Time to Investigate, Improve and Augment Aerial Fire Fighting. Commit to the Martin Mars.

This is a followup to BC Wildfire Tanker Cost FOI — The Devil is in the -redacted- Details.  Download the full FOI Release here: Reconsideration FOI (PDF) Download the Excel Spreadsheet here: XLS file or PDF file

Do the poll on the side or leave a comment!
CHALLENGE #1:

Will the parties and subsequent new Provincial Government, commit to re-evaluating the effectiveness of its FIRE FIGHTING STRATEGY and USE OF AERIAL RESOURCES?  Are we attacking fires effectively in order to keep overall costs down?  Does the current ‘let it burn’ strategy still apply with new and extreme fire behaviour? Should we implement ‘no-go-zones’ in regions near population centres with heightened surveillance and much improved initial-attack response times in order to keep uncontrolled burning to an absolute minimum?  Have we implemented the recommendations of the Commissioners report produced after the Kelowna Fires?

CHALLENGE #2:

Will the New Provincial Government, re-evalutate its tendering process, make long term firefighting contracts open and public and ban the receipt of donations from prospective firefighting companies as well as impose limits on how government and industry professionals and move between sectors that would avoid potential conflicts of interest.

CHALLENGE #3:

Will the New Provincial Government, invest in the upgrade of both Martin Mars aircraft to modern turbine engines to reduce fuel, maintenance, and positioning costs and ensure these aircraft are in the provincial arsenal for the forseeable future and further, create lake bases across the province for all amphibious and flying boat aircraft to use in times of need as inevitable fire fighting emergencies will continue to increase as climate change impacts our province?

In the words below I submit the information that I believe supports implementing these initiatives.

The Government Fact Sheet Debunked by Government Information.

As announced by Airspray on their Facebook page on Sunday, Monday April 24 marks the start of the 2017 Fire Season.  At this time in 2016, I had already been in contact with the Ministry for a request for information on contracts and flight and fuel costs.  The full information was initially redacted and, after a complaint to the Commissioner, was not released for 6 months. In January I finally got the email. It has taken me this long to slog through the numbers and create a report.

So here is a little reach back in order to tie up those loose ends.  In summer 2014, when fires raged and controversy peaked on the absence of the Martin Mars aircraft including a 19,000 signature petition, the Government released a “Fact Sheet” it was thoroughly debunked with available information.

However, some questions lingered due to a lack of full cost information especially, that was the purpose of the FOI and new facts released by the Ministry have helped clear things up.

The Ministry claimed “four new fire bosses cost $2.5 Million per fire season” plus hourly rates.  The FOI reported cost for 2015 was $2.1 Million excluding the birddog and a total of $3.3 Million including flight and fuel costs for 600 hours of work.  The Martin Mars cost $450,000 on standby for 30 days and another $456,000 for flight and fuel.

Fuel costs are estimates as only average fuel consumption numbers were provided by the Ministry.  According to my discussions with the Ministry, actual billed fuel costs seem to be tracked nearly manually and are not coalesced electronically. This would have required a massive cost in time and effort to bring together that I could not afford or justify.

Why are fuel costs, surely the cost most susceptible to extreme fluctuation, not tracked more comprehensively and transparently?

Hourly flight rates between the various types of aircraft turn out to be very similar.  2015 rates, excluding fuel, are around $6000-$6500 for Martin Mars and Air Boss Groups, bird dogs are included, and $4000-4500 for CV580 or L188 Air Tankers.

Actual fuel consumption rates are also very comparable between flight groups.  A pack of 4 Airboss aircraft have an average fuel consumption of 1400 Litres per Hour (350 each), slightly less for the wheeled types.  The workhorse CV580 and L188 fire retardant air tankers use between 1400 and 2800 Litres per hour respectively.  And the biggest aircraft, Martin Mars, consumes 2850 Litres per hour.

Perhaps the most emotional topic brought forward during the debate was age.  The FOI request revealed not only the age of all of the aircraft in the provincial arsenal, but more importantly for aircraft, the flight hours.

