; `default washout coefficient' . For example, the mathematics of the models was left unverifiable by local mathematicians because it wasn't presented in the EIA.
1.14 Volatile Organic Compounds
VOC's; Carcinogenic. 93 tonnes/yr or 112 tonnes/yr?
1.15 Polycyclic Aromatic Hydrocarbons
PaH's, Carcinogenic, Mutagenic. Needed is a quantitative assessment of production of this pollutant and design measures which are known to eliminate this air pollutant. The terms negligible to minimal mean nothing.
1.16 Defects in Dispersion Modeling Herald Significant Potential Air Pollution Problems; Inversions & Fumigation
Ground level air contamination modeling failed to take into account inversions and fumigation, which by their high frequency in the Terrace-Kitimat corridor (Orenda EIA, Vol. 2. Table 4.2.4. PG. 113) , have a significant potential to cause severe ground level air pollution. The quotation on pg. 109 is very damaging; "...the frequency of their occurrence is a measure of air pollution potential."
Nowhere did I find mention of these parameters in the American dispersion model which was used. Fumigation which occurs when inversions break up, allows air borne pollutants to reach the ground, and at those times, the highest pollution levels occur.
The impact of these parameters is probably highly under-represented in the EIA, leading to the conclusion that the EIA is faulty and that in fact there is a high probability of intermittent severe low level air pollution and acid on snow deposition.
1.17 Model Defects on Acid On Snow Potential
Failure to incorporate inversions and fumigation in air dispersion modeling, also leads to underestimating the potential for acid accumulation on snow, and by inference, acid run-off during freshets and rapid thaws, thereby leading to endangerment of the Lakelse river fish stocks and other biota and Kitimat river fish stocks and ecosystems as well.
1.18 Acid Rain and Ecological Effects of Air Pollution
SO2, NOx, and ozone cause forest death, and death of susceptible lakes and rivers, that is those with low buffering capacity. Of course their attendant flora and fauna are also adversely affected.
There is a need globally to reduce and eliminate the discharge of these substances to the air. How adding a new source on line helps in this regard is hard to see.
Heterogenous bedrock and heterogenous glacial depositions in the Pacific northwest makes it hard to predict which watercourses will be most vulnerable to impacts due to limited buffering capacity. We know for example, that watercourses contiguous with granitic bedrock generally have low tolerance for acid while limestone parent materials generally means high buffering capacity. What happens however, when you have limestone parent material overlain by several hundred meters of granodiorite glacial till?
1.19 Long Range Transport
The effective air shed of sulfates is 1000 kms.
1.20 Impacts on Lakelse Lake Residents and Tourists
Aesthetic effects are anticipated from the air pollution from time to time.
1.21 Need to Know Boiler Generated Pyrolysis Products
Pre-start-up testing of burn emission products of evaporator sludge ignition should be conducted to identify which pyrolysis products are generated and how these can be mitigated or eliminated, prior to mill approval even being considered. Burning of this material is expected to increase air emissions.
1..22. 372 Tonnes is Called Minimal
It has been said that CO is minimized by good combustion but projections are for production of 372 tonnes/yr. If 372 tonnes/yr is minimal, what is maximal (See 3.4.1, pg. 61)? CO2 Production?
1.23 Need To Know Boiler Temperatures
Internal temperatures within the boiler under varying conditions of operation should be available before we can safely accept the proposition that most toxins will be incinerated by this method of chemical alteration. However, high temperatures lead to increased greenhouse CO2.
1.24 Greenhouse Gas Methane from Organic Decomposition
Methane emissions may result from the site from wood waste decomposition, paper product decomposition and from natural gas leakage, as was specified by Colin di Cenzo Scientific Services Meteorologist with AES Pacific Region in a memo to Bob Sherwood, 8 Oct. 1991. Methane is a greenhouse gas. I would add that biotoxic H2S would also be generated by that same organic decomposition, particularly if anaerobic conditions were to develop.
