Subject: Backgrounder on Bennett Environmental Inc. Proposal
to Build aPCB Incinerator in Kirkland Lake Date: Sun, 13 Jan
2002 09:57:25
From: Northwatch <[email protected]>
To: (Recipient list suppressed)
 
PCBS IN KIRKLAND LAKE: BENNETT ENVIRONMENTAL INC.
 
Bennett Environmental Inc. wants to set up and operate a PCB
incinerator in Kirkland Lake to treat up to 200,000 metric
tonnes of contaminated soil, sludge and other debris from
across North America. Last year, Bennett announced that they
would undergo a full environmental assessment, but now they
want a narrow review that leaves out alternatives and health
impacts.
 
Polycholorinated biphenyls (PCBs) are a class of manmade
organic chemicals produced by the direct combination of
chlorine and biphenyl, a derivative of benzine.
PCB's have been banned in Canada since 1977 due to their
adverse effects on the environment and human health. PCB's
bio-concentrate and biomagnify, are extremely persistent
toxics, and are known carcinogens.
 
 
BENNETT'S PROPOSAL FOR KIRKLAND LAKE
 
Bennett Environmental Inc. is proposing to establish a
"fixed soil treatment" facility on Archer Drive in Kirkland
Lake. The proposed facility will be capable of receiving and
treating up to 200,000 metric tons of contaminated soil
annually from, according to Bennett, "a primarily North
American market base". Bennett says the proposed facility
will be a scaled up version of the BEI owned Récupère Sol Inc. treatment facility in Saint Ambroise, Quebec which is a "high
temperature thermal oxidiser", more commonly known as an
incinerator.
 
The proposed facility could accept soils and solids
contaminated with chlorinated organic compounds (for example
PCBs & PCP) as well as non-chlorinated organic compounds.
Soils and solids will consist primarily of soil, sediment,
concrete, brick, asphalt, sand, aggregate, roots, wood, and
similar materials removed during the cleanup of contaminated
sites.
 
The proposed facility could also treat packaging material
such as plastic liners, bulk bags, corrugated boxes and wood
used to package delivered soils. The chlorinated and
non-chlorinated organic compounds will include pesticides,
herbicides, fungicides, wood perservatives, PCB, PCP, PCDF,
PAH, PCDD, TCE, coal tars, hydrocarbons, creosote, and
"others".
 
The first steps in the Bennett system will be to screen,
crush or shred the contaminated soil and other waste
materials. Soil of similar contaminants may be homogenised
to achieve a more uniform moisture level, contaminant
concentration and granular (physical) consistency of the
feed stock, which would allow, according to Bennett, the
incinerator to function at peak  efficiency.
 
The thermal process equipment consists of a rotary kiln
primary combustion chamber (PCC), a secondary combustion
chamber (SCC) and an emission control system. The emission
control system consists of an evaporative gas conditioning
chamber (GCC), a dry scrubber system, a fabric filter and a
monitored emission stack. Contaminated soil is metered into
the PCC where it is heated to 650 to 800 C, and the
contaminants in the soil are vaporised. The vaporized gasses
mixing chamber where air and fuel are injected, and the
resulting gas mixture is directed to the secondary
combustion chamber (SCC) where the "total oxidation"
(incineration) takes place at temperatures over 1,000 C at a
prescribed retention time of just over 2 seconds. The gasses
exiting this chamber then move through an emission control
system and are then released to the environment.
 
INCINERATION HARMS THE ENVIRONMENT
 
Around the world, PCBs have been disposed of primarily by
incineration.
 
When PCBs are burned, they create dioxin, an even more
potent toxic chemical with a wide variety of adverse health
effects.  The United States Environmental Protection Agency
has found that the average body burden of dioxins and PCBs
among U.S. citizens are already sufficient to place all of
them at or near those levels at which human health effects
are known to occur. A recent survey by the United Nations
Environmental Programme (Inventory of World-wide PCB
Destruction Capacity, 1998) listed 37 incinerators that are
used to burn PCBs. The health threats to the local
communities surrounding these incinerators are significant,
but other areas of the world are threatened as well.  For
example, a report by the Center for the Biology of Natural
Systems in New York, USA, concluded that dioxin emissions
from incinerators in Texas, Florida, Utah, and Louisiana
migrated long distances and contaminated the Great Lakes.
People living near the PCB incinerator in Swan Hill, Alberta
have been warned against eating local game.
 
PROBLEMS MEASURING EMISSIONS
 
PCBs typically are incinerated at facilities that can
purportedly achieve a destruction and removal efficiency
(DRE) of 99.9999%.  This means that no more than .0001% of
the PCBs that enter the system escape through air emissions
"up the stack." Even this level of efficiency could mean
substantial releases of PCBs and dioxins over time. However,
there are several flaws with this way of measuring
emmissions. First, the DRE is not measured during daily,
routine operations when actual PCBs are being burned.
Instead it is measured during a one-time-only "trial burn"
of selected substitute chemicals under carefully controlled
conditions.
 
Second, the DRE only takes into account air emissions. A
high DRE tells us nothing about the amount of PCBs/dioxins
transferred into ash, left in the residual, or discharged in
waste water as a routine part of the incineration process 
 
Finally, not all PCBs that are intended for incineration
actually are.
 
While stack emissions and contaminated ash and waste water
are serious concerns, losses during transportation, storage,
and processing may be an even greater problem. . 
 
BENNETT'S ENVIRONMENTAL ASSESSMENT
 
In May 2000, Bennett Environmental "volunteered" for a full
environmental assessment of the proposed PCB incinerator.
But when Bennett produced draft terms of reference for the
EA a few months later, an examination of the need for the
project and alternatives was excluded, as was a full
examination of the health impacts (instead, Bennett wants to
include a 'risk assessment').
 
In April 2001, the Ministry of the Environment approved the
narrow terms of reference, and Bennett has now prepared a
draft environmental assessment document, describing the
project. The public comment period on the draft EA document
ends January 15, 2002. Bennett will produce a second or
final environmental assessment after reviewing public
comments. A final environmental assessment will be submitted
to the Ministry of the Environment, probably in the spring
of 2002, for government and public review. A decision on
whether there will be a public hearing will be made later in
2002, based on public comments and the Ministry of the
Environment's review.
 
January 2002
 
For more information about PCBs and the projects proposed for
Kirkland Lake, contact Public Concern Temiskaming at Box
592, Kirkland Lake, P2N 3J5, or email
[email protected] or contact Northwatch at Box 282,
North Bay, P1B
8H2 or email [email protected]
 
 
 
 
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