The AirBoss aircraft are essentially new.  The oldest planes were built in the 1990s but most were built in this century.  However, the veteran aircraft in the arsenal are the CV580, L188 Electra aircraft.  These aircraft are between 40 and 65 years old and yet log hundreds of hours a year from bases around the province.  Their airframe hours (reported in 2010) range from 14 to 24,000 for the Airspray L188s and 52 to 81,000 hours for the ConAir L188 and CV580s.  The Martin Mars aircraft, according to information provided to me by the company, are as of 2017 at 21,326 hours and 23,497 hours for the Philippine and Hawaii Mars aircraft respectively.  For the Hawaii Mars, the aircraft used last in 2015, just 3,459 of those hours were since conversion to Fire Bombing in 1964.

The biggest challenge for the Martin Mars is not age or ability, it is maintenance of its engines and the cost and availability of the “AVGas” fuel needed for the piston engines compared to “Jet A” used by turbo-prop aircraft.

The cost to replace the piston engines with fuel efficient and more powerful turbo-props have been suggested to be in the $10-$30 Million per plane.  Would that one-time cost be worth it if the planes could give us 5000-10,000 more hours each of forest fire fighting time over the next 40 years?  Given the changes in weather that we can expect in that same time, I believe so.

CONTRACTS FOR LIFE

Away from the technical details, the contracts themselves should really be a cause for concern. They are invariably long term, and rarely changing… demonstrated in the excerpt below:

Last Line of the 2008 annual modification with Airspray. Document shows it was reused from Year 2000 contract.

Agreements are 7-10 years with modifications each fire season to specify location, dates, and incremental increases in costs if they are different from the template.  The process has essentially gone unchanged, and unchallenged, for probably 20 years if not longer.  And yet, the public does not have access to these contracts.  They are not overly complex. And their cost should not be a state secret.  We already know the bottomline numbers for the cost of wildfire firefighting in British Columbia.  The public deserves to know more detail.

The call for proposals for the 2007 Air Tanker Service contract above is still on the website and shown below.Note that Jeff Berry, the Provincial Air Tanker Manager in 2007, is now Vice President at ConAir.

Over that time, there can be no doubt that ConAir in particular has benefited to the tune of millions upon millions of dollars in contract and flight/fuel costs compared to the other two companies.

ConAir provided 5 groups comprising 18 aircraft for the 2015 season compared to 4 planes from Airspray (up from 2 since 2008) and 1 from Coulson (down from 2 in 2007).  The total bill shared in standby costs to three companies in 2015 was approximately $15.7 Million.  About $12 Million of that went to ConAir.  With flight and fuel costs you can add another $18 Million being paid for Provincial air tankers with only $450,000 of that going to Coulson/Martin Mars and $5 Million going to Airspray.  So in total ConAir, in one year, walked away with business totalling as much as $24 million on a total BC Wildfire cost of $277 million.  About 1/10 of the entire budget.  Is that right? That is what the information seems to suggest. We need more transparency.

Donating to Political Parties, or not, is just as consistent.

Since March 2005, ConAir has donated $100,000 to the BC Liberal Party and $2500 to the NDP.

Coulson started donating politically in 2009 and has donated $9450 to the BC Liberals and $5350 to the NDP.  Airspray is not listed as having donated to either party.

You can get there from here.

Finally, remember when the Province said the Martin Mars was not that great because of the small number of lakes it could use in British Columbia?  The FOI included the list of lakes, both those suitable for bases, and those just for scooping.

I have plotted them in Google Earth.

Here are the Bases.  These lakes represent places where not only the Mars could be based, but any amphibious or flying boat aircraft could be repositioned in times of need.  Except for those way up north, they are all within a few miles of a major population centre able to provide logistics and support.  If there is not already facilities for floating aircraft, these are the places BC should invest in staging areas to facilitate the use of all firefighting water-borne aircraft.

The circles are 600km radius showing the historical range the Martin Mars has demonstrated. For example, from its base in Port Alberni to a fire in Nelson. From bases in BC the Martin Mars can cover all of the province, plus most of Alberta, Washington and parts of Yukon and Oregon.

These are lakes able to be used by the Martin Mars for scooping.  Most are near population centres, where extreme fire conditions are most likely to require extended attention.  It is likely that these are the most commonly used lakes for all firefighting activity by amphibious or flying-boat aircraft.

