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contents
vol 22 no 4 FALL 2010
on the cover SUSTAINABLE REMEDIATION
8
12
15
29
Site remediation project managers may want their initiatives to reflect the principles of sustainable development, but translating that wish into hard science is difficult. A new five-step system from Golder Associates facilitates this in a way that's credible for all stakeholders. by Robert Noël-De-Tilly and Bernard Lefrançois
features EMERGENCY RESPONSE: SPILL CLEANUP Responding to Enbridge’s Michigan river spill. by Dec Doran
ER SIDEBAR: RIVER SPILL Dealing with a spill in Toronto’s Don River. by Jason Rosset
WASTEWATER TREATMENT: FACILITY
A look at Newalta’s facility in Surrey BC. by Dave Ellwood
BROWNFIELDS
MARKETPLACE
departments Editorial
4
Up Front
6
Workplace Safety
34
Environment Business
35
Ad Index
37
Legal Perspective
38
CleanTech Canada
(PAGES 17-25)
(PAGES 26-28)
BROWNFIELDS REHABILITATION: SOIL
GREEN ENERGY: ELECTRIC CARS
Waterfront Toronto's pilot soil-washing facilities.
Understanding plug-in car technology
by Laoise Hadley
18
ENERGY EFFICIENCY: PLANNING
SITE RESTORATION: DISPERSION
How to create an energy master plan
A high-tech fluid remediation system. by Patrick Hicks
26
by John Nicholson
22
by Jerry Carter & Zach Platsis
27
next edition (winter 2010) Supplements: Annual Buyers' Guide • Brownfields Marketplace • CleanTech Canada Editorial Focus: • Understanding US HazMat regs for exporters • PCB update • personal protection • environmental consulting • products and services Advertising closes, November 25, 2010. Advertising Artwork required, November 29, 2010. Call 1-888-702-1111. FALL 2010 HazMat Management 3
editorial
The Bitter Business of Bitumen
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by Guy Crittenden
”Until our need for petroleum is highly diminished, Canada’s future as the world’s only democratic oil kingdom is not in doubt.”
ost Canadians don’t think of themselves as “oil sheiks of the north” but that is what we’re becoming with the development of the oilsands in northern Alberta — the second largest reserves in the world — to feed an oil-thirsty world. But as occurs in oil-rich countries everywhere, fossil fuel wealth has triggered political fights and concerns about pollution. It hasn’t been a good year for oilsands proponents, at least in terms of public relations. Just how much the expanding projects are (or are not) causing pollution has been the subject of considerable high-profile controversy. The visit to the oil sands this fall by Avatar director James Cameron — suggesting northern Alberta is a kind of Pandora — was only the latest in a series of challenges for oil sands proponents. In June a senior Alberta government scientist was forced to retract public statements he made accusing two prominent oil sands critics of lying and manipulating data that suggested the projects pollute the environment. A public relations battle erupted this year between the Alberta government and oilsands opponents. One campaign from Corporate Ethics International saw billboards posted in Seattle and elsewhere with the slogan “Alberta: The other oil disaster.” The billboards are part of a RethinkAlberta.com campaign urging tourists to boycott the province; they link images of oil-soaked birds from BP’s Gulf spill disaster to oil-soaked oilsands birds. In September a $17,000 billboard ad campaign hit Times Square via which, over six weeks, the Alberta government hoped to rebut such negative public perceptions. Two 10-second pro-oilsands spots highlighted the province’s commitment to carbon capture and storage, and stated that “A good neighbour lends you a cup of sugar. A great neighbour provides you with 1.4 million barrels of oil per day. And does it responsibly.” What’s at stake for Alberta in this PR war is more than the opinion of tourists. TransCanada Pipeline has proposed the $7-billion Keystone XL pipeline that, if approved, will become the single largest conveyor of oilsands-derived oil to the United States. The 2,700-kilomtre long, metre-wide pipe would pump an additional 900,000 barrels per day