This article first appeared in the Halifax Examiner on March 5, 2019.
There is much to wade through in the documents that Northern Pulp submitted to Nova Scotia Environment on February 7, 2019, when it registered its “Replacement Effluent Treatment Facility” for a 50-day, Class 1 environmental assessment (EA).
Citizens who wanted to comment to the government on the proposal, as was their right, needed to slog through 1,586 pages in 17 registration documents, and they needed to do it quickly. The public was given only one month to comment. Environment Minister Margaret Miller had until March 29 to decide on the project. [Minister Miller’s decision is detailed here.]
Not surprisingly, the EA submission starts on a very encouraging note. In the Executive Summary, Dillon Consulting, which developed the project documents on behalf of Northern Pulp, provides a table indicating the “significance of project-related residual environmental effects” on 18 items, everything from the atmosphere to marine fish and fish habitat at every stage of the project, during construction, operation and maintenance, or because of accidents or malfunctions.
Every single one of them is assessed as NS, or “No Significant Residual Environmental Effect Predicted.”
Every. Single. One.
This could mean either of two things.
One, there is nothing to worry about. Citizens of this province, and all those who fish in or depend on the Northumberland Strait for their livelihoods or just care about its health, can suspend their disbelief and have faith that Northern Pulp’s plans for treating its effluent and disposing of it in the Strait are foolproof.
For this scenario to work, we have to trust that Northern Pulp and its consultants, working with the $6.1 million that taxpayers chipped in for the studies for the project, have ensured that it’s all good, there really will be “no significant” environmental effect of anything.
In other words, the on-site Activated Sludge Treatment system will effectively treat millions of litres of toxic pulp effluent a day, every day, without a hitch. The 36-inch diameter pipeline that will run 11.4 km across the causeway and then overland beside Highway 106 to Caribou Harbour will never leak or spill its contents in the Pictou watershed, or negatively affect the scenic landing point for the PEI ferry that brings tens of thousands of visitors to Nova Scotia each year. The 4.1-kilometre pipe into the Northumberland Strait that will dump millions of litres of effluent a day into the rich fishing grounds will not harm fish habitat or the ecosystem. The “dewatering process” of the sludge from the treatment facility will work well, and there is no need to worry about burning it in the mill’s power boiler, even though that boiler has already caused many emissions problems.
There is, of course, an alternate interpretation, that there are many significant risks, which Northern Pulp is downplaying or ignoring altogether in the documents submitted to the province, and also to the Canadian Environmental Assessment Agency (CEAA), which has been asked by many groups to undertake a federal environmental assessment of the project, despite apparent reluctance by Prime Minister Justin Trudeau to get involved.
My doubts over the validity and accuracy of the project documents increased dramatically as I slogged through nearly 1900 pages of emails and reports that environmental lawyer Jamie Simpson received through a freedom of information (FOIPOP) request from the Department of Transportation and Infrastructure Renewal (TIR) and Nova Scotia Environment (NSE).[i] TIR paid for the studies for the project, and its executive director of corporate initiatives, Gary Porter, was part of the “team” that discussed its development over the past two years.
The FOIPOP materials, coupled with the views of independent pulp experts, show that the project documents are full of contradictions and gaps large enough to drive a large effluent pipe — or several of them — through.
Missing answers, missing mercury
I’ll start with the missing mercury, and the short shrift given to highly toxic dioxins and furans, which Health Canada says can cause liver problems and some cancers, impair reproductive functions, and immune and endocrine systems.
Internal emails that Simpson received through his FOIPOP request show that Dillon consultants raised the issue of heavy metals, such as mercury, and of dioxins and furans in the effluent. In January 2018, Dillon sent a list of questions to Northern Pulp, KSH Consulting, and TIR, saying it needed information on the “percentage of dioxins and furans in the final effluent going into the straight [sic] daily.”