Rebasing the Martin Mars is certainly one of the key reasons it is expensive to operate.  The amount of support people and materiel that moves with the Mars means an extra $13,000 a day in costs. However, as we saw with the fires in 2003 in the Interior, when you need them, they are worth the cost. A basing scheme with permanent staging points that benefits more than just the Mars would maximize their use and minimize the costs of all water-borne aircraft.

One last thing, that fancy plane.

Remember when Provincial Cabinet Minister Mike De Jong announced in February 2016 that the BC Government would be evaluating the RJ-85 Avro jet powered fire fighting aircraft for the first time in the 2016 fire season?

FOI records do not show any new contract being awarded.  The RJ-85 had already been on a ‘supplementary’ list for additional aircraft since at least 2014.  The RJ-85 has not been used in BC for fire fighting according to the information provided. The information does show that two RJ-85s were flown for a total of 9 hours at zero cost to the Province in 2014. By the way, by the way, is around 2,400 Litres per hour, in line with the all ‘heavy’ fire fighting aircraft.

Take out the Politics. We need all hands on deck.

As I have delved into this topic over the years one truism came up again and again… aerial fire fighting is political.  And here we are, in the middle of a provincial election proving that point once again.

We need a government that will take the politics out of it.  We need a government that will not be influenced, or even be perceived as influenced by political donations from companies that provide its services.  Will the any of the parties commit to this?

In light of the challenges faced us with climate change and the new fire behaviour that it is creating, are we providing adequate protection to our forest service?  Is the Air Tractor, which has had notable safety as well as personnel problems investigated by Transport Canada, the right system for the job?

I believe all of the planes in the provincial arsenal are valuable and need to be used to their maximum potential.  We need to find the best way to minimize the potential for loss of life, property, and resources in BC and a robust initial attack.  Aircraft should not be retired out of spite, or misplaced ‘ageism’. We need and deserve as British Columbians a full costing of the forest firefighting world and an analysis of how best to minimize those costs both now, and in future conditions in 10, 20, or 50 years.

The technology is unlikely to change much in that time, but it seems certain that expectations for success are certain to only rise.

Media Contact: 250-731-7930

 

 

A slow, but determined, walk uphill toward reconciliation.

Not just a gathering

Something happened on a chilly and drizzly Monday afternoon and it wasn’t just a bunch of people milling about at Harbour Quay and then walking to City Hall. On March 27th, 2017 two leaders in this community, Cynthia Dick, Chief Councillor of Tseshaht First Nation, and Jolleen Dick, Councillor of Hupacasath First Nation organized a gathering to speak against systemic racism in Port Alberni.

It succeeded in bringing together a huge amount of people, here on the unceded territory of the Tseshaht and Hupacasath First Nations.  All of these people were together to acknowledge that territory and acknowledge the pain that racism and hatred toward First Nations and toward one another has caused over the years and continues to cause today.  Here are three big things I gained from the experience at the Walk for Reconciliation.

A long Walk uphill.

It is a long, steep journey up Argyle hill from Harbour Quay to City Hall.  There were 200-300 people, trudging up the hill together.  It was made easier because we were all together, we all had someone to talk to and share stories with. We were together in common cause and purpose, and it felt good. When you feel good about something, when you are with friends, when you know someone, or a lot of someones, have your back, it is a lot easier to tackle hard climbs.  This will be a slow process, this reconciliation, but people are determined. Some will not be able to make the journey on their own and will need help.  Others will not be able to participate at all but will meet us there at the finish line in full support.

A Song sung by All.

If you’ve followed me at all on Facebook you might have seen a Kinder Morgan protest march I participate in that featured a very strong First Nations presence.  One of the big moments of that rally of tens of thousands strong was at the end, when a huge circle of Indigenous peoples from all over BC and elsewhere sang and drummed and they asked the crowd to join in. This was the first time I had participated in something where First Nations so openly invited all into their celebration and exclamation. It was very powerful and I think it made a real impact on people there.

There were a number of great songs sung at the Walk for Reconciliation on Monday.