all the way to refineries in Houston, Texas. The project has been denounced by some US lawmakers, including Henry Waxman, chair of the influential energy and commerce committee, and John Podesta, a politico with ties to President Obama. He described the oilsands as “polluting, destructive, expensive and energy intensive.” His prominence in the Clinton White House era is significant as the Keystone decision rests with US Secretary of State Hillary Clinton. And the recent Enbridge pipeline spill into a Michigan river hasn’t helped matters. (See article, page 12.) Apart from possible water pollution, the major environmental concern with the oilsands relates to their energy intensity and greenhouse gas emissions. With Texas-style oil wells, the value proposition is obvious: you drill a hole in the ground and black gold spurts up, yielding many units of energy for each unit one puts in. With the oilsands, the ratio is more like to two-to-one. (Experts say the fact that we’re developing the oilsands at all proves we’re in the era of “peak oil”.) A lot of natural gas is used to melt the bitumen. Of course, if you’re a global warming skeptic like me, the GHG emissions are less of a worry. Some deep thinkers have suggested Canada built nuclear reactors atop the oilsands to achieve an almost zero-emission bitumen melting process (an idea that’s still worth evaluating). Although I feel strongly that the oilsands developers need to be held accountable to high environmental standards, in the end, I think the US government will approve the Keystone pipeline and become a big customer of oilsands crude for several reasons, both practical and ethical. First, though critics have tried to compare oilsands development with the Gulf oil spill, BP’s disaster makes exactly the opposite point. Melting oilsands bitumen is far less risky than pumping oil from the ocean floor with deep well rigs. Second, the US government knows that if it doesn’t buy the oil, other fast-growing countries like China and India will. (China already has a huge financial stake in the oilsands.) Oilsands fuel is also consistent with the USA’s policy of relying less on Middle East oil. While petroleum products are less “green” than renewables, such energy sources won’t displace conventional fuel in the United States for a long time. While critics try to build a moral case against Canadian crude, Canada is arguably the only politically stable full-fledged democratic country exporting oil to the United States. The list of other major producers (Saudi Arabia, Nigeria, Iraq, etc.) is a rogue’s gallery of human rights abusers and terrorism supporters. I can’t recall the last time our government beheaded someone for being gay, or a fire department let a dormitory full of schoolgirls burn to death because they weren’t wearing full Islamic attire (as happened in Saudi Arabia a few years ago). I wonder why the oilsands opponents aren’t buying billboard space to oppose that. The oilsands developers will have to more proactively prevent pollution, and our society should invest in renewable energy. But until our need for petroleum is highly diminished, Canada’s future as the world’s only democratic oil kingdom is not in doubt. HMM Guy Crittenden is editor of this magazine. Contact Guy at gcrittenden@hazmatmag.com
4 www.hazmatmag.com FALL 2010
HazMat
FALL 2010
up-front
management
Vol. 22, No. 4
Solutions for the Business of the Environment
Guy Crittenden EDITOR gcrittenden@hazmatmag.com
Brad O’Brien PUBLISHER 416-510-6798 bobrien@hazmatmag.com Jamie Ross ACCOUNT MANAGER 416-510-5221 jross@hazmatmag.com Sheila Wilson ART DIRECTOR Kimberly Collins PRODUCTION MANAGER 416-510-6779 kcollins@bizinfogroup.ca Selina Rahaman CIRCULATION MANAGER Carol Bell-LeNoury GENERAL MANAGER, ECOLOG GROUP Bruce Creighton PRESIDENT
OUR TOP LETTER DEAR EDITOR: RE: BP’s Spill, Space Shuttles and 9/11 (Summer 2010 edition) Just a quick note to say I enjoyed Guy Crittenden’s recent editorial comparing BP’s spill, the Space Shuttle, and 9/11. Safety and the probability of accidents… it all boils down to people — and people at every level make mistakes. Big business, the government and (like you pointed out) yes, even NASA. No one’s infallible. Quite a lot of food for thought in what you had to say! Mark McLaughlin, PR/Marketing Coordinator MANCOMM mmclaughlin@mancomm.com
