February 6, 2017
To: Mayor and Council, Williams Lake
We are Rail Ties Be Wise (RTBW) and we are supporting community members in their appeals to both recent permit amendments concerning the burning of rail ties in our town.
The Province has amended two of Atlantic Power’s permits. One process was opened to public input; the other was not.
Permit 8808 allowing AP to burn rail ties.
The permit that was subject to public input, the ‘boiler permit’, authorized the presence of a number of new airshed pollutants as a result of burning railroad ties. The Province found that the increases to air pollution, while significant, would be within air quality guidelines when rail ties are burned as 50% of the feedstock. Therefore the permit was issued.
One major issue that the appeals to 8808 raise is this: the modelling done by Atlantic Power is based on 2001 trial burns when 100% rail ties were burned for one hour per day for three days. Since AP in its application asked to burn up to 50% rail ties, all the models used the raw data from that trial burn and divided the results by two. The modelling therefore was done based on burning rail ties at a maximum 50% at any given time.
However, the new boiler permit allows for the company to burn up to 50% rail ties per year. Thus, it is entirely legal for AP or any company that buys the plant to burn more than 50% on a given day, so long as the amount of rail ties that they burn does not exceed 50% per year.
This is a significant change from what we have been told during the amendment process. AP has stated they only want to burn 0.8 – 1.2 million ties / year but they have been authorized to burn upwards of 4 million ties / year.
Of course, we are concerned about the increased varieties and levels of pollutants in the airshed. A summary of these concerns is also attached to this letter, as they have been previously published on our website: railtiesbewise.ca
Permit 8809 governing the disposal of boiler ash
The other permit regulates the landfill where AP dumps the waste ash from the boiler. This permit has been amended several times with no opportunity for public involvement.
In the 8809 permit amendment process, AP advised the Province that “the agricultural/residential soil standard” for dioxins was 0.00035 milligrams/kilogram (mg/kg). The 2001 trial burn reported that there was a >30-fold increase in dioxin/furan concentrations in ash from 23.8 picograms/gram (pg/g) to 788 pg/g (clean wood vs treated wood ash) when 100% rail ties were burned. A 50% treated wood fuel supply is estimated to produce ash with 394 pg/g, which is equivalent to 0.000394 mg/kg. AP subsequently advised that the industrial land use criterion is more suitable, and the rail tie ash is predicted to be below level.
It is undisputed that the ash pile will have a higher concentration of dioxins and furans. Yet neither the Province nor AP ever considered the safety of the ‘fly ash’ — that is the ash that is blown from the ash landfill onto neighbouring vegetation, waterways, residences, businesses and people who frequent the area.
A number of people who live and work near the ash landfill have approached our group. Some residents on 11th Avenue and 12th Avenue report seeing ash land on their cars and lawns in the mornings. Some workers at the mill near the ash landfill tell us that their cars are often covered by ash when they leave work. Residents tell our group that they are concerned that at least some of this fly ash is probably from the ash landfill.
On this basis, we are concerned that the ash landfill will carry elevated concentrations of dioxin/furans such that fly ash may adversely affect nearby residents. No scientific study has been done to determine the safety of this fly ash.
As well, what will happen to the property values of the houses nearby, if the fly ash is found to have adverse effects on people or property? These concerns are not addressed.
The Province has applied to dismiss all parts of our appeals that refer to the ash landfill.
The Province’s permit allows for burning up to 50% rail ties a year, and this will make Williams Lake the main site in Western Canada for burning ties. Waste rail ties from Saskatchewan, where they are not allowed be burned even in their coal plants, will be shipped here. The Province’s permit did not have to consider if, for instance, Williams Lake has the capacity to respond to an operational failure causing excess pollution to be discharged (as happened at the Swan Hills Alberta hazardous waste incineration plant). The Province’s permit also did not consider if the City of Williams Lake is equipped to respond if the ash landfill, with its elevated concentrations of dioxins and furans, were to slide into the River Valley.
To this end, in the appeals that our group is putting forward, we are asking that AP set aside an emergency fund in the case of an environmental disaster. This fund will ensure that if there were an environmental emergency in which clean-up costs exceeded insurance coverage, then there would be funds available to help the town recuperate. (note: Swan Hills clean up costs are currently projected at $71 million)
Finally, we have some questions for City Government:
- The Province’s permit does not include a risk assessment. Meaning, they did not consider the potential for an environmental disaster and the capacity of the Province or the City to handle any such disaster. This group has been advised by environmental lawyers that such risk assessment is usually done in coordination between the company and local governments, to ensure there is a safety or emergency plan in place. Because this industry is located within City limits, has the City reached out to develop such a plan with AP?
- In the case of an environmental disaster, could the City be held responsible for the cost of a clean up?
- The City of Williams Lake Official Community Plan prohibits development within 100m of an escarpment without the approval of an engineer. The area north of the ash existing landfill is a steep escarpment above the Williams Lake River. Has an engineer for the City ever approved the landfill location? Since the ash landfill, under the amended permit 8808, will significantly change in composition once rail ties are burned, will a City engineer review the location of this landfill to ensure that it is stable and safe to remain there? If a landslide were to happen on that escarpment, who would be responsible for clean up? Could the City be liable for not getting an engineer to approve the location of the landfill or to review if its current location is safe?
- Given that Williams Lake experiences frequent weather inversions which trap pollutants like those that will be emitted from burning railroad ties, will the City require that AP commit to refraining from burning treated wood during those incidents?
- Given that there are no background data on the ambient levels of some pollutants (e.g. SO2) in our airshed, will the City require that AP establish a more comprehensive air quality monitoring and reporting program to accurately measure the impact of burning railroad ties?
This group loves Williams Lake. Some of us live within City limits and others live outside the town’s boundaries, but we all call Williams Lake home. The Province issued the permits that would make Williams Lake the rail-tie burning capital of western Canada, without considering some important implications (like the fly ash and risk assessments). This designation brings liability that we fear is too big for this town to handle. We are concerned that burning rail ties will damage our reputation as a healthy place to live, and make it harder to attract new families, professionals and retirees. We want to make sure this beautiful town is able to remain as vibrant and flourishing as it is now.
Please let us know if you have any questions about any of these issues.
Thank you for your attention to this crucial issue.
Rail Ties Be Wise
For background on our concerns about emissions from the ash boiler permit 8808, we are attaching the following document, previously published on our website www.railtiesbewise.ca:
Backgrounder: How to Make our Inversions Even Worse
For background re the ash disposal permit 8809, we are attaching the following documents.
- Permit Amendment 8809 dated September 16, 2016
- Ash Landfill Closure Plan dated September 22, 2011. Relevant sections are:
- Golder geotechnical report at p 55 of the Closure Plan
- Original permit dated February 22, 1991 at p 35 of the Closure Plan
- Permit amendment dated October 21, 2010 at p 33