The time is now for you to provide feedback on the Northern Pulp Effluent Proposal. You can do so by emailing email@example.com. Below I am offering a potential framework to help you organize your feedback.
1. For your health
The composition of the toxic effluent will contain dioxins, furans, metals, solids and other contaminates at a rate of 90,000,000 Litres per day. Dioxins and furans can cause very serious health issues to humans and our food sources. Shellfish absorb dioxins and furans at 25,000-50,000 times the concentration in the water.
The Northern Pulp treatment system proposal includes a plan to burn the waste sludge. The waste sludge contains toxins which would be released through the stacks of the mill’s power boiler. The proposal is to “dewater the sludge prior to mixing it with bark and other wood waste for combustion in the mill’s power boiler.”
This is the same power boiler that is currently and repeatedly failing stack emissions tests. Problems with air quality from mill emissions have been documented for years. Lack of appropriate monitoring and enforcement already puts area residents at risk. Now, Northern Pulp is considering adding sludge containing toxins to the combustion mix, increasing health risks from NP’s air emissions.
It is also important to note, the route of this effluent pipe goes through the source water supply for the town of Pictou and community of Caribou and surrounding area.
2. For the economy
The proposed treatment system runs the risk of harming three lifelong Industries worth close to $4 billion to the Nova Scotia economy. The tourism industry is worth $2.7 billion and prides itself on warm, clean water and world class sandy beaches. The commercial fisheries is worth over $1 billion and relies on sustainable wild shellfish that is shipped all across the world. The sport fishing industry is worth $56 million, and the Northumberland Strait is home to the last remaining stable Atlantic Salmon stocks on mainland Nova Scotia.
3. For the environment – Meeting regulations does not prevent harm
Nova Scotia and the Northumberland Strait are put at risk by the proposed effluent treatment process. As it stands right now, there are no CCME guidelines established for marine environments in terms of some of the chemicals and compounds that make up the pulp mill effluent.
Pulp and Paper Effluent Regulations (PPER) in Canada cover two matters; total suspended solids (TSS) and biochemical oxygen demand (BOD.) Even though total discharges of TSS and BOD in pulp and paper effluent decreased by approximately 90% and 97% respectively from 1970-2008, pulp mill effluents continue to have harmful impacts on fish, fish habitat and the environment.
Information gathered through environmental effects monitoring (EEM) at all Canadian mills points to the disturbing conclusion that although mills are meeting regulations and passing the PPER toxicity test, 70% are having harmful effects on aquatic life and habitat, and 55% are having harmful effects on the larger environment.
This information led the federal department of Environment and Climate Change to undertake a modernization review of pulp and paper effluent regulations in 2017. “Results from EEM studies and the changing realities of the pulp and paper industry indicate a need to modernize the PPER to improve environmental protection,” the department states.
If meeting regulations is not enough to prevent harm, neither is passing toxicity tests. Only one toxicity test is required under Canadian pulp and paper regulations. The required LC-50 test is for acute lethality. For this test, an effluent is considered acutely lethal if the treated effluent at 100% concentration kills more than 50% of the Rainbow Trout exposed to it during a 96-hour period. Long-term effects, including impacts on reproduction or growth, cumulative impacts on fish habitat and the larger environment or accumulation of substances harmful for human consumption are not regulated under the PPER. Testing for environmental effects is required for information purposes.
Only two mills in Canada test for and report impacts of effluent on the usability of fish resources by humans. Effluent from pulp and paper mills is regulated at the federal level principally by the Pulp and Paper Effluent Regulations (PPER), which form part of the Fisheries Act. The standards that apply to pulp effluent today were adopted in 1992 and have remained unchanged for 25 years. Highly toxic dioxins and furans are regulated under a separate Act.
70% of pulp & paper mills are having harmful effects on aquatic life and habitat despite meeting current regulations. Long term impacts on reproduction and growth are not regulated under PPER. Federal regulations cover only a few of the recognized harmful substances in pulp mill effluent. For example, there are no federal regulations for AOX compounds, a component of pulp effluent in mills that bleach with chlorine or a chlorine compound. AOX compounds are recognized as extremely toxic. They are not easily broken down by bacteria and thus bioaccumulate in the environment. Yet they are not included in PPER regulations. Neither are phenols, toluene, chloroform or chemical oxygen demand (COD).
For 25 yrs the regulations that apply to pulp effluent have remained unchanged. Provinces may go beyond Federal standards and adopt stricter regulations for effluent from pulp mills. British Columbia, Alberta, Ontario and Quebec have adopted stricter regulations. Nova Scotia does not have regulations, but sets limits through individual industrial approvals. The EU has more protective regulations than Canada does.
4. The new treatment facility is not better than the current one
Northern Pulp’s proposed new effluent treatment facility differs from the present facility in a number of ways. In the present system untreated effluent is piped from the mill to the north settling ponds at Boat Harbour, where it remains for 12 hours for primary treatment. It then moves to an aerated stabilization basin where effluent is placed in contact with microorganisms. The effluent remains there for 8 days for secondary treatment. After 8 days, the effluent is discharged from the aeration basin at what is known as Point C, and treatment is considered finished.
At point C, samples are taken for testing to determine whether the treated effluent meets regulations. Point C is also a dead zone!
After point C, the effluent enters the 300-acre Boat Harbour lagoon, also known as Boat Harbour Basin. Boat Harbour Basin was initially used as a stand-alone effluent treatment facility. In 1972, settling ponds and an aerated stabilization basin were constructed to meet stricter regulations for pulp effluent treatment. Additional aeration and other upgrades were added from 1992-1996, as the federal government again adopted stricter regulations. The lagoon at Boat Harbour has not been officially part of the effluent treatment system since 1972. Official or not, treated effluent remains in the lagoon for an additional 20-30 days.
Further aeration, settling, cooling, volatilization and breakdown of materials takes place during that time. This is referred to as “polishing” or tertiary treatment. Natural springs and surface run off further dilute the effluent. According to Northern Pulp’s figures, during the time in Boat Harbour Basin, total suspended solids (TSS) and biochemical oxygen below the proposed water quality standard of 1%.”
The Stantec Preliminary Receiving Waters Study, August 2017, illustrates the same lack of dispersion. Treated effluent has never flowed directly into the deeper waters of the Strait. From its discharge at the shoreline, after 20-30 days in Boat Harbour Basin, tides and currents further break down, dilute and settle contaminants before they reach the deeper waters of the Strait. It is misleading to imply that effluent from the proposed new system pumped directly into the fishing grounds of the Strait within 24 hour that contains almost 1000 kg of solids will have the same impact as the effluent which presently enters the Strait at the shore edge, hugs the shore and recirculates in and out of Pictou Harbour.
Further to this, the same proposal was rejected in 1994 for the same concerns!
5. Better return for your tax dollars
Nova Scotians are on the hook for the Boat Harbour clean up which is expected to be close to half a billion dollars once remediated. They also paid for the design process of the proposed effluent process at a cost of $6 million and will be expected to cover the construction, installation, labour etc for the proposed pipe estimated at $100 million. Further to that $127 million of Nova Scotia tax payers money have been given to the mill in the last several years.
Meanwhile we have overworked doctors leaving our province. We have ER closures and very long wait times for treatment and care. Our education system is also at its max with constant cuts. Funding for seniors and veterans as well as many other public programs and services would benefit from these large sums of tax dollars.
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