1.25 Large Tonnage of Carbon Dioxide a Special Climatic Concern
The large amount of CO2 generated (143543 t/yr) is of special concern to greenhouse because this gas among all gases, is increasing most omnipotently and inexorably. It is the gas which will be the most difficult to deal with globally in trying to curb greenhouse. Canada is simply not doing enough to slow the rate of CO2 emission, and has made very weak commitments regarding its control. This involves stabilization, not reduction, by the next century.
It is difficult to see how adding such a large new source on tap at this time in our atmospheric history is good for anyone. Among one of the projections to emerge from greenhouse theory, is that Canada's expansive boreal forests will be replaced by hardwood forests which will migrate north from the USA. This would effectively destroy whatever economy we have linked to that boreal forest.
Adding such a large greenhouse gas source is clearly unsustainable.
1.26 Acid Rain is Approaching the Lethal pH =4.5 Limit for Fish
Acid rain is a fact in Terrace with an average pH of rain of 5.1 (4.4-6.9). In Kitimat where there exists the Alcan smelter and the Eurocan pulp mill, the average pH of rain is 4.7 (4.3-.9) and on the west coast of Vancouver Island and Queen Charlotte Islands it is 5.3 to 5.4. The ph of unpolluted rain is considered to be 5.6 and this is due to CO2 dissolved in the precipitation forming carbonic acid. Clearly, pollution has increased from the time the rains hit Terrace. The high CO2 output of the Orenda mill as well as other acid generating gases, can be expected to make our rain still more acid. The lower end of these values is approaching the toxic range for fish. Below pH=4.5, all fish are eliminated. Note the 4.4 event in Terrace, and the 4.3 event in Kitimat. We are getting dangerously close to major impacts on fish.
1.27 Do Proposed BC Interim Guidelines Have Force of Law?
Proposed BC Interim Guidelines for Air Emissions are meaningless without the force of law. I understand that from the fact that they are proposed and interim, that they are not gazetted and are therefore without effect. In addition, they are described with mg/kJ units rather than ug/m^3 and convenient conversion tables were not provided so that the reader can make comparisons with existing standards for ambient air concentrations. The rationale for using mass per unit of energy rather than using mass per unit of volume needs to be explained.
1.28 Improper Use of Term Background?
In section 4.2.4.3 background ambient air readings were given for TSP, SO2, NO2 and readings were cited from towns with pulp mills.
Background in normal scientific usage in this regard would mean pristine, or in this case would mean uncontaminated control.
It would be more correct to use `Polluted Background' when referring to ambient air readings in these Mill towns.
1.29 Fluoride Emissions Computed
It was stated in a response memo from Cirrus Consultants that fluoride emissions: " ...should be much less than 5 mg/m^3...".
By simple proportionality, attainment of this level could result in fluorine emissions of 4.5 +/- t/yr.
1.30 HCL Potential Impacts on Stratospheric Ozone
It has recently been discovered by NASA Scientists that chlorine monoxide is a serious agent of degradation of the stratospheric ozone. Anthropogenic chlorine has been raised as an issue.
Our BC Special Waste regulation permits 70 mg/m^3 of HCL emissions according to CIRRUS consultants which suggests another serious potential anthropogenic source of chlorine to the atmosphere is being permitted by our Provincial government.
This suggests to me that we need to review anthropogenic chlorine sources and the permitted level before agreeing to any new major emissions coming on line.
Water:
2.0 Aquatic Effluents of the BKME Variety Linked to Orenda
Use of initially 25% and subsequently 20% KRAFT fiber will lead to water pollution increases elsewhere by a KRAFT mill of the types known to be associated with KRAFT mills, and which currently are shutting down coastal shellfish fisheries. While it is true that these mills are mostly in upgrade right now, it will be some years before this process is finished and in the interim, there will be significant pollution. KRAFT mills use millions of cubic meters of water annually and subsequently pollute it. Impacts of KRAFT mills on the aquatic environment are cited in Appendix 2.