And as Trevor Little of Tseshaht passionately led the final song in front of City Hall, drummed and sung by members of Tseshaht and Hupacasath and others, he encouraged the whole group to join in.  Which it did, a little timidly perhaps, but it did.  For this to be happening in my hometown. A town known for its divisions between races, even between neighbours, was very powerful.  It was a wonderful moment and I thank Mr. Little especially for his passion and outspokenness.

Not just something to wear for the day

Finally, one last thing.  When I first got there, John Alan Jack, councillor for Huu-ay-aht First Nation and Chair of the Alberni Clayoquot Regional District, walked up and offered me this head dress to wear.

He and other First Nation leaders were wearing similar features. I took it and wore it out of respect, but honestly I did so without really knowing what it symbolized.

After the event had wrapped up I walked back up to John and asked if I should give it back.  He very kindly told me it was not something to return but something to wear at events of importance or where learning was taking place. It was a way to focus the mind on the task at hand and it was now mine.

I don’t seek out gifts from others, and so when I am given one of symbolic importance it is important to me.  I want to thank Councillor Jack for his gift.  I am still not entirely confident on how and when is the right time (and may bug John occasionally for advice) but I deeply appreciate the gesture.

I think it is safe to say that Charles Thomas (picture above, courtesy Jen Fisher Bradley) and many other Aboriginal and non-Aboriginal residents of Port Alberni had a lot of fun yesterday.  It was a wonderful event put on by two inspiring leaders in our community, supported by their Nations, and supported by the wider community in an unprecedented way. I hope we have all been able to come away with something of value from the event. I know I did, both in the form of a gift and in the knowledge that Port Alberni might just be ready to heal and grow.  There are no set dates or defitinitions to this. We do not know if this is really the start of real reconciliation or not (I think it is), it comes down to the feeling in the community as a whole and the true relationships between people.  The start and end are fluid, but I think we will know in time, when we have made good progress.

Klecko Klecko.   ….. now… if I could just convince my keyboard to write that in the proper Nuu-Chah-Nulth, we’d have another step up the hill. HELP! 🙂

Update! See it always helps to ask for help.  Here is where you can download keyboard layouts for a huge array of Indigenous Languages and install them on your Mac or Windows computer.  You are looking for Nuučaan̓uł under the Wakashan group of languages.

For iOS users, you can grab the First Voices App and add the Keyboard Layout to your screen!

And if you just need a quick character translation, you can go to this webpage here!

ƛlecko ƛlecko!

Updated Jan 12 – A Question of Honour and Reconciliation

Updated Thursday Jan 12 Below

Some updates since the weekend:
The Hilton Centre has estimated the cost of a transition coordinator to manage the change of address at $13-$16000.  I will encourage Council to cover this cost either through the Community Grants program or directly. Hopefully with the help of provincial and federal grants as well. You can see their letter sent to Council this week at the bottom of the post or here.

Tseshaht First Nation passed a resolution at their AGM supporting the name change of A.W. Neill school.  A motion on the street issue did not pass.

John Alan Jack, Chair of the Alberni Clayoquot Regional District and Councillor at the Huu-ay-aht First Nation was interviewed on CBC Radio Wednesday afternoon.  Unfortunately, a recording is unavailable, but a couple days before he tweeted:

And finally, the National Association of Japanese Canadians sent a letter to the AV News in addition to citizens supporting the Reconciliation efforts.

The support for this historic bit of work seems to be growing and Port Alberni is being watched by groups all over on how it deals with this important issue.


Hi everyone,

Below you will find a document I have been working on since early December on the issue of Honouring and Renaming Indian Avenue and Neill Street. I didn’t decide to move on with it until after the last council meeting in December.

So that everyone is on the same page with the same information with this difficult conversation, please read the document and this post in full before commenting.

This document is a draft. It is only my research. There may be errors and it will change and be updated. If you see an error please let me know.

These are my personal writings. This does not represent the City of Port Alberni.

If you have any trouble viewing the document below, you can download it directly here.

The report includes justifications, history, suggestions on alternative commemorations, costs, and implications for residents and non-residents.

Download the PDF file .

This is an issue that came to me from Chris Stevenson.  Below is an interview he did last week with CBC on the topic. He did a paper on A.W. Neill and we started talking about it a few months back with Trustee Rosemarie Buchanan when the school was being switched to an Elementary School.