In February 2018, Dillon again wrote to Northern Pulp reminding the technical manager of the need to acknowledge these substances, noting that:
… questions have arisen regarding the content of metals in the discharge. Based on available data …[redacted] will review potential metals or other effluent components levels in the context of potential marine environmental risk …
We believed [sic] that an understanding of effluent characteristics regarding metals, dioxins and furans will be necessary.
If such an “understanding” was provided by any of the studies done for the new effluent facility, it does not show up in the EA documents submitted to Nova Scotia Environment.
EA document Section 1-7 states that:
Dioxins and furans in NPNS’s [Northern Pulp Nova Scotia] effluent have virtually been eliminated since the conversion to chlorine dioxide bleaching in 1998. NPNS has never exceeded the limits as per the Pulp and Paper Mill Effluent Chlorinated Dioxins and Furans Regulations.
That doesn’t mean that these toxins are not present in the effluent, however. When the mill’s effluent pipeline broke in 2014, spewing 47 million litres of untreated effluent over sacred Mi’kmaq burial grounds on Indian Cross Point and into the East River, dioxins and furans were found near the spill. One dioxin (OCDD) was detected several kilometres down the Northumberland coast at Melmerby Beach.
Although Northern Pulp does annual tests for dioxins and furans, those results were withheld from the FOIPOP results that provided to Jamie Simpson.
Northern Pulp Nova Scotia’s EA document Section 1–7 notes that for more than two decades, the Canso Chemicals chlor-alkali plant next to the pulp mill used mercury to produce chlorine for the pulping process. In 1992, Canso Chemicals closed when when the pulp mill switched from elemental chlorine to chlorine dioxide to bleach the pulp. This was so the mill could “meet new federal PPER [Pulp and Paper Effluent Regulations] for dioxins and furans.”
This cursory reference to the defunct Canso Chemicals plant on Abercrombie Point fails to mention the mercury contamination on the site, or the mercury that seems to persist in the mill’s effluent. When Northern Pulp’s effluent pipeline broke in 2014, the Mi’kmaq Conservation Group commissioned a study that showed that the concentrations of mercury in untreated effluent at three sample sites were above safe standards.
According to Dr. John Krawczyk, a child and adolescent psychiatrist in Pictou County who specializes in studying and treating the effects of environmental toxins on the developing brain, there is every reason for the public and the government to be concerned about the presence of mercury in the mill effluent. He is also worried about the mill’s emissions should dewatered sludge from a new treatment facility be burned in the mill’s power boiler.
Krawczyk recently penned an open letter detailing his concerns about mercury and carcinogenic Particulate Matter 2.5 from the mill. In an interview with the Halifax Examiner, he noted that in 2014, the Clean the Mill Group, of which he was a member, engaged a consultant who found mercury in three sample sites in groundwater surrounding Pictou Landing. They sent the results to the provincial government, Krawczyk says, but nothing was done:
It’s now 2019, five years since we said “you can’t waste a day when you’re dealing with mercury.” When mercury becomes methylated mercury in the ground it is one of the most toxic heavy metals around . . .This is a pressing issue in our backyard and why wasn’t this addressed five years ago?”
In his letter, signed by four other medical doctors in Pictou County, Krawczyk calls for an end to “fifty years of environmental racism.”
What’s buried at Abercrombie Point?
Krawczyk also points to media reports from the 1970s about tons of mercury that were lost or unaccounted for at the Canso Chemicals plant. A 1977 Montreal Gazette story says that there were several tons of “unaccountable mercury losses” during the 1970s, which peaked in 1975 at five tons.
It would be years before the mystery of the missing mercury would be solved.
A 2000 report on the decommissioning of the Canso Chemicals site by Dillon Consulting (the same company that put together the EA documents for Northern Pulp’s replacement treatment facility) states that in “1973 – 1975, a series of equipment failures in the [Canso Chemicals] cell room resulted in high mercury consumption and mercury was lost to the floor.”
