Kamloops:Kamloops:Not a Place to BurnNot a Place to Burn

Paul Connett, PhDPaul Connett, PhDExecutive DirectorExecutive Director

American Environmental Health American Environmental Health

Studies Project (AEHSP)Studies Project (AEHSP)www.AmericanHealthStudies.orgwww.AmericanHealthStudies.org

pconnettpconnett@@gmailgmail.com.com

Kamloops, BC, Sept 1, 2009Kamloops, BC, Sept 1, 2009

The problems with the The problems with the Kamloops gasification plantKamloops gasification plant

1) Inexperience of the operator1) Inexperience of the operator 2) Scaling up from a small research 2) Scaling up from a small research

project to a commercial operationproject to a commercial operation 3) This Gasification plant is an 3) This Gasification plant is an

incinerator in disguiseincinerator in disguise 4) Kamloops is not the place to run a 4) Kamloops is not the place to run a

burning experimentburning experiment 5) Commercial gasification plants 5) Commercial gasification plants

have a dismal track recordhave a dismal track record

The problems with the The problems with the Kamloops gasifying Kamloops gasifying incinerator (continued)incinerator (continued) 6) Burning any kind of waste is dangerous6) Burning any kind of waste is dangerous 7) Creosote treated ties presents a complex 7) Creosote treated ties presents a complex

burning problemburning problem 8) Creosote treated ties may be the thin 8) Creosote treated ties may be the thin

end of the wedgeend of the wedge 9) Disposal of toxic by-products 9) Disposal of toxic by-products 10) Incineration of any kind threatens local 10) Incineration of any kind threatens local

democracydemocracy

1) Inexperience of the operator1) Inexperience of the operator

The company has not a run facility of The company has not a run facility of this type anywhere else - or any other this type anywhere else - or any other facility!facility!

This company seems to have more This company seems to have more prowess at putting business deals prowess at putting business deals together and attracting government together and attracting government grants than it has in engineering skillsgrants than it has in engineering skills

The people that push these in North The people that push these in North Dakota appear to be far more Dakota appear to be far more interested in making energy than the interested in making energy than the subtle problems of air pollutionsubtle problems of air pollution

Stantec, August 25, Stantec, August 25, 20092009 Section 4. Air EmissionsSection 4. Air Emissions 4.1.1 Engine emissions4.1.1 Engine emissions The emission rates and stack parameters for The emission rates and stack parameters for

the two 1 MW internal combustion engines the two 1 MW internal combustion engines were calculated based on were calculated based on preliminary datapreliminary data obtained from tests conducted by the Energy obtained from tests conducted by the Energy & Environmental Research Center (EERC & Environmental Research Center (EERC 2008;EERC 2009)…2008;EERC 2009)…no data givenno data given

Table 2 gives estimated emission rates in Table 2 gives estimated emission rates in grams per second for SO2, CO, NOx, PM grams per second for SO2, CO, NOx, PM (PM2.5)(PM2.5)

Air Emission data -very Air Emission data -very limitedlimited Does not include data on:Does not include data on: NanoparticlesNanoparticles Dioxins and FuransDioxins and Furans Hydrogen chlorideHydrogen chloride Heavy metalsHeavy metals Only single numbers for pollutants Only single numbers for pollutants

reported - no indication of range of reported - no indication of range of data, or whether the single numbers are data, or whether the single numbers are averages, highest value or 95% upper averages, highest value or 95% upper confidence numbers.confidence numbers.

2) Scaling up from a research project2) Scaling up from a research project

According to an article published in According to an article published in Environment Protection (eponline.com) Environment Protection (eponline.com) date date June 2, 2009June 2, 2009

““EERC’s power system, which has been EERC’s power system, which has been under construction for two monthsunder construction for two months, can , can process process 35-40 lbs35-40 lbs of fuel per hour” of fuel per hour”

Proposed plant in Kamloops would handle Proposed plant in Kamloops would handle 7000 lbs per hour7000 lbs per hour

Stantec claimed to have used emission Stantec claimed to have used emission levels based on tests by EERC in 2008 levels based on tests by EERC in 2008 and 2009 - and 2009 - how could they have got 2008 how could they have got 2008 emission data, if it had only be running emission data, if it had only be running two months in June 2009 ????two months in June 2009 ????