2.1 Secondary Pressure to Develop Kitimat Estuary Impacts
Estuary
The mill will put pressure on to increase port development in Kitimat, with resulting impacts on estuarine flora and fauna and primary production in the Kitimat estuary. This causally linked probability must be viewed along with the impacts of this proposal.
2.2 Emission transport Harms Distant Aquatic Ecosystems
As mentioned previously, air pollution will transport pollutants to far away ecosystems where they will become part of the global water pollution. We have seen DDT, mirex and PCB's transported in this way from as far away as the tropics to the arctic where they now reside in beluga whales and Baltic seals.
2.3 Test Drilling No Assurance of Supply; Alternate Contingency
Should additional water be required beyond the 1600 m3/day, than that projected by existing plans, Orenda should satisfy all concerned that they can get that water without impacting on the local streams, and this should be a pre-condition of approval.
2.4 Potential for Stormwater Runoff Contamination.
Stormwater discharge from the site could lead to groundwater contamination, if spills are entrained in it, and measures should be in place to ensure that this cannot occur prior to approval being given for the mill at this site.
2.5 Groundwater/Surface Water Interaction Places Recharge in Limbo
Dave McIlroy. Senior Engineer with Forest Products Program, Environment Canada, Vancouver, has said that: "it is possible that the surface water may be a major recharge variable to the aquifer. The Golder Report has fallen short of providing details on the groundwater/surface water interactions". The outcome of further investigations was requested and needs to be shared to conclude that there will be no significant impact on local fish streams.
Wastes:
3.0 Source and Annual Tonnage of Ash Waste
Ash wastes of 7472.5 t/yr are anticipated and these will consist of combustion products of wood waste and of residual materials and chemicals contained in the clarifier sludge and evaporator sludge which are burned along with the wood wastes.The evaporator sludge contains wood wastes and chemicals used in the pulping process.
3.1 Listed Chemical Used in the Mill
Water treatment; NaCl=.2t/d, Lime CaO=.2. Pulping Chemicals; NaOH=9.6, H2O2=9.6, Sodium silicate Na2SiO3=3.2, Magnesium hydroxide MgOH2=0.2, Sodium Diethylene Triamine Penta Acetic Acid DTPA=1.3, OTHER=???0.2. Paper Fillers CaCO3=29., Starch=3.0, Size=???0.6, OTHER=???. Paper Coatings CaCO3=79, Clay =20, Starch=7, Latex=9.0, Cellulose=2.0, OTHER=???3.0. Defoamer and biocide are listed in Table 5.6.1 and clarification as to their chemical composition would have been helpful.
3.2 Listed contents of Ash
Silicon=1052 kg/d, Aluminum=126, Iron=252, Calcium=1112, Magnesium=.224, Sodium=5989, Potassium=1213, Manganese=139, Sulfate=28, Carbonate=8869, Chloride=183, OTHER ???? 141, Oxygen=20.22.
3.3 Kraft Mill Link From Demand for KRAFT Pulp
Use of initially 25% and subsequently 20% KRAFT fiber will lead to increased land disposal problems of the type associated with KRAFT mills elsewhere.
3.4 Who Will Monitor Leachates 100 Years From Now?
The very long term management of solid wastes hasn't been properly addressed, nor has the management of the storage areas during very inclement environmental conditions.
3.5 Heavy Metals Left Out of Ash Table?
Wood waste boiler ash characteristics listed in Table 3.3.1 excluded the most important trace elements such as Co, Mo, Se, Te, Ni, Zn, Cr, Pb, As, CN, OTHERS, some with high toxicity’s, and I wonder if this was simple oversight? Mention was made that heavy metals are immobilized at the pH ranges likely to result from the soda and lime in the ash, ie. 9-10. The cost of storage during economic downturns characteristic of this industry might make storage management too costly to comply with needed works for effective management of these toxins.