From 1992 after the plant closed through 1996, efforts were made to “recover free mercury from contaminated soil,” which, along with “mercury contaminated materials generated during the demolition” of the plant, was disposed of in the “on-site secure landfill.”
In 1999, elemental mercury was also found to have seeped into the bedrock underneath the former cell room and brine basement, but it could not be excavated and placed in the landfill because of its depth — eight metres — and because of the risk of disturbing and spreading the contamination. The mercury is about five metres below the water table, so according to the decommissioning report, “there is potential for it to dissolve into groundwater and migrate towards Pictou Harbour.”
The report recommended that the province set up a long-term monitoring program, and said it could take up to two centuries for the mercury plume to make its way into Pictou Harbour.
According to Rachel Boomer, spokesperson for Nova Scotia Environment, the mercury monitoring on the site has been ongoing for “at least 20 years.” In an email to the Halifax Examiner, Boomer confirmed that:
Nova Scotia Environment requires ongoing annual mercury monitoring on the former Canso Chemical site, which is next to the site of the proposed Northern Pulp effluent treatment plant.” [emphasis mine]
That sent me back to the EA registration documents from Northern Pulp, to see where, exactly, it intends to put its activated sludge treatment facility on Abercrombie Point. I then compared that to the map showing the location of the former Canso Chemicals plant, which sits atop mercury-contaminated bedrock and very close to the secure landfill where mercury-laden soil and materials were deposited in the 1990s.
The secure landfill and former Canso Chemical plant site where mercury monitoring takes place are indeed “next to the site” of the proposed treatment plant. Perhaps Northern Pulp intends to build its new treatment facility above ground, with no digging whatsoever into rock that might be contaminated with mercury, or soil into which mercury might have seeped from the “secure landfill.”
But a diagram of the proposed treatment facility, on page 77 of the EA document Section 1-7, shows clarifiers and the activated sludge basins with depths of seven metres and greater very close to the former Canso Chemicals site.
This is what EA document Section 8 has to say about the Canso Chemicals site and potential contaminants:
The former Canso Chemicals plant is located on the adjacent property south of the NPNS facility industrial site. . . Similar to the pipeline, there is limited potential for encountering contaminants; however, NPNS’ contingency plan for encountering contaminated materials during construction will apply to the construction of the ETF [Effluent Treatment Facility] as well.
There is no mention of the mercury at the site. Even if construction and operation of the new treatment facility pose no risk of disturbing — or being affected by — the landfill containing mercury and the contaminated bedrock, it is unfathomable to me that this isn’t discussed in detail in the EA documents.
What’s going to be coming out of that pipe, anyway?
Then there’s the big question of what’s going to be in the treated effluent. Email correspondence involving Northern Pulp, Dillon, and TIR show that there was a team effort to shape and stick to the talking points that would go to the media, public, and local councils to try to assuage fears about the plan to pipe treated effluent directly into the Northumberland Strait.
The Communications Director for Paper Excellence / Northern Pulp repeated that message in a letter of November 30, 2017 to the town of Westville:
Northern Pulp has been releasing treated effluent into the Northumberland Strait for five decades … Treated effluent that will be discharged under the proposed new design will see an even greater improvement.
So convincing were the message masters that they even managed to get then-Environment Minister Iain Rankin singing their tune. In a form letter sent out to citizens in January 2018, he wrote:
…I am sure you are aware that effluent from the pulp mill has been treated by the Boat Harbour effluent treatment facility and then discharged into the Northumberland Strait for the past 50 years…
In a recorded interview that CBC Information Morning aired during a live broadcast from Pictou on February 21, 2019, Northern Pulp general manager Bruce Chapman repeated the message, and went even further, declaring:
Effluent will be a better quality than it is now…we will produce an effluent that is amongst the best in North America.