AWARD-WINNING MAGAZINE HazMat Management, USPS 016-506 is published four times a year by EcoLog Group, a division of BIG Magazines LP, a div. of Glacier BIG Holdings Company Ltd., a leading Canadian business-tobusiness information services company. HazMat Management magazine provides strategic information and perspectives to North American industry and government on pollution prevention and waste management issues. Readers include corporate executives, compliance and safe ty officers, industrial plant managers and operators, municipal government environment officials, working scientists, and consulting engineers. EcoLog Group products include Solid Waste & Recycling magazine, the ERIS risk information service, and a number of newsletters affiliated with EcoLog.com Head Office: Internet: Email:
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Information contained in this publication has been compiled from sources believed to be reliable, thus HazMat Management cannot be responsible for the absolute correctness or sufficiency of articles or editorial contained herein. Although the information contained in this magazine is believed to be correct, no responsibility is assumed therefore, nor for the opinions expressed by individual authors. Articles in this magazine are intended to convey information rather than give legal or other professional advice. Reprint and list rental services are arranged through the Publisher at (416) 510-6780.. Periodical Postage Paid Niagara Falls, NY, U.S. P.S. #016-506 U.S. Office of publication: 2424 Niagara Falls Blvd., Niagara Falls, NY 14304-0357 U.S. Postmaster: Send address corrections to: HazMat Management, P.O. Box 1118, Niagara Falls, NY 14304 Canadian Publications Mail Product Sales Agreement No. 40069240
Canadian Industrial Emergency Conference
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etired fire chief and current editor in chief of Fire Engineering magazine Bobby Halton was the keynote speaker at the Fifth Annual Canadian Industrial Emergency Conference and Expo. The event was held in Calgary at the Coast Plaza Hotel and Conference Centre, September 23-24. Halton’s forum “Unplugged” involved a short interview followed by audience questions, thoughts and opinions. The forum will highlighted the challenges, opportunities and issues facing firefighters everywhere. The conference included 100 exhibitors and ran simultaneously with the 26th Annual North American Vehicle Rescue Challenge. Visit www.industrialemergencyexpo.com Retired fire chief Bobby Halton
Return Undeliverable Canadian Addresses to Circulation Department — HazMat Management magazine 12 Concorde Place, Suite 800 Toronto ON M3C4J2 From time to time we make our subscription list available to select companies and organizations whose product or service may interest you. If you do not wish your contact information to be made available, please contact us via one of the following methods: Phone: 1-800-668-2374 Fax: 416-510-5133 Email: jhunter@bizinfogroup.ca Mail to: Privacy Officer Business Information Group 12 Concorde Place, Suite 800 Toronto ON M3C 4J2
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We acknowledge the financial support of the Government of Canada through the Canada Periodical Fund (CPF) for our publishing activities. ©2010 All rights reserved. No part of this publication may be reproduced without prior consent. PAP Registration No. 11032 Print edition: ISSN-1713-9511 Online edition: ISSN 1923-3469
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CONTRIBUTING EDITORS Lynne Bard • Michael Cant • John Hosty • Dianne Saxe • Usman Valiante
up-front
Danatec celebrates 25 years
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Danatec’s employees (from left to right): Lena Hogarth, Jill Friesen, Dana Haywood, Judith Berzins, Alina Martin, Warren Bailey, Jeff Power, Chris Plante, Jeff Storey and Steve Sorrenti.