Stantec, August 25, Stantec, August 25, 20092009

The emission rates and stack parameters for The emission rates and stack parameters for the two 1 MW internal combustion engines the two 1 MW internal combustion engines were calculated based on were calculated based on preliminary datapreliminary data obtained from tests conducted by the Energy obtained from tests conducted by the Energy & Environmental Research Center (EERC & Environmental Research Center (EERC 2008; EERC 2009)…2008; EERC 2009)…

Inconsistent claimsInconsistent claims ACC claims this is a closed loop ACC claims this is a closed loop

system. It is not:system. It is not: A) because the syn gas is A) because the syn gas is

burned in an internal burned in an internal combustion enginecombustion engine

B) because the facility operates B) because the facility operates with a flare systemwith a flare system

The use of the flare The use of the flare stackstack ““The flare stack will be used for The flare stack will be used for

start-up, shut-down, and start-up, shut-down, and unplanned events (less than 5% of unplanned events (less than 5% of the time).”the time).”

ACC Permit application to MOE, ( June 2009)ACC Permit application to MOE, ( June 2009) These are periods of maximum These are periods of maximum

dioxin emissions!dioxin emissions! Could be over one hour a day!Could be over one hour a day! Could be over 17 days a year!Could be over 17 days a year!

4) Kamloops is not the place 4) Kamloops is not the place to run a burning experimentto run a burning experiment

Kamloops has a large populationKamloops has a large population Your river is perhaps the most Your river is perhaps the most

precious you haveprecious you have Kamloops has a topography which Kamloops has a topography which

does not allow ready dispersal of does not allow ready dispersal of pollutants from its air shed (inversions pollutants from its air shed (inversions etc)etc)

Your air shed is already overburdenedYour air shed is already overburdened You have over two times the average You have over two times the average

background levels in Canadabackground levels in Canada

BC Fine Dust (2006 BC Fine Dust (2006 Ministry of Environment)Ministry of Environment)

4) Kamloops is not the place 4) Kamloops is not the place to run a burning experiment to run a burning experiment (cont)(cont) You are already suffering the You are already suffering the

consequences of that pollutionconsequences of that pollution Higher asthmatic rates etcHigher asthmatic rates etc You don’t need to make that worseYou don’t need to make that worse These railroad ties are going to come These railroad ties are going to come

from a very large region - is this the from a very large region - is this the best location in that whole region to best location in that whole region to build such a facility?build such a facility?

5) The track record of 5) The track record of commercial gasification plants is commercial gasification plants is dismaldismal See the difference between the See the difference between the claimsclaims

and the and the reality reality of gasificationof gasification in thein the report “Incinerators in Disguise”report “Incinerators in Disguise” from from GreenAction (GreenAction (greenaction.orggreenaction.org) and ) and GAIA (GAIA (no-burn.orgno-burn.org))

There are a few commercial There are a few commercial gasifying plants burning clean gasifying plants burning clean woodwood

BUT none handling creosote BUT none handling creosote treated woodtreated wood

Again this is an experimental Again this is an experimental facility with very little supporting facility with very little supporting emission dataemission data

Kamloops is not the place for Kamloops is not the place for such an experimentsuch an experiment

GASIFICATION, GASIFICATION, PYROLYSIS PYROLYSIS

Engineering consultants’ view:Engineering consultants’ view:

““Many of the perceived benefits of Many of the perceived benefits of gasification and pyrolysis over gasification and pyrolysis over combustion technology proved to be combustion technology proved to be unfounded. These perceptions have unfounded. These perceptions have arisen mainly from inconsistent arisen mainly from inconsistent comparisons in the absence of quality comparisons in the absence of quality information.”information.”

Fichtner Consulting Engineers Ltd, Stockport, Fichtner Consulting Engineers Ltd, Stockport, Cheshire, March, 2004Cheshire, March, 2004

Lurgi (a major engineering Lurgi (a major engineering company) company) pulled out of the pulled out of the gasification business in gasification business in 2003 2003 (see letter)(see letter)

6. Burning any kind of 6. Burning any kind of waste is dangerouswaste is dangerous Burning produces toxic air emissionsBurning produces toxic air emissions Burning is never complete - YOU ALWAYS Burning is never complete - YOU ALWAYS

GET products of incomplete combustion GET products of incomplete combustion (PICs)(PICs)

Elements cannot be destroyed with Elements cannot be destroyed with burning. Any toxic metals present in the burning. Any toxic metals present in the waste are releasedwaste are released