Chapman’s on-air boast about effluent from the new system being better than it is now contradicts the views Northern Pulp’s technical manager expressed in private communication. In an email of November 29, 2017 to Dillon consultants, she writes:
Some say effluent quality [from the replacement treatment facility] will be worse than today because of all the polishing that is happening across the Boat Harbour basin — and they are correct to some extent…
It also seems odd that the mill’s general manager would brag about producing some of the “best” effluent when Northern Pulp is not saying what will be in the treated effluent. There is this, from EA document Section 9 – 15:
At this time, it is only possible to identify candidate COPCs [contaminants of potential concern] that may be evaluated should a HHRA [Human Health Risk Assessment] of the project be a regulatory requirement. This is due to the fact that chemical process engineering design work is continuing and there is presently uncertainty regarding the likely chemical composition and characterization of the marine treated effluent discharge (including the potential concentrations of substances present in the effluent.
And this, from page 489:
At this time, effluent chemistry characteristics (including the specific substances present in treated effluent and their anticipated concentrations) will not be known with certainty until the project is operational. [emphasis added]
Unless I’ve suddenly lost my capacity to understand English, I can only conclude that the mill is admitting it doesn’t know (or doesn’t want to tell us) what will come out of the pipeline. It seems we are supposed to hope for the best and just wait until after the pipe has been laid (which Appendix F-H of the project documents tells us will be under two metres of soil and require a trench three metres deep and nine metres across being carved out of the Strait floor), and until after 85 million litres a day of treated effluent (37 degrees C in summer and 25 in winter, according to Appendix E) start gushing into the rich fishing grounds off Caribou Harbour, to find out if the effluent might contain harmful concentrations of harmful substances.
Nor does this convoluted statement from the project’s Executive Summary inspire confidence:
It is not predicted that the installation of the pipeline will result in long term harm to fish or fish habitat. [emphasis added]
Just like that mill that was never built in Tasmania
A Class 1 provincial environmental assessment in Nova Scotia, which is what the province decided this project qualified for (a controversial decision that Linda Pannozzo wrote about for the Halifax Examiner), does not require a Human Health Risk Assessment (HHRA).
However, Northern Pulp recognized that at some point Health Canada might require an HHRA, so it submitted a “human health evaluation” (Section-9-15) to the province as part of the environmental assessment.
The consultants looked for a project that was “similar to the NPNS project,” which had undergone a human health risk assessment, so they could compare the “potential human exposures and risks associated with a marine treated effluent discharge” from a kraft pulp mill.
For this, Northern Pulp chose a study done by Toxikos consultants in 2006 for a highly controversial pulp mill proposed for Bell Bay, Tasmania. It would be impossible to check the veracity of the study because the mill was never built; there was powerful community opposition to it, and the giant timber company behind the mill, Gunns, couldn’t get its bank to finance it.
Results of Simpson’s freedom of information request show that this study of a mill-that-never-existed was recommended by someone from KSH Consulting (whose name was redacted) in an email on February 28, 2018 to TIR’s Gary Porter (and to four others whose names were redacted). This person said that the Toxikos assessment was carried out “in an outfall configuration similar to that encountered at Northern Pulp.”
Except that it wasn’t.
Northern Pulp’s proposed outfall is the Northumberland Strait, which is prized for both fishing and recreation. Not so Bass Strait, the proposed effluent outfall for the Bell Bay pulp mill-that-never-was.
According to the Toxikos study, which KSH sent to Porter in its entirety, in the Bass Strait, “recreational activities in the vicinity of the proposed outfall site were not observed during any of the survey work done to-date.” And on page 86, it states:
The available information indicates that commercial and recreational fishing does not occur in the vicinity of the proposed ocean outfall. In addition, there is a paucity of fish in the area.
In contrast, the proposed Northern Pulp pipe outfall location in Caribou Harbour is a critically important fishing and spawning ground for lobster, rock crab, herring, ground fish, and many other species.