anatec Educational Services is celebrating 25 years of providing workplace health and safety compliance solutions to clients across Canada. Incorporated in 1985, Danatec is a family-run publishing and information company focused on producing occupational health and safety (OH&S) materials used by safety trainers, as well as by large companies to train staff internally. Headquartered in Calgary, Danatec has offices in every major city across the country thanks to its emphasis on family values. “We are very family-oriented,” says Danatec Vice President of Sales and Marketing Alina Martin, who is also the daughter of Danatec President Ronald Martin. “We’re fortunate to have a knowledgeable, hardworking team of employees, agents and distributors who know the business and care about our customers.” Danatec published its first books in 1985 under contract to Transport Canada. Over the years, the company has updated its Transportation of Dangerous Goods Instructors Manual and corresponding TDG Handbook several times, setting the mark for dangerous goods publications across Canada. The company’s TDG Handbook is its number one bestseller; Danatec produces more than 30 publications, and is also conducts online OH&S training. The dangerous goods online training program won the Hermes Platinum Award last year, and the WHMIS program has won 12 awards in the past three years. This fall the company is launching its first app for iPhone and iPad, a convenient way to access a summary of the material covered in Danatec’s TDG training programs. Also new this fall is DanatecTV, which is a platform for electronic video delivery that allows users to view safety training videos on the internet with just a username and password. Visit www.danatec.com
Call for overhaul of US chemicals policy
A
group of investors has reminded US senators and representatives that reforming obsolete federal legislation governing toxic chemicals is necessary for American companies to be able to compete better internationally, lower health care costs, enhance productivity, and drive innovation. The investor letter, signed by 51 organizations managing more than $35 billion in assets, endorses S.3209, the Safe Chemicals Act of 2010 , and H.R. 5820, the Toxic Chemicals Safety Act of 2010. Both proposed laws would comprehensively overhaul the Toxic Substances Control Act of 1976 (TSCA). The letter, coordinated by the Investor Environmental Health Network (IEHN) and the American Sustainable Business Council (ASBC),
is directed to the chairs and ranking members of the House and Senate committees and subcommittees that will consider the proposed legislation. Exposures to toxic chemicals produce a tremendous drag on the economy, contributing to health problems throughout supply chains. Investors observe that proposed legal changes to drive development and disclosure of information on chemical hazards can especially assist those companies eager to reduce their “toxic footprint.” Because of TSCA’s weaknesses, companies have encountered major challenges in identifying the chemicals in their products and supply chains and gathering information about the toxic hazards of those substances. Visit www.iehn.org and www.asbcouncil.org FALL 2010 HazMat Management 7
cover-story
A new tool helps project managers embed sustainability principles in remediation projects
The “Triple Bottom Line”
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by Robert Noël-De-Tilly & Bernard Lefrançois
ustainable development (SD) requires that we meet our needs without impairing the ability of future generation to meet theirs. Forwardthinking organizations are starting to embed the principles of sustainable development in the operations. The question arises for project managers as to how we can integrate sustainability at the project level? How can we determine the most sustainable option? How can we facilitate the trade-offs needed in an optimized solution for an organization and different stakeholders? Environmental professionals subscribe to SD principles yet usually deal in hard numbers and sound science; they may find there are few decision-making tools they can apply in their work. With this in mind, Golder developed GoldSET© — an evaluation tool that can be used to weigh the pros and cons of multiple options concurrently with multiple aspects of sustainability (including the economy, society and the environment). So just how does one wrap a spreadsheet around the concept of sustainability? It’s important not only to do it, but to do it in a way that’s quantifiable and transparent to different stakeholders.
THE “TRIPLE BOTTOM LINE”
The SD concept stems from the recognition that economic activity must respect the integrity of the environment, while promoting social equity. 8 www.hazmatmag.com FALL 2010
Accordingly, economic, social and environmental aspects — the “triple bottom line” — are all important to a project’s success. Project proponents must show that the plan is financially feasible and also that it will meet social needs, otherwise the project may then run into local stakeholder opposition. In turn, this may translate into lack of support from political or institutional leaders. Failing to address environmental concerns will mean regulatory delays and denials, as well as opposition from environmental stakeholders and organizations. The challenge, for engineers and project managers, is finding a practical, workable way to determine ahead of time whether all three aspects of the “triple bottom line” will be satisfied. Frameworks have been developed by several institutions to
“The SD evaluation is performed-based on a structured system for ranking options.”
