Disposing of Rail Road Ties

Williams Lake, BC,  Friday January 6, 2017:

Rail Ties Be Wise (RTBW) responded today to the Province of BC’s attempts to strike appeals brought against permits allowing Atlantic Power to burn creosote-treated rail ties as up to 50% of its feedstock in their Williams Lake biomass facility.

 

Williams Lake residents have every reason to be concerned. Burning creosote-soaked rail ties emits chemicals that pose a risk to human health and the environment. The ash residue will also contain toxic chemicals, as the Ministry of Environment has acknowledged. It nevertheless issued permits without addressing how that ash will be disposed of. There are concerns about the slope stability beneath the current ash landfill; the potential for failure of that ground puts the Fraser River watershed at risk, endangering water quality, salmon and other aquatic life.

 

The appellants argued that the Province should not have issued the permits without considering all of their implications, and that the appeals should be heard by the Environmental Appeal Board (EAB) in a hearing — not dismissed at this early stage.

 

The Province specifically argued that parts of the appeals dealing with the rail tie ash should be dismissed on the grounds that these requirements were not significantly changed in the amended permits.  It is precisely because these issues were not considered that the appellants want them raised to the EAB. They want proper scientific investigation before the permits are finalized, and neither the Province nor Atlantic Power has done this.

 

RTBW is very concerned that the Province is attempting heavy-handed legal maneuvers to thwart Williams Lake residents’ access to the EAB. In response, RTBW is supporting (at their own expense) the appellants in preparing responses to the EAB just to keep the full scope of the appeals alive.

 

“The actions by the Province are an attempt to out-spend and ultimately outgun residents who don’t want to see Williams Lake become a destination for toxic rail ties,” says RTBW member Patricia Weber. “We love Williams Lake and we want to protect it from a potential environmental disaster.”

 

It is alarming that the Province is trying to frustrate citizens’ lawful access to appeal this decision. Yet we remain adamant that the EAB needs to review the decisions around burning millions of rail ties here, including the decision to allow more-toxic ash to be dumped on the edge of the WL River Valley.

 

Rail Ties Be wise continues to organize and prepare for EAB hearings, expected to be announced in the coming weeks. Concerned citizens and supporters can find out more at www.railtiesbewise.ca. Donations to help with the cost of appeals can be made at www.gofundme.com/2q7qdu4 or the Rail Ties Be Wise account at Williams Lake and District Credit Union.

 

We gratefully acknowledge West Coast Environmental Law for their support through the Environmental Defense Resource Fund.
Williams Lake, BC, Friday January 6, 2017:

Rail Ties Be Wise (RTBW) responded today to the Province of BC’s attempts to strike appeals brought against permits allowing Atlantic Power to burn creosote-treated rail ties as up to 50% of its feedstock in their Williams Lake biomass facility.

Williams Lake residents have every reason to be concerned. Burning creosote-soaked rail ties emits chemicals that pose a risk to human health and the environment. The ash residue will also contain toxic chemicals, as the Ministry of Environment has acknowledged. It nevertheless issued permits without addressing how that ash will be disposed of. There are concerns about the slope stability beneath the current ash landfill; the potential for failure of that ground puts the Fraser River watershed at risk, endangering water quality, salmon and other aquatic life.

The appellants argued that the Province should not have issued the permits without considering all of their implications, and that the appeals should be heard by the Environmental Appeal Board (EAB) in a hearing — not dismissed at this early stage.

The Province specifically argued that parts of the appeals dealing with the rail tie ash should be dismissed on the grounds that these requirements were not significantly changed in the amended permits.  It is precisely because these issues were not considered that the appellants want them raised to the EAB. They want proper scientific investigation before the permits are finalized, and neither the Province nor Atlantic Power has done this.

RTBW is very concerned that the Province is attempting heavy-handed legal maneuvers to thwart Williams Lake residents’ access to the EAB. In response, RTBW is supporting (at their own expense) the appellants in preparing responses to the EAB just to keep the full scope of the appeals alive.

“The actions by the Province are an attempt to out-spend and ultimately outgun residents who don’t want to see Williams Lake become a destination for toxic rail ties,” says RTBW member Patricia Weber. “We love Williams Lake and we want to protect it from a potential environmental disaster.”

It is alarming that the Province is trying to frustrate citizens’ lawful access to appeal this decision. Yet we remain adamant that the EAB needs to review the decisions around burning millions of rail ties here, including the decision to allow more-toxic ash to be dumped on the edge of the WL River Valley.