3.6 Spill Frequency in the Long Term?
We cannot foresee all of the spills which might occur but if frequency of spills at other mills are any indication, then it is clear that spills are unavoidable. Since it is a condition of their permit that spills will not be tolerated into the waterways, it is hard to see how this mill can be permitted under this condition alone. We are given assurances of the quality of contingency measures but wonder what will happen when the equipment gets old and large spills need to be vented to the environment. Where will they be discharged?
Impacts on Forests
General Comments
4.0 Limitation of Mandate to Mill Site Impacts Rejected
The mandate of the MPRP has limited itself to aspects of the operation of the mill and chosen to ignore the impacts on the forest. This is like saying that we can understand the effect of a giant herbivore on the environment without discussing the forests they feed upon. It is choosing the path of ignorance by design to frustrate the exposure of truth and understanding, perhaps to expedite the development, and simply untenable.
4.1 Available Pulp Fiber In Orenda's Kwinageese Area Over-estimated
Orenda has said that it has sufficient pulp fiber in its allocated cutting area, but on closer analysis, with assumptions that are more in line with evolving public and scientific thinking, it appears that this assumption may be premature. In particular, the effect on pulp fiber supply that an open public review of the enormous recreational and fish and wildlife values in the Kwinageese lakes district would have has been ignored or deliberately excluded from future pulpwood supply projections.
In my view, if the public were aware of the alternate value and sensitivities of the lakes and forests of the Kwinageese, of their fishing and swimming potentials, they would never allow the massive harvest plans to go ahead and there would result a significant netdown.
4.2 Critical Approval Date Precedes Public Review of Kwinageese
There are two critical dates approaching rapidly. One is the date for approval or rejection of the mill, and from the bulk of government correspondence it appears that approval will be confirmed. The other date is after the approval date, when MOF will begin the public review of its Orenda Kwinageese Resource Management Plan. I have heard that Orenda wants to turn the sod on May 6th, and also that public involvement for the Kwinageese LRUP is expected to begin about the same time.
In other words, the area is being given away, before the public has a chance to see and to comment on, and approve what is being given away.
It has been argued by many that future flexibility in forest management decisions will be severely constrained by adoption of the Orenda allocation.
This is clearly not a level playing field.
4.3 Reasons for Future AAC Netdown Projections
Lack of consideration of the forest impact aspect leads naturally to question the long term viability of the project. We now have two pulp mills in the area placing demands on the pulpwood supply and are being asked to approve a third.
This is occurring simultaneously that we are seeing forecasts of netdowns from falldown, concerns about arbitrarily high AAC's that are out of line with LRSY, calls for increasing rotation age for soil fertility renewal, increasing ESA netdowns from primary inventory of new sites, netdowns for habitat increasing demands on commitments of forest lands to long term recreational viability and compatibility with VQO's, demands for preservation of old growth forests for planetary climate and ecological stability, and suggestions from leading forest ecologists for lengthening the rotation ages significantly to comply with ecologically compatible holistic forest management principles.
These trends suggest that we had better reappraise the inventory before committing a huge amount of it to another forest consumer.
4.4 Need to Re-Rationalize North and South Kalum Resource Management Plans (RMP's) Linked to Bringing Major new Consumer of Pulp On Line
The North Kalum TSA RMP plan and the Kalum south development plans are placed into a critical situation by the addition of a new pulp fiber demand of this magnitude. They will have to be re-rationalized and the public input process will have to be gone through thoroughly and this process is best done prior to approving a new mill to be put on line.
The RMP for Kalum South is scheduled for completion in 1992 while the RMP for Kalum North is scheduled for completion in 1993.
It is hard to see how long term commitments of the magnitude we are discussing can be made prior to completion of the Public component of both of these plans.
When the former forests minister, Tom Waterland committed the north Kalum TSA in 1981 or 1982, he ordered that the TSA be liquidated in 20 years, which would be completed in about 2001. If the three main operators in that area have been on schedule, then there should be no available timber left in 9 years. In fact, I happen to know that they have been over harvesting in the early years of this planned liquidation.