The motion I will introduce tomorrow (the 9th) will be:

That Council for the City of Port Alberni, in the spirit of Reconciliation, work with the Hupacasath and Tseshaht First Nation Councils, the Community and any affected property owners to potentially rename Neill Street.

You might notice mention of Indian Avenue has been removed.  After talking with Jolleen Dick of Hupacasath I have decided to remove that at this point but I have kept it in the document since it was part of the original intent and so all of the information is there.

You will also see it says “potentially”. While I believe the renaming should proceed, no final decision will be made on the 23rd when the motion comes up for debate, only a decision on whether to move forward and start the consultation process with property owners, First Nations, the NTC and cultural groups and anyone else affected.  This was also my intent from the outset.

Reconciliation is an issue that requires a commitment to calm, thoughtful discussion in order for all views to be heard and respected. I invite your constructive feedback in the comments section.

I have shared this document and post with my fellow Councillors and I will bring it to the Council meeting with the Motion on January 23rd.

What the document does not mention in large part yet is the opportunity for healing.  What ceremonies could we undertake? What new memorials could we create?  What new understandings could we come to as we acknowledge and work through the pain of the Indian Residential School system, Japanese Internment, and Anti-Immigrant sentiment that have deeply affected our communities?

Those are the questions I would really like to hear answered as they are the ones I think we can get to now that this conversation has begun.  It will not solve the Reconciliation question overnight, but I hope it will get us a little ways there.

Please also consider the words of the others involved to this point, Chief Cynthia Dick of Tseshaht, Councillor Jolleen Dick of Hupacasath, Trustee Rosemarie Buchanan of SD70 and others in this AV News article.

Chuu

Chris

Download the PDF file .

(Updated Dec 21) CanTimber Golder report raises serious concerns that must be addressed before restarting

(Updated Dec 21)

Subsequent the City of Port Alberni has released a statement on the report.  Here is the City of Port Alberni’s statement.

Earlier this week, the Port Alberni Port Authority publically released the evaluation of operations and emissions at the Cantimber Biotech facility. The evaluation was conducted by Golder Associates, an independent consulting firm with expertise in emission measurement and controls and air quality permitting.

The report provides a thorough review of Cantimber’s operation with key findings and recommendations regarding the facility operation, emissions testing, air quality, and other regulatory considerations.

While the report outlines Cantimber’s general compliance with many of the provincial limits for emissions, there are air quality concerns identified that the City feels must be addressed before operations resume.

The City of Port Alberni’s paramount concern is for the health and welfare of the community. As such, the City is committed to working with the Port Alberni Port Authority, Golder Associates, Cantimber, the provincial health and environmental authorities, Hupacasath and Tseshaht First Nations, and the many regional partners to ensure the facility’s operation is safe and environmentally responsible.  The City’s support of Cantimber operating in the community is contingent upon their being consistent with the high environmental standards that were committed to at the developmental stage of this venture.

Cantimber has expressed a strong commitment to fulfil the operational and emissions improvements identified in the report. The City remains confident in the opportunities to establish and grow an eco-industrial forest products cluster within the Alberni Valley as an economically and environmentally responsible component of our existing forest-based economy.

As the regulatory authority, the Port Alberni Port Authority(link is external) will be providing further information regarding the operational status and progress of Cantimber in addressing the report’s recommendations.

I in general agree with the City’s statement and their direction on this particularly the expectation that CanTimber operate ‘contingent upon their being consistent with the high environmental standards that were committed to’.

However, one thing the statement does not address is the water treatment and disposal issues that were identified in the report.  As such, I have sent the following letter to City Staff and Council on the topic:

I think the statement is good however, I am concerned by the details in the report of disposal of the scrubbed water. What is in the water (which wasn’t part of Golder mandate)? How is it being transported (plastic containers? Then?), and where is it being disposed of?  I am concerned by the potential noted in the report of that solution overflowing during strong rain events. What happens in that event? What are the consequences and actions? And finally, I am concerned about the cooling water, even though it should be “clean”, simply being sent down the drain.  These all strike me as both City (sewer or waste disposal through acrd) and DFO items.
I would like to please request that these issues be brought up with DFO to see if they have any concerns and some more detail provided by Cantimber or Golder on disposal, etc.
Without these all being addressed fully it will be very hard to convince an already skeptical public.
Thanks for your continued attention to this issue.
Cheers,
Chris

I hope the City will take this water issue seriously and bring DFO to the table.  There was never any indication from the original reports that there would be any potential harm to the Harbour from the operation but I believe the water scrubber material and the hot water discharge put that at risk.  Unfortunately the whole “no emissions” idea just hasn’t held up.