Robert Noël-De-Tilly Bernard Lefrançois
address this issue. These include the International Federation of Consulting Engineers (FIDIC, 2004), the World Business Council on Sustainable Development (WBCSD, 2008), the Organization for Economic Co-operation and Development (OECD, 2006), and the International Union for Conservation of Nature (IUCN, 2001), as well as performance indicators from the Global Reporting Initiative (GRI, 2006) and the Equator Principles (2006). These call for the need to tackle sustainability issues in a more pragmatic and transparent fashion. The difficulty is in implementing these frameworks at the project level and during the design phase. Organizations need tools to effectively and efficiently evaluate project proposals with a comprehensive sustainability approach. Such an evaluation process needs to be: • Easy to understand and communicate; • Defensible and transparent to the stakeholders; • Flexible so that both quantitative and qualitative information can be processed; • Balanced and comprehensive in regards to the sustainability principles; • Specific to the organization and its activities; and, • Pragmatic so that it can support sound decisions based on a rigorous evaluation of the prospect for sustainability performance.
A FIVE-STAGE PROCESS
The analytical framework developed by Golder involves a fivestage process integrated in an evolving, adaptable and versatile web application called GoldSET©(from Golder Sustainability Evaluation Tool; visit www.gold-set.com) Different modules have been developed to help project managers in different fields. Site description: Setting out a description of the site helps conceptualize site conditions and find out the key issues the project must address. It includes determining key stakeholders, their interests and needs. The project objectives are thus understood before the SD evaluation begins. Generating options: Because there isn’t generally one “right
Sus t
EN ain V a EC IRON bili ON ME ty SO OM NT F CIE ICS a TY 27 % c t s
GoldSET© checked
34 %
71 %
answer” in site remediation, it’s important to determine various possible ways of attaining the project’s objectives. Options must then be narrowed down according to whether they can meet those objectives. Selecting indicators: Indicators tailored to the project are selected, based on context and specifics of the project. The indicators should reflect the issues that are critical to the project’s overall performance and are chosen based on international and national references, as well as industry-specific references and legal requirements. Ranking options: The SD evaluation is performed-based on
FALL 2010 HazMat Management 9
cover-story
Applying sustainability criteria to a railroad operation
A
s one of North America’s leading railroads, CN seeks to create long-term, sustainable, profitable growth. In 2007, CN mandated the Golder Associates to develop a customized version of GoldSET, taking into account the environmental, social and economic dimensions of CN’s remediation projects. Thus, what was originally a qualitative tool was adapted to include quantitative analysis, including a greenhouse gas emissions, energy consumption, water usage, waste generation, duration of work and Net Present Value of options, tailored to the needs of CN. Two examples of applying the version of the program developed for CN, called GoldSET-CN-SR, are described below.
RECOVERING WEATHERED DIESEL
At a former CN yard in Saskatchewan, there was an existing treatment system for the recovery of weathered diesel. GoldSET©-CNSR identified “easy-to-implement” modifications for a high energy pump that would result in an energy savings of 17 per cent and a 15 tonne CO2 equivalent reduction in greenhouse gas emissions. During the evaluation of remedial alternatives, it was discovered that incorporating a biological percolation system to treat the hydrocarbon-charged effluent would result in a waste reduction of 90 tonnes of carbon filtered over the expected life of the project
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10 www.hazmatmag.com FALL 2010
cover-story
and 435 tonnes of CO2 equivalent reduction in gas emissions.
REMEDIATION A HYDROCARBON SPILL
Remedial options for a large diesel and gasoline spill in protected habitat (a bog), where vegetation re-growth and natural attenuation of hydrocarbons had been observed, were assessed using GoldSET-CN-SR. The findings demonstrated that excavating the contaminated area instead of implementing a natural attenuation monitoring program would have significant negative impacts on the habitat while generating more waste (5,000 tonnes) and greenhouse gas emissions (320 tonnes of CO2 equivalent). GoldSET: Copyright 2009 Golder Associates. All rights reserved.