I find it hard to accept that we can make major long term commitments without completion of a review of the impact of Tom Waterland's past decision on future Timber Supply in the north Kalum TSA.
4.5 Close Utilization and Opportunity Wood Ecologically Detrimental if Pulped
Close utilization and opportunity wood is viewed by Orenda as efficient but it is viewed by forest ecologists as harmful to the ecology.
4.6 Remaining South Kalum Pulpwood Mostly High Elevation; Costly and Environmentally Impacting, Especially to Fish and Cover.
Much remaining pulpwood in Kalum south is in high elevations, on steep slopes, and on moderately to highly unstable erodible soils, which can be expected to impact on fish habitat when they are roaded and logged and subsequently erode. These impacts are well known and increase the amount of deleterious fines in the stream substrates while reducing Large Organic Debris, essential for maintaining productive pool riffle ratios.
These practices also affect the hydrological severity of freshets and rain on snow events, as well as reducing the late summer water supply.
They can also clog stream beds with excess bedload accumulation. Much of this is high elevation forest is also valuable range for moose, bear, goats, furbearers, and avian and microtine vertebrates. Mature cover is increasingly in short supply in Kalum south.
4.7 Forestry Operations Impact Local, Regional, Global Ecology
The air pollution from these forestry operations is also a consideration. There will be vehicular emissions (PAH's, sulfur, mercury, soot, CO, CO2, NOx etc.), transportation maintenance costs, slash burning and its impact on global CO2 and greenhouse and its health effects related to suspended particulates, pesticides and all of their impacts, above and beyond what could be expected without this mill. These emissions will have impacts on vegetation and animal life and some of these were discussed in the Nisga'a Review to which the Reader is referred. The impacts are global and cumulative and incremental harmful.
4.8 Kwinageese Local Resource Use Plan Needs Public Involvement
The Orenda Kwinageese Local Resource Use Plan, which is a critical element of this proposal, has had no complete public review as yet and there will be critical questions pertaining to the recreational values inherent within this area.
There are over 256 lakes in the area and many are fishable and or swimmable and there is the Kwinageese river which has all of the five species of salmon and steelhead and trout and a vital sockeye run.
None of this has had input from public review, a process which is vital where keen interests and conflicts are anticipated, a public review which is expected to go ahead in late April or May of this year, and yet inherent timber resources are being asked to be committed to Orenda prior to such review.
There is a large population of grizzly bears in the Kalum north planning area and their need for old growth and salmon is well known. In addition, there may be caribou stragglers that occur there as attested to by a track I saw once and increasingly, deer are certain to use the area as well. The area may perhaps be viewed as a Park opportunity as well as or instead of a logging chance.
The main impact that a public review would have on the area would be to probably result in a large net-down of projected operable wood for these other forest values, and this would definitely impact on Orenda's wood supply. The timing of the review of the North Kalum RMP is curiously after the timing of the approval of the Orenda mill. Also the mandate of the MPRC has limited itself arbitrarily to discussing the effects of the mill to the exclusion of its forest impacts, which has the effect of preventing full disclosure, consideration and discussion about the full range of ecological impacts of this project.
Kalum MOF is preparing the initial steps of an LRUP for Orenda's Kwinageese Cutting permit. This is in keeping with evolving Integrated Management thinking in the MOF that recognizes that in situations where there are high alternate values and potentials for conflict with timber production, that consideration of all options needs to be conducted and then itneeds to go to public review, as has been done for the Babine LRUP.
To commit this area to Orenda's proposed mill prior to Public review of the options element of LRUP planning and also the Public review of the finalization, a process which can take up to a year or more, would be to commit a serious planning error.
It appears that a planning error is about to be committed because the go decision is about to precede the Public involvement step for the Kwinageese LRUP.
4.9 Alienation and Loss of Productive Valley Bottom Forest Encouraged by Precedent Set by Orenda Mill Harms Forest Based Economy
The location of the mill on the Onion Flats will be detrimental to the Kitimat forest, resulting in both permanent loss of forested lands and also in establishing the precedent of opening the door for complete industrialization of the Terrace-Kitimat corridor, a development which has serious ramifications for future forest production. The conversion of such valuable valley bottom forested lands to other uses seems very unwise in the long term.