Rail Ties Be wise continues to organize and prepare for EAB hearings, expected to be announced in the coming weeks. Concerned citizens and supporters can find out more at www.railtiesbewise.ca. Donations to help with the cost of appeals can be made at www.gofundme.com/2q7qdu4 or the Rail Ties Be Wise account at Williams Lake and District Credit Union.

We gratefully acknowledge West Coast Environmental Law for their support through the Environmental Defense Resource Fund.
Numerous harmful chemicals and fine particulates will be released into our airshed if Atlantic Power (AP) burns rail ties in their Williams Lake facility. Those same contaminates would be present in the ash added to the existing landfill on Soda Creek Road. The company and the Ministry of Environment (MoE) assure us that concentrations will be so negligible that we are foolish to be concerned.

They are basing this assertion on modelling from a single test burn in 2001. 100% rail ties were burned in that test, and measured levels of chemicals were then divided by two, help based on the assumption that no more than 50% ties would be burned at any given time. Because these calculations yielded numbers below provincial air quality guidelines, it is assumed that all is well.

Rail Ties Be Wise has two problems with this. First, the permit allows AP to burn no more than 50% rail ties per year. This does not preclude burning more than that on any given day, so are these calculations valid? Second, is it possible that simply dividing the results by 2 does not give an accurate picture? We agree with the Ministry of Environment meteorologist who recommended that stack testing at the actual maximum burning rate should be undertaken as soon as possible to find out. The permit from MoE does not require this to be done.

We also strongly endorse his recommendation that AP should develop a monitoring system to detect background levels of respiratory irritants (sulphur dioxide, polycyclic aromatic hydrocarbons and hydrochloric acid) currently present in our airshed. There are no available figures for these. Would adding the “safe” amounts from AP’s stack create dangerous conditions? This too is not addressed in the permit.

A Health Risks Assessment predicted short-term exceedances of air quality guidelines for two dangerous gases, sulphur dioxide and nitrous dioxide, but dismissed their potential for harm. However, Health Canada’s 2016 review of research and information about the effects of sulphur dioxide does not seem to have been considered in that assessment. That information suggests that intermittent spikes in concentrations at lower levels than AP’s permit allows can be harmful to asthmatics, children, unborn children and the elderly. Health Canada recommends that we need new National Ambient Air Quality Objectives.

We agree with Health Canada that further research is needed. In the absence of such research, it makes no sense to subject the people of the Cariboo-Chilcotin to a long-term health experiment.

For a more detailed consideration of these issues, please look at this document. We are grateful to our dedicated volunteers for the many hours they devoted to researching these issues.

According to the BC Ministry of Environment the concerns will be

  • Sulphur Oxides;
  • Hydrogen Chloride (HCl);
  • Chlorophenols (CP);
  • Dioxons and Furans (PCDD/F);
  • Chlorobenzene (CB);
  • Polycyclic Aromatic Hydrocarbons (PAH);
  • Volatile Organic Compounds(VOC); and
  • Metals.

Added concerns mentioned by the MOE but not focused on:

  • nitrogen oxide
  • fine particulate
  • reduced sulphur —This is what causes the “rotten egg” smell in Quesnel and PG. I could find no evidence that this will be a problem as a result of burning rail ties.

According to the Intrinsik Health Risks Assessment (found in Atlantic Powers Technical Assessment Report appendix 4)

The only exceedances of the limits (health risks) at the points of highest concentration were predicted for short-term inhalation exposure to NO2 and SO2 acting both singly and in combination as part of the respiratory irritants mixture. The predicted short-term NO2 and SO2 concentrations are unlikely to result in adverse health effects on their own or as part of a mixture due to:
· The conservatism incorporated in the predicted short-term ground-level air
concentrations of NO2 and SO2;
· The areal extent of the predicted exceedances;
· The likelihood of an exceedance occurring; and,
· The levels of exposure that have resulted in observed adverse health effects in humans,
as documented in the most recent scientific literature.

Since there is new information out from Health Canada (2016) concerning safe levels of sulfur dioxide which neither MOE or Intrinsik refer to, treatment I decided to look at the how the sulfur dioxide levels would change in Williams Lake as a result of burning rail road ties.