It should also be said that there were positives in the report, and it was not my intent to ignore those.  The particulate and other air emissions were good and well within limits.  It is the NO2, Carbon Monoxide, and the potential for PAHs that were a surprise and I am hopeful that CanTimber takes those concerns seriously and addresses all 21 of the recommendations fully before restarting operations.


Original Post

I have read the report on the emissions testing from engineers at Golder Associates.  These are my personal views on the report.  You can download the report here in PDF.  It is very good. I give credit to PAPA for bringing in Golder. They have produced a comprehensive and objective report.

The Bottomline

I was very hopeful for this facility and believed it could be a new way forward for our industry, but what I have read leads me to believe that at the very least this facility may not be viable in its current location, and at worst it may not be viable at all.  They have much work to do before I would be comfortable with them restarting operations.

This report raises serious concerns on both the air and water emissions. Carbon Monoxide, Nitrogen Dioxide and PAHs were all identified as areas of concern and the water emissions from the scrubbers and cooling equipment are also issues.  The report indicates emissions modelling, ie. what we expected from the stacks and how it would behave, done for the 2015 Levalton report was “not considered to be representative of the facility”.  Carbon Monoxide levels were two hundred and fifty times higher than the licensed limits which is of similar magnitude as an operation the size of Catalyst Paper.

I believe these issues will need input from the Department of Fisheries and Oceans (who has not been involved to this point) and the Provincial Ministry of Environment.  Had this report been provided in place of the Levalton report I personally would not have supported this operation.

It is very far from “emissions free”.

There are major actions that need to be taken by CanTimber in order to ensure this facility is safe and can be properly monitored for their workers, for the neighbourhood, and for the air and marine environment.  Currently, I can’t realistically support it being operated at its waterfront Harbour location.

The Concerns and Recommendations

First, there are 21 recommendations in total.  There are 11 recommendations (shaded in grey) that “should be completed prior to the facilities resumed operation”.

Some are relatively simple like installing permanent monitoring and alarm systems for temperatures and air quality.  Others are much more involved like upgrading the water disposal system to be a contained system that is regularly and safely emptied.

I will go through each of the 11 immediate concerns in order of what I think is most important, though they really should be all taken together and the final recommendation #21 speaks directly to that point.


RECOMMENDATION #10, 11 and 13

….updated modelling should consider emissions of PM2.5, NO2, CO and individual VOCs including Acrolein, Acrylonitrile, Benzene and Napthalene.

…GIven the magnitude of the CO emissions, the modelling assessment should be undertaken to confirm that the level of emissions result in acceptable ambient concentrations of CO prior to the facility re-commencing operations.

Monitoring for CO at the facility and associated procedures should be developed to reduce the risk of worker exposure to CO….

These are the most serious deficiencies, and recommendations, of all of them and it has to do with the emissions from the stacks.

Table 1 provides a summary of the stack test results. A comparison is provided against the emission rates used as the basis of the dispersion modelling assessment undertaken by Levelton (Levelton 2015).

The numbers on the left hand most column are what we expected based on the modelling reports the City and PAPA were provided prior to Cantimber starting up.  CanTimber then agreed to adhere to those numbers (4.15 for Nitrogen Dioxide and 2.08 for Carbon Monoxide).

The Golder engineers bolded the areas of concern in the table.  Most of the emissions are well within limits but there are two, the Nitrogen Dioxide (NO2) and the Carbon Monoxide (CO) that are beyond the limits.  Nitrogen Dioxide is estimated to be double the agreed emissions and Carbon Monoxide more than 250x the agreed standard.

That level of emissions puts the small Cantimber Facility at the same general level as Catalyst Paper. Which Golder illustrates fully in the table below:

That amount of Carbon Monoxide emissions from such a small facility is shocking.