4.10 Impact on Forest Recreation Aesthetics
As regards forest recreation, there will be periodic negative aesthetic impacts on Cross country skiing near the facility, and detrimental impacts to those swimming or boating in Westlake and the Two Ena lakes near the mill.
4.11 Kalum TSA timber Supply Projection Agrees on AAC Reduction
The Kalum TSA Timber Supply Status Report of January 31, 1991 states that the Kalum TSA will require a substantial reduction in AAC. The inventory is incomplete and has been so for 10 years. The Report states that operable land base may shrink by 20 to 30%. ESA delineation will cause a further netdown. Yield curves are too high for certain species and sites in the Kalum TSA. Heavy to severe losses to Leader weevil and vole damage is occurring in both the south and north Kalum TSA. Forest Planning Canada also lists most of BC TSA's as exceeding their AAC. All of this leads to conjecture about certainty of long term fibersupply.
Impacts on Fish:
5.0 Acid Precipitation Overlapping Lethal Limits for Fish
The potential for acid accumulation on snow and for acid run-off during periods of melt is not properly addressed because of deficiencies in the models, especially for the extremely valuable Lakelse lake and river fishery.
5.1 The impacts on fish through forest operations associated with this mill have already been discussed (see comment 4 Forests above).
5.2 See comment no. 25 Air pollution above. Our rains are approaching the critical pH of 4.5 where all fish are killed off.
Nature Trust:
6.0 Nature Trust has two ecological preserves on Lakelse lake, one at the north end and one at the south end.
Air emissions from the mill can be expected to impact on the flora and fauna of these areas, so that the ecology of these areas is jeopardized by this development. Oddly, I saw no mention of these Nature Trust areas anywhere in the review. An ecological preserve located at Hai Lake in the Thunderbird could also be impacted by this development.
Rare or Endangered Plants
7.0 Two Species Identified in the Mill General Vicinity
Gnome plant was mentioned by Pojar as being present in the area, and I have found Chocolate Lily in the Lakelse lake area.
7.1 Potentially Present and Impacted but Not Inventoried for EIA
However, a more complete list of plants potentially impacted by ecosystem changes is the following attributable to Schofield, Taylor, Pojar and TERA: Bryhnia hultenii found in swamps, near streams or rivers, on logs in bog-muskegs alluvial conifer forests is infrequent, endangered; Campyplopus schwarzii on cliffs overhanging river in montane communities is infrequent and endangered; Habrodon leucotrichus, an epiphyte on yellow cyrpess or shore pine humid cliffs in bog-muskeg coastal forest very likely at the south end of Lakelse Lk-infrequent, endangered; Isoptertgiopsis muelleriana on humid cliffs-infrequent, endangered; Pleuroziopsis ruthenica in floodplain areas of alluvial coastal forest-endangered, infrequent; Sphagnum aongstroemii localized on cliffs in montane communities-infrequent, endangered; Lepidozia sandvicensis in wet areas near coast in bog muskeg-rare; spiny woodfern in mountains, open rocky slopes in pine forest-rare; Water star aquatic rooted in mud in tidal marsh aquatic communities occasional, rare, uncommon, infrequent; Dwarf azalea in bogs in bog-muskegs-rare; gnome plant already mentioned; white gentian in bogs, tundra, lake margins in bog muskeg-uncommon; mudwort in shallow water or wet mud to tidal marshes and aquatic communities-uncommon; Wapato in swamps, ditches, ponds and lakes in tidal marshes, bog muskegs, aquatic communities-rare but widespread; water plantain in marshy areas in tidal marshes and bog muskegs-rare in northernmost part of range; flowering quillwort, shallow water at edge of ponds, tidal flats to interior valleys, tidal marsh, bog muskeg, aquatic communities-very rare northernmost range; slough sedge on wet ground, standing water along rivers or coastal swamps in tidal marshes, bog muskegs, alluvial conifer forest; chocolate lilly in moist areas near tide flats to mountain meadows, tidal marshes and also at Lakelse lake-fast disappearing; Austin's phantom orchid in moist deep coniferous forests in coastal forest alluvial conifer forest-unconfirmed sighting; western twayblade orchid moist places lowland to subalpine in coastal forests, uncommon.