Sulfur Oxides—How Will this Change as a Result of Burning RR Ties

According to page 2 of the Ministry Assessment of the permit for AP to burn rail road ties the following limits and monitoring requirements were established in the permit based on a 2001 trial, modeling and current guidelines: for sulphur dioxide:

110mg/metre cubed daily average and 193 mg/metre cubed rolling 1 hour average. –at the stack

The real time SO2 limit was established based on the modelling estimates at 50% feed stock. To be verified with real time continuous emission monitoring. This is diluted quite quickly so:

The ministry assessment and meteorologist report state maximum concentrations in ambient air of 47% of the BC Air Quality Objectives for sulphur dioxide or 47% of 75 ppb. =35.25 ppb These figures refer to 1 hour max

Atlantic Power’s updated technical assessment report (changes made as a result of stack height being incorrect) at 100% burn of RR ties shows the 1 hour maximum (99 percentile) SO2 concentration to be 187 micrograms per cubic metre (about 70 ppb) right around the plant itself. Similarly, the maximum (99 percentile) SO2 concentration seems to be about 40 micrograms per cubic metre (about 15 ppb) for residential areas in the City of Williams Lake nearest the plant (absolute 1 hour max at way-point nearest Columneetza). There will be other areas in Williams Lake (fewer residences located there, but very difficult to tell from AP’s map) that will have higher concentrations ranging from 25-75 micrograms (9.5-27 ppb)

So if the RWDI Air Modeling Report using the results of the 2001 trial burn of 100% rr ties can be relied on as the primary evidence to assess that Air Quality Objectives are being met, then Sulfur Oxide levels will not be a detriment to general health using BC Air Quality Objectives if only the emissions from the power plant are considered.

Intrinsik Report states:

Respiratory irritant chemical mixtures (primarily NO2 and SO2) were the only aspect with any potential to exceed the short-term and long-term exposure limits.

SO2 levels must be high enough to overwhelm the protective mucous membranes and enable penetration of the lungs and alveolar spaces before the co-exposure to NO2 and SO2 on the respiratory tract becomes additive. The conditions under which this would occur were predicted to be less than 0.05% of the time in the forested area to the northwest of the facility. Intrinsik therefore predicted that exceedances in excess of the threshold level were unlikely to occur and the “assumption of additivity in the assessment of the respiratory irritants mixture, particularly the effects of NO2 and SO2 is likely conservative.”

It is important to consider what Ralph Adams, Meterologist, states on page 64-65 of the Ministry Assessment of Permit Amendments. He comments on the non-inclusion of background Sulfur dioxide measurements and the dependence on all of the modeling on the 2001 100% tie tests. He recommends:

  • That as soon as feasible, stack testing is completed at the maximum firing rate allowed in the amended permit. The initial stack tests would be used to confirm that the emission rates used in the modelling and this assessment are appropriate.
  • That an ambient monitoring programme be developed by the proponent, which will be approved by the director, to confirm that that ambient levels of SO2, PAH and HCl in the airshed are below levels of concern.

I could not find in the permit that these two things were required.
However:

Health Canada (2016) has come out with an extensive review of research and information about the effects of sulphur oxides on human health which relate to Williams Lake which should be considered. http://www.pembina.org/pub/sulphur-dioxide-and-health

Full document: http://publications.gc.ca/collections/collection_2016/sc-hc/H144-29-2016-eng.pdf

From this study:

Remember: Using the figures from the RWDI Modeling Report, we will have at most spikes of 15-25 ppb (70 ppb right at the plant) for 1 hour maximums (99percentile).

Conclusions from the Health Canada Review

  • To detect odour (burnt matches) there needs to be a concentration of 300 ppb or more. So smell will not be an issue
  • The strongest evidence of causality according to this study) was between short term SO2 exposures and respiratory morbidity (illness), based largely on the 5-10 minute controlled human exposure studies. A 10-min human health reference concentration of 67 ppb has been identified in the assessment. Sensitive populations such as asthmatics, children, unborn children, and the elderly are more susceptible to adverse effects when exposed to SO2 at these levels.
  • The more recent literature also adds to the weight of evidence for a “suggestive of
    causal” relationship between non-accidental and cardiopulmonary mortality risks and
    short-term exposures to SO2.
  • Additional endpoints (reproductive/developmental) have been identified based on the more recent literature. Although these endpoints have also been designated as having a weakly “suggestive of causal” relationship with SO2 exposures, the database is limited.
  • Intermittent spikes in exposures are linked to respiratory morbidity and are suspected for most other endpoints, including reproductive/developmental. Current Canadian monitoring data support that Canadians are likely to be exposed to intermittent spikes in concentrations. Mechanistic and personal exposure modeling also support intermittent spikes in exposure as being relevant to the health effects observed.