As you get better at protecting the air, the As you get better at protecting the air, the collected residues (solid or wet - fly ash of collected residues (solid or wet - fly ash of scrubbing effluent) are more toxic and scrubbing effluent) are more toxic and more expensive to get rid ofmore expensive to get rid of

AIR EMISSIONS

CO2 + H2O

ACID GASES:HCI, HF, SO2

NOx

TOXIC METALS:Pb, Cd, Hg, As, Cr etc

NEW COMPOUNDSNEW COMPOUNDS::

PCDDs (DIOXINS)PCDDs (DIOXINS)PCDFs (FURANS)PCDFs (FURANS)PCB’sPCB’sETCETC

NANONANOPARTICLESPARTICLES

Incineration andIncineration and nanoparticles nanoparticles Nanoparticles are not Nanoparticles are not

efficiently captured by air efficiently captured by air pollution control devicespollution control devices

Travel long distancesTravel long distances Remain suspended for long Remain suspended for long

periods of time (especially periods of time (especially during air inversions over during air inversions over cities)cities)

Penetrate deep into the lungsPenetrate deep into the lungs

We already know that We already know that air particulate matter air particulate matter causes many health causes many health problemsproblems

RESPIRATORY PROBLEMS RESPIRATORY PROBLEMS related to air particulaterelated to air particulate

• Allergies

• Asthma

• Acute and chronic bronchitis

• Emphysemia

• lung Cancer

PM 10

PM 2,5

Slide from Dr. Ferninando LargiSlide from Dr. Ferninando Largi

BLOODBLOOD

Nano particles are Nano particles are so small theyso small they

can easily crosscan easily cross the lung membranethe lung membrane

Nano PathologyNano Pathology

Once nanoparticles Once nanoparticles have entered the have entered the bloodstream they bloodstream they can easily cross the can easily cross the membranes of membranes of every tissue in the every tissue in the body.body.

Nano PathologyNano Pathology

They can even cross the blood They can even cross the blood brain barrierbrain barrier

7) Creosote treated ties 7) Creosote treated ties presents a complex burning presents a complex burning problemproblem Creosote is derived from coal tarCreosote is derived from coal tar It contains over 200 compounds includingIt contains over 200 compounds including benzene,benzene, phenols,phenols, polyaromaticspolyaromatics Many of these substances are carcinogenicMany of these substances are carcinogenic All are precursors for dioxin and furan All are precursors for dioxin and furan

formation when burned if there is a source of formation when burned if there is a source of chlorine available. Chloride ion is present in chlorine available. Chloride ion is present in wood.wood.

Commercial wood burners emit dioxinCommercial wood burners emit dioxin

8) Creosote treated ties 8) Creosote treated ties may be the thin end of may be the thin end of the wedgethe wedge

A huge concern is that in addition to A huge concern is that in addition to creosote treated tiescreosote treated ties

The plant will “accidentally” or out The plant will “accidentally” or out of “economic necessity” burn ties, of “economic necessity” burn ties, or other wood, treated with or other wood, treated with pentachlorophenol or copper pentachlorophenol or copper chromium arsenatechromium arsenate

And/or wood derived from And/or wood derived from construction and demolition debrisconstruction and demolition debris

9) Handling of the residues 9) Handling of the residues presents another burden on the presents another burden on the communitycommunity

The plant will produce solid residues - The plant will produce solid residues - bottom or furnace ash/char and possibly bottom or furnace ash/char and possibly fly ashfly ash

If a wet scrubbing system is used it will If a wet scrubbing system is used it will also produce a liquid effluentalso produce a liquid effluent

These will be passed onto the community These will be passed onto the community for disposalfor disposal

This may be a blessing in disguise as it This may be a blessing in disguise as it will provide a point of intervention by will provide a point of intervention by local decision makerslocal decision makers

Local interventionLocal intervention

1) Councilors should be encouraged to set up 1) Councilors should be encouraged to set up a “task force” to investigate the impacts that a “task force” to investigate the impacts that this facility will have on the local community, this facility will have on the local community, which can have far broader terms of which can have far broader terms of reference than the provincial bureaucratic reference than the provincial bureaucratic assessment.assessment.

2) A full environmental impact assessment 2) A full environmental impact assessment needs to be undertaken to assess the needs to be undertaken to assess the impacts of local disposal of the solid and impacts of local disposal of the solid and liquid effluents from this facility.liquid effluents from this facility.