a structured system for ranking options. Tailored scoring and weighting schemes are used to compile sustainability performance with respect to various dimensions under consideration. Depending on the size of the project and the level of uncertainty acceptable to the client (versus cost to reduce this uncertainty), the framework can be adapted to a level of detail where quantitative data are calculated (like energy consumption, greenhouse gas emissions, water consumption and wastes). Engaging some local stakeholders in the decision process may also be considered. Pre-determined scoring schemes are also used to evaluate qualitative indicators like health and safety, the impacts on landscape and cultural heritage (for instance). In GoldSET, the end result is a visual compilation of the sustainability performance of each option. The three axis of the triangle illustrate the performance of an option with respect to the three dimen-
sions of SD. Under normal circumstances, the optimized approach is illustrated by the biggest, most balanced triangle. Interpreting data: It’s an iterative process; if new information becomes available, it can be added. Sensitivity analysis performed on the outputs can improve the findings’ reliability. The result of this process is a more clear understanding of the issues, the options and the trade-offs among them, to guide selection of a remediation option that meets the project objectives in the most sustainable way. HMM Robert Noël de Tilly, Eng., is an Associate with Golder Associates, in Montreal, Quebec. Contact Robert at robert_noel-de-tilly@ golder.com Bernard Lefrançois, Jr., Eng., is a Project Manager in the Geosciences Group of Golder Associates in Montreal, Quebec. Contact Bernard at blefrancois@golder.com
Waterfront Toronto
Legal counsel from a business perspective Every business is affected by complex regulatory legislation and exposure to litigation. From environmental requirements and occupational health and safety laws, to TSSA legislation, civil liability and insurance issues, our experience and insight allow us to help you focus on the identification and management of your liability. For more information, please contact: Cynthia R. C. Sefton csefton@airdberlis.com 416.865.4730
David S. Reiter dreiter@airdberlis.com 416.865.4734
Wednesday, October 27, 2010 Westin Harbour Castle, Toronto
With speakers from: • Waterfront Toronto • Stuyvesant Environmental Contractors DEC UK Ltd. • Golder Associates Mark your Calendar & Register Today! Wednesday, October 27th, 2010, 7:30 a.m. Toronto’s Westin Harbour Castle Hotel. $69 includes a full breakfast. www.brownfieldsmarketplace.com/breakfastseries/
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FALL 2010 HazMat Management 11
emergency-response
I Got a Spill in Kalamazoo Responding to the Enbridge pipeline oil spill into Talmadge Creek, Michigan
Red emergency response trucks near the wall of a dam on the Kalamazoo River. The dam was a natural place to intercept oil from the river, the sheen of which is visible in this photo.
A
by Dec Doran
”Excluding possible fines and class-action lawsuits, the cleanup costs will likely be in the hundreds of millions of dollars.”
s the residents and business owners along the Gulf Cost were trying to deal with the environmental impacts and economic effects of one of the worst oil spills in U.S. history, the residents of Marshall Michigan were facing one of the worst oil spills in the U.S. Midwest. At around 9:00 a.m. on July 26, 2010, Kalamazoo County declared a state of emergency as heavy crude oil started to leak from a ruptured pipeline in Marshall, Township. The pipeline is owned and operated by Enbridge Liquids Pipeline. The leak started when a buried 30-inch pipeline — which was built in 1969 and moves about eight million gallons of heavy crude oil daily — suffered a failure. The opening was approximately 6’6” long and 4½” at the widest part of the failure. According to the National Transportation Safety Board (NTSB), the failure in the pipe was located approximately 25 feet from an upstream joint of a 40 foot section of the pipe. The 41-year-old section of pipe that failed is part of the Lakehead pipeline system that runs about 1,900 miles from North Dakota, around the Great Lakes and into Sarnia, Ontario.
12 www.hazmatmag.com FALL 2010
Before crews from Enbridge could shut down the pipeline and close the isolation valves (to stop the flow of oil from the damaged pipe) an estimated 820,000 to 877,000 gallons of heavy crude oil spilled into nearby Talmadge Creek, which flows into the Kalamazoo River. The pipeline crosses Talmadge Creek about one-and-a-half miles upstream from the Kalamazoo River. The Kalamazoo River then flows west to the city of Kalamazoo, and then northwest through Allegan County into Lake Michigan — source of drinking water for an estimated six million people in the northeastern Illinois area. Shortly after the spill was discovered, hundreds of Enbridge employees and U.S. EPA-approved oil spill cleanup contractors were dispatched to the scene. Containment booms and oil skimmers were deployed at designated containment and recovery areas along the Kalamazoo River in an effort to stop the oil from spreading further. The initial containment and recovery operations were hampered by high water levels that made access to the creek and the river difficult. In spite of these difficulties, the Enbridge crews and the US EPA contractors were
BAD LUCK COMES IN THREES Calgary, Alberta-based Enbridge Inc. has suffered a spate of pipeline problems recently. In September the company shut down Line 10, running from Westover, Ontario to Kiantone, New York due to a potential low-volume leak. The 146-kilometre pipeline transports 70,000 barrels per day of heavy and light oil and other products. The pipeline runs through the Buffalo area, where a leak may have occurred. The company and its affiliate Enbridge Energy Partners also dealt with a spill near Chicago, in addition to the large spill that leaked hundreds of thousands of gallons of oil into a southern Michigan waterway in July.