 

Because of these conclusions, the human health assessment has identified potential health risks to the Canadian population from exposures to ambient concentrations of SO2 which are below the current National Ambient Air Quality Objectives. It is therefore recommended that the current National Ambient Air Quality Objectives be revised or new Ambient Air Quality Objectives or Standards be introduced

Note the 10 minute human health reference concentration of 67 ppb above

 

Relating these conclusions to the sulfur dioxide levels expected in Williams Lake is not easy because most of the data in the AP technical assessment and the MOE assessment of the permit amendment is given in 1 hour max. and Health Canada information is based on short term-10 minute exposures. On p. 21 of the Intrinsik Health Risks assessment there is a reference to a 10 minute (100 % rail tie scenario) sulfur dioxide concentration of 699 micrograms (267 ppb) at the stack. The RWDI predicted this to be only 186 micrograms (71ppb) at ground level for 50% rail road tie scenario. This puts the ground level concentrations above what was found significant in the Health Canada study (67 ppb) Note BC Air Quality Objectives are 1 hour-75 ppb and there are no 10 minute objectives listed.

But if more than 50% are burned in a day as the permit seems to allow, then there could be even higher 10 minute level concentrations.

 

 

What about long term exposure?

  • 104 of the Health Canada study states:

The limited number of epidemiological studies, the equivocal nature of results related to chronic exposures, and the lack of animal toxicity studies for long-term SO2 exposures render the weight of evidence inadequate to infer a causal relationship between respiratory morbidity and long-term exposure to SO2 at ambient concentrations.

 

There may be a causal relationship between long-term, low-level exposure to sulphur dioxide and prenatal development issues (congenital heart defects and preterm delivery). This warrants further research

And:

A major consideration in evaluating SO2-related health effects in long-term epidemiologic
studies is the high correlation among the pollutant levels observed, particularly between longterm averages for SO2 and PM. The lack of evidence available to the evaluation of (potential) confounding by co-pollutants restricted the ability of the US EPA (2008) to make a causal determination based on these studies; it concluded that the available evidence from the epidemiologic and animal toxicological studies was inadequate to infer that respiratory effects occur from long-term exposure to SO2 at ambient concentrations.

 

So to consider:

Is there a relationship of Particulate Matter and sulphur dioxide that we should worry about.?

From RodgerHamilton :

Note that numerous sources indicate there are no safe levels of PM2.5 due to its very small size and ability to penetrate deep into our lungs.

The lowest observable effects are identified as 15ug/m3;

Paraphrasing Rodger: The RWDI modeling study does not give a clear picture of the changes to total particulate matter that will result from burning rr ties. It also does not address Secondary Particulate Matter(SPM) which is a significant contributor to ambient PM 2.5 concentrations in town. SPM is formed when gaseous compounds such as sulfur oxides form secondary compounds like sulphates after exiting the stack.

 

So if there is an increase in sulfur dioxide, is it reasonable to expect an increase in PM 2.5?

According to the air management plan–2005

The continuous PM2.5 record is too short to report on any patterns in trends – continuous monitoring began in 2001. However, PM2.5 levels in Williams Lake have ranked in the top ten since that time, when compared to all other monitoring sites within the province. Concentrations of PM2.5 exceed the federal health reference level up to 11% of the time, depending on location, but are in compliance with the Canada-Wide Standard.

The air pollution potential in the Williams Lake area is high due to topography and local weather conditions. This leads to periods when air quality is poor and 24-hour fine particulate levels can be elevated

What PM2.5 as a result of increased sulphur oxides can be expected

Ralph Adams requested that AP be required to:

participate in an ambient monitoring programme with other stakeholders in the airshed to investigate the spatial variability of PM2.5 and NO2.

My Conclusions:

The MOE and the Intrinsik Health Risks Assessment of changes to the levels of Sulfur Dioxide as a result of burning rail road ties have not considered the latest research related to the confirmed effects of short term exposure to sulfur dioxide on human health.

The documents supplied to the public to assess the changes in air quality related to sulfur dioxide make it very difficult (estimated 25 hours to research this) for a concerned citizen to come to a conclusion. There is “inadequate evidence to infer (or dismiss) a causal relationship” between long term exposures of SO2 and other health effects.   Health Canada suggests that further research is needed.

Do we want to be part of a long term study on the effects of long term exposure to Sulfur Dioxide?