Greg Egilsson, Chair of the Gulf NS Herring Federation and who fishes very close to the proposed pipe outlet, estimates that within a radius of just a few kilometres, there are 86 lobster fishermen, of whom 10 to 15 are First Nation, and more than 22,500 traps are set in the area. He tells the Halifax Examiner that the deep channel where they want to place the pipeline is crucial for lobster and herring larvae, and that herring spawning stock are already depleted. “It’s the worst possible place you could put it,” he says.
What happened to the lobster studies?
An email from Dillon Consulting to Northern Pulp’s technical manager on February 14, 2018 highlights public concern about the project’s potential impact on the lobster fishery:
Conducting research on lobster larvae, and potential alternatives to pipe discharge into the Strait needs to be completed to demonstrate to regulators that these were properly considered and stakeholder concerns are being addressed as much as reasonably possible.
A lobster larvae study has been called for by commercial fishers and concerned environmental community groups. As a first step, Dillon completed a literature review and contacted researchers who may have current studies underway to understand what information is available.
The level of stakeholder (commercial fishers) concern regarding lobsters necessitates the need [sic] for increased scientific understanding. A lobster study is not intended to be included in the environmental assessment. We will assess the value of a lobster study once the specialist has been contracted.
Questioned in February 2018 by the PEI Legislature’s Standing Committee on Agriculture and Fisheries if tests were ongoing to determine how the pulp effluent would affect lobster larvae and herring eggs, Northern Pulp technical manager Terri Fraser replied:
No there is not. Currently we’re looking at getting experts that can do those things and understanding the right time of year that that happens; we’re looking at that now. . . Right now we’re in the study phase talking to experts and understanding what’s been done in research so far.
Fraser added that they were working with Dillon Consulting, which was “reaching out to experts in the field.”
Email correspondence from that time shows that Dillon was indeed reaching out to researchers for studies of the potential effects of the effluent on lobsters and other fish in the Strait. But if such studies were undertaken, there is no evidence of them in the documents Northern Pulp submitted to the province, at least none that either Jamie Simpson or I could find.
Another question is: What happened to the oxygen delignification system that was originally proposed for the mill? An email from Northern Pulp’s technical manager on November 30, 2017 to TIR’s Gary Porter and 11 others whose names are redacted, contains a series of slides attributed to Northern Pulp 2012. One states:
Two-stage Oxygen Delignification technology will be incorporated into the pulp making process at Northern Pulp. . . The lignin removed in this new state will result in the use of less bleaching chemicals to whiten the pulp in the existing bleach plant. It is a significant and well-proven process for the ECF [Elemental Chlorine Free] pulp and as such it is often referred to as the first stage of bleaching (oxygen bleaching).
Another Northern Pulp slide lists environmental benefits:
– Reduces Chlorine Dioxide bleaching chemicals by 30 – 40% – corresponding reduction in effluent organic loading for BOD [biochemical oxygen demand], COD [chemical oxygen demand] and AOX [adsorbable organic halides]
– Reduces effluent colour
– Reduces wood losses
– Increases recovery of lignin to the liquor cycle — reduction in carbon footprint
– Reduces energy consumption by reducing aeration requirements in the new EFT [Effluent Treatment Facility] – reduction in carbon footprint
– Reduces nutrient addition in the new ETF
As recently as December 18, 2018, Paper Excellence Director of Communications, Kathy Cloutier, told The Chronicle Herald that the mill would be getting oxygen delignification, and it would add $70 million to the cost of the new effluent treatment facility, although she didn’t know if the provincial government would be covering some of that cost.
Since then, the plan for the oxygen delignification system seems to have disappeared. It is not included in the mill’s replacement treatment facility plan submitted to the province.
A pulp industry expert who requests anonymity tells the Halifax Examiner that most pulp mills put in oxygen delignification systems back in the 1980s or early 1990s, and that they pay for themselves in reduced chemical use. Northern Pulp, he said, is the only one he knows without such a system.