7.2 Evidence of Lack of Proper Consideration of Rare and Endangered Species in the Vicinity
Endangered or rare plants have undergone no systematic inventory that I can see in this EIA. Had they done so, they would have undoubtedly picked up the chocolate lilies at Lakelse Lk. This is a significant oversight and suggests that other important considerations have also been overlooked by this EIA, perhaps as regards rare and endangered animals.
The MPRP Process:
8.0 Need For New Administratively Fair Process Pre-Approval
The MPRP process has been well critiqued in the Nisga'a Review of the Orenda proposal and the reader is referred to this document (see The Orenda Papermill. A Response, Submission to the BC Major Projects Review Committee by the Nisga'a Tribal Council. February 1991.).
Its conclusion that the process seriously lacks administrative fairness is well supported.
How we can employ a process which has so clearly been shown to be defective to reach a decision of such long term and far reaching import, when there is time and a sympathetic government to make the needed changes prior to reaching a decision, is a question that needs to be addressed.
8.1 Rejection by a Majority
It is my understanding that the majority of people who attended the open houses held by Orenda were opposed to the mill at this site. I do not see how we can call ourselves a democracy if we let it go ahead on this basis alone.
9.0 Summary and Recommendations
The Orenda MPRP review is flawed technically and administratively.
Key issues are raised in every aspect of which I examined and had I examined more, I would undoubtedly have found more.
The most important conclusions I reached are these:
i) Air pollution will be harmful to the ecology, health, recreation and tourism and zero effluent means increased air pollution returned as water pollution in other locales.
ii) The water supply is not a certitude in the long term.
iii) Special waste management problems will occur in the long term and these were not dealt with.
iv) Proper planning steps have not been taken in north and south Kalum TSA RMP or LRUP planning by MOF and public review of these plans would impact on Orenda's proposal if they were not being disallowed by an improper MOF review schedule.
v) A precedent will be set by Orenda which will launch the eventual degradation or pollution of Lakelse river and Kitimat river and Kitimat estuary.
vi) A precedent would be set by Orenda mill, which would eventually result in the alienation of prime forest lands between Terrace and Kitimat.
vii) Pressures placed upon regional fish and wildlife and plant life, both common, game and non-game, and rare and endangered, have not been properly considered in the MPRP though these would be impacted by the type of demands and or pollutants placed on their habitats.
viii) The timber supply is probably not there to meet Orenda's needs and all future uses of the forest in an integrated planning framework and in the light of new ecological forest management planning beyond 2001 and almost certainly not beyond the projected fall down time frame.
ix) The MPRP process is unfair administratively by the Ombudsman's criteria and undesirable by a democratic yardstick for there was apparently a rejection of the mill at this location by a majority of the northern public who attended public meetings on the mill impacts.
While this mill would bring new pollution abatement technology to Canada, it is not going to replace any existing polluting mills. This type of mill should ideally replace the pulp mills on the Fraser river. It is being added to the burden of pollution in Canada, and thus is indefensible.
In conclusion, from the sheer weight of evidence of errors, over-sights, data gaps, insupportable speculations, and failures to consider and so on, I recommend that this proposal be rejected until proper planning steps taken in both south and north Kalum TSA be completed, and reconsidered only after all of the technical and other concerns I identified in this critique are effectively addressed.
©
1990 Jorma Jyrkkanen . All rights
reserved.
Tag: Ground woodmill, EIA, Impact, assessment, Jorma Jyrkkanen
No comments:
Post a Comment