This is also concerning:

Measured stack temperatures are significantly lower than those used as the basis of the dispersion modelling (Levelton 2015). The lower temperatures will result in less thermal buoyancy, and therefore poorer dispersion of stack emissions.

Measured volumetric flow rates, and consequently stack gas velocities are lower than those used as the basis for the dispersion modelling (Levelton 2015).

You can see the flow rates and velocity in the first table above.  The numbers on the far left column should be lower than the numbers on the far right.  Unfortunately, they are not.

These factors together mean that all of that Carbon Monoxide is being emitted into the air and it is not dispersing very well.  Golder identified it as a potential safety hazard for workers onsite.  I would also be worried that it may be a hazard for neighbours including residents and WFP workers as this is a significant new source of Carbon Monoxide in the area.

I personally would never have given my support to a project with those levels of emissions in that location.

Furthermore:

Naphthalene, a polyaromatic hydrocarbon (PAH) was detected within both the carbonization and activation stacks. This was the only PAH compound currently included in the stack test. Based on the presence of naphthalene, stack testing of speciated PAH’s is recommended in the future.

These are potentially harmful emissions.  PAHs are nasty compounds.  These were also not considered a concern based on the previous reports so Golder has recommended that new assessments be done with those in mind.

It is recommended that the modelling assessment is updated for PM2.5, NO2, and CO, and additionally the modelling is used to assess the off-site concentrations of individual VOCs detected, including Acrolein, Acrylonitrile, Benzene and Napthalene.

Again, I would not have been as supportive of a project that produced these toxic chemicals and the fact the previous reports had no mention of even the possibility of some of these compounds is very disturbing.


RECOMMENDATION #6 AND #7:

“The scrubber water disposal system should be upgraded to a contained system prior to the facilities resumed operation. “

AND

“There should be a mechanism/procedure in place to replace the scrubber water as required to maintain efficiency of the particulate removal from exhaust gases.”

This scrubber water, which is in an open-to-the air vessel where the water is collected and evaporates will contain potentially harmful emissions (tars, acids, PAHs etc) from the stack gases.  In a heavy rain event, this vessel could conceivably overflow.  It is imperative that this water be removed in an efficient and safe way.

“The containment may not be adequate, particularly during periods of significant rainfall. During the evaporation, any water soluble organic compounds collected by the scrubbers have the potential to be re-emitted to the atmosphere.

During the site visit, an upgrade to the scrubber water system was discussed which includes capturing scrubber sump discharges within plastic containers, and subsequent removal off site for disposal. It is Golder’s understanding that these upgrades are currently in process and will be in place prior to the re-start of operations. “

I am not convinced that removing the water scrubber discharge in ‘plastic containers’ is very efficient or reliable.

This is also potentially a fishery concern if there is a chance that the system could overflow during heavy rainfall events.

Speaking of fisheries, Recommendation #8:

Cooling water should be adequately cooled prior to discharge to surface drains.

This is *not* a recommendation that is suggested to be complete before restart.  However, here is what is stated from the report during the testing:

“Cooling water discharges were identified during the facility operation. The cooling water is non-contact water that is not in direct contact with the process gases.”

The temperature of the water discharge from the carbonization process “was estimated to be 50-70 °C” and  “was discharged to a surface water drain.”  The temperature from the water discharge from the activation process “was estimated to be 30-40 °C” and “was discharged to a surface water drain (Photograph 1). “

This should be simply city water that is being brought into the facility for cooling purposes only and not have anything added to it so it should be safe, but Golder was not asked to test this water and to my knowledge the Department of Fisheries was not contacted to ensure any discharges into the Marine environment is safe.

In my opinion, DFO should be brought into this process to sign off on the impact to the Harbour from both a potential spill of the water scrubber effluent and from this hot water discharge.  We should also hear from the Provincial Ministry of Environment on what is in the scrubber discharge and where it is being taken.  This would be standard for any industrial operation like Catalyst or Western Forest Products.  The City of Port Alberni may also have a responsibility to provide a sewer hookup for the facility.


Recommendation #2 and #3:

“A low temperature audible alarm is installed on both combustion chambers.”

and

“A datalogger is installed to record temperatures within both high temperature combustion chambers.”