But even that is not the real issue at Northern Pulp mill, he says. Rather, the problem is its “ancient systems” that put “shit” into any effluent system that will be built. Genuine improvements in the mill’s environmental footprint, he says, would involve changing the mill’s processing system, and “tightening up loops” well upstream from the effluent treatment process.
In his view, the Northern Pulp project documents are riddled with “data manipulation,” prepared “purposely to make the stuff hard to understand.” And if I want to know how bad the effluent will be, he says, “just look at Boat Harbour.”
So I did.
Effluent will be worse than today
It’s a frigid, sunny day when I go to Point D, as Northern Pulp calls the outlet where its effluent leaves Boat Harbour and enters the Northumberland Strait. At this point, it has already spent time in settling ponds, an aeration basin and in 350-acre Boat Harbour, where it stabilizes before being released into the Strait.
Even here at the end of the whole treatment process, the wastewater is a dark brown, and the stench, as I approach the dam through which it froths and bubbles as it flows slowly into the Strait, is so noxious that it catches in my throat, induces a headache. Much like the airborne emissions of the mill did as I drove through Trenton and Pictou Landing on my way to Boat Harbour.
The mill does not consider the Point D outlet into the Northumberland Strait the “receiving waters” for the effluent. Rather, as folk musician, songwriter and member of the Clean the Mill group Dave Gunning points out in his letter to the Nova Scotia government in response to Northern Pulp’s effluent project, this is not what the mill considers the “receiving waters” for the effluent. Rather, Gunning points out, the receiving waters are at Point C, where the effluent flows out of the aeration basin and into Boat Harbour:
Point C is the federally regulated point. The new ETF would release the treated effluent directly into the Northumberland Strait without the added bonus of the 20-30 day retention time for additional cooling, dilution and settling in the large Boat Harbour Basin. The elimination of the Boat Harbour Basin is a huge factor because EEM [environmental effects monitoring] data shows that the Basin has a large effect on effluent quality that is currently reaching the saltwater.
… it is very clear that the elimination of the Basin would have a substantial and negative impact on the effluent quality reaching the Strait. Based on this data there is enough information to conclude that the new ETF would be worse than the old facility because of the elimination of the Boat Harbour Basin. So Northern Pulp is proposing a newer system but a worse location for the receiving water. The elimination of the Boat Harbour Basin would result in more of the toxins reaching the Northumberland Strait.
Surprisingly, despite the mill’s talking point that the effluent has been going into the Strait for 50 years and the new treatment system will be an improvement, Northern Pulp’s technical manager seems to agree with Gunning. In November 2016, she sent TIR a KSH Consulting report done for Northern Pulp, which confirms his view:
The effluent treatment system consists of constructed sedimentation basins followed by aeration in a natural basin with baffle curtains directing flow. A large, natural final polishing / stabilization basin follows prior to release to the Northumberland Straight [sic] . . . Point C of the effluent treatment system also benefits from the settling effect of Boat Harbour prior to Point D, so the impact on marine environments is even less pronounced.
Point D is just a few hundred metres down the road from Pictou Landing First Nation, which has had to live with the reeking pulp waste in their backyard since 1967. Chief Andrea Paul has repeatedly said that there can be no change to the Boat Harbour Act, and that Northern Pulp has to stop using Boat Harbour — or “A’se’K” — by January 31, 2020. The First Nation is counting down the days till its closure.
Northern Pulp has said that even if it gets provincial approval for its replacement effluent treatment facility, it will need an extension on the Boat Harbour Act, so it can continue to send its effluent there for an additional year or so, until it has the new system up and running.
But first, the question is whether Nova Scotia Environment will approve Northern Pulp’s EA for the new effluent treatment facility, flaws and all.
The clock is ticking.
[i] I would like to acknowledge the incredible work of Jamie Simpson, who not only made this Freedom of Information request to TIR and NSE, but then combed through nearly 1,900 pages of documents and made important notes, which he then shared with journalists.