The report states:

“To keep the combustion chambers temperature above 875 °C charcoal was added manually, approximately twice an hour. The timing of the charcoal addition was entirely dependent on the chamber temperature, and was therefore not added on a regular time basis (e.g., every 30 minutes). The temperature in the chamber relied on the operator visually monitoring the temperature read out, and acting to add more charcoal when the temperature decreased close to 875 °C.”

This strikes me as a surprisingly ‘hands on’ and inefficient approach.  A high operating temperature is critical to ensuring emissions are kept to a minimum. This labour intensive approach makes that much more difficult.  Golder recognized this as well as their Recommendation #1 : “The fuel source for the combustion chambers is changed to natural gas, and is automated.” speaks directly to that.  I am a little surprised that Golder did not recommend that that change over to natural gas be done before the system is restarted because this is also a concern that was raised before both by the Air Quality Council (by the Provincial Ministry of Environment) and by the general public.

There are also Worksafe BC concerns around emissions from leaks that were detected from the carbonization equipment itself and to protect the workers in that immediate vicinity.

“During the monitoring a leak was detected near the fire door of eastern furnace #4, which was traced to the nearby syngas valve. Concentrations at the leak location were detected up to 40 ppm. A temporary seal was made to the leak at the time it was detected. Concentrations at the other syngas valves ranged from 200 ppb to 15 ppm.”

Recommendations 4 and 5 address those concerns as there were leaks detected in the equipment during the testing.  They recommend regular testing be done while it is in operation to identify any leaks so they can be resolved immediately and workers are not exposed to harmful emissions and are aware of exposure limits.


Recommendation #9

A meteorological station with a datalogger and web portal access to the data is installed in the proximity of the facility.

The specification and location of the meteorological station should be approved by a suitably qualified person.

There is a serious problem with the assumptions made because the weather at the facility is not the same at the nearest reliable weather station on Alberni Elementary (run by the BC Ministry of Environment)

Given the significant difference in wind pattern between the Cantimber and elementary school station locations, the meteorological data from the elementary school location is not considered to be representative of the wind pattern at the Cantimber facility. Therefore it is recommended that a meteorological station is installed in the vicinity of the facility. This will provide information to use in the investigation of complaints and interpretation of ambient monitoring data. The specification and location of the meteorological station should be approved by a suitably qualified person.

This means that because the modelling done for dispersion of air pollutants for the 2015 report relied on the Alberni Elementary station, it would not match the real world because the wind is so different along the Harbour.  (As anyone in Port Alberni would know).

So I (and the City) made a decision to support the facility based on potentially incorrect data.

This would be an excellent argument for Environment Canada to re-install a meteorological station on the Somass River which should be much more representative of the Harbour, and of the City in general.


RECOMMENDATION #20

Inclusion of a condition in the permit to avoid saltwater contact with the wood chip feedstock.

Golder said:

The permit should include restrictions around the source of wood chips to ensure they are not in contact with saltwater, as this could potentially result in air emissions of dioxins and furans.

This was a surprising finding as I was always under the impression that none of the wood used in the facility was going to come from saltwater booms and so there was no worry about the wood being impregnated with salt which is well known to cause harmful emissions when it is burned, especially at low temperatures.  I do wonder if the simple proximity of the wood to the Harbour may be enough to have them absorb some saltwater from mist and spray in the area.


RECOMMENDATION #21

The current license requirements for quarterly stack sampling should be updated based on the results of the recommended updated dispersion model assessment. As a minimum, quarterly stack testing for PM2.5, NO2 and CO is recommend during the first year of operation.

This means that Golder believes CanTimber needs to have its license requirements updated *after* more modelling based on an updated dispersion model.  This would depend on all of the previous monitoring related recommendations being followed through on first.

Golder recommends that this all be done *before* CanTimber is allowed to resume operations.


Conclusion

I don’t know if all of these recommendations amount to a show stopper for CanTimber but one thing is for sure, I cannot support CanTimber restarting its operations until they have at least complied with the 11 recommendations from Golder.  And preferably they should have to comply with all  of them.

Realistically, they may not be able to comply with these recommendations and deal with the implications and still be sited on the Harbour Waterfront.

I do not believe at this time that this facility should be operating on the City of Port Alberni waterfront.