able to contain the oil along a 25-mile stretch of the Kalamazoo River. Fortunately, the containment efforts prevented the oil from entering Lake Michigan. Due to the high levels of airborne crude oil vapors, as a precautionary measure the Calhoun County Health Department ordered the evacuation of about 50 homes and issued a bottle water advisory for all the affected areas along the river. Residents along the river near Battle Creek were also advised not to drink their tap water due to concerns the oil could contaminate their
Crane deploys a boom on the river.
drinking water wells. (Recent tests confirmed the drinking water wells were not impacted by the spill.) Because the spill happened inland rather than offshore, officials from US EPA assumed responsibility for supervising the cleanup operations and restoration activities along the creek and the river. Under the Oil Pollution Act (OPA) of 1990, EPA has specific roles and responsibilities regarding inland oil spill. As a result of these roles and responsibilities, EPA officials and other federal and state agencies mobilized immediately in response to the Enbridge spill and took a series of steps to minimize the damage to the river and the surrounding communities. In order to contain and recover the oil on the
© 2010, GAC
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FALL 2010 HazMat Management 13
emergency-response Kalamazoo River, Enbridge personnel and the EPA clean-up contractors set up staging areas along the river in several areas between Marshall and Kalamazoo. Vacuum trucks were used to recover the oil from the river at designated recovery areas. The recovered crude oil and oily water were transported to the staging areas for temporary storage and separation. To date, over eight million gallons of crude oil and oily water have been recovered and shipped off-site. The operations then shifted from emergency response to cleaning up the residual contamination along the river banks. Based on my personal observations of the overall oil spill containment and recovery operations along the Kalamazoo River, from a technical perspective, the Enbridge personnel and the US EPA contractors mounted a very effective and professional response to this a serious spill. Clearly, this spill had the potential to get a lot worse if the proper control measures had not been implemented quickly. In the United States, the federal agency that regulates pipelines is the Pipeline and
14 www.hazmatmag.com FALL 2010 tharris_half_pg.pdf 1
Closeup of the 6’6” x 4½” pipeline rupture.
Hazardous Materials Safety Administration (PHMSA). PHMSA reports that in general the number of hazardous liquid accidents in the United States caused by corrosion is trending downward, but clearly, something went seriously wrong with the Enbridge Liquids Pipeline. The cause of the failure of the pipe is still under investigation by the NTSB. It took several weeks to remove the oil from the river and it will likely take months to clean the residual oil from the river
banks. In all likelihood, it will take several more months to clean up the marshy area where the oil spill occurred. Excluding possible fines and class-action lawsuits, the cleanup costs will likely be in the hundreds of millions of dollars. HMM Dec Doran is the Oil Spill and Firefighting Coordinator for Oil Spill Control Services Inc., in Richmond Hill, Ontario. Dec can be reached at oilspill@sympatico.ca
2/16/07 9:24:30 AM
emergency-response-sidebar
Fuel Oil, Swift Water Responding to a spill into Toronto’s Don River by Jason Rosset
Vacuum trucks in the equipment staging area. Members of the public walking into this area was a constant concern.
O
n Sunday August 15, 2010, construction crews working at a plaza on Eglinton Avenue East in Toronto unearthed an underground oil storage tank under the plaza parking lot. It was a surprise discovery. This tank turned out to be in service almost 100 years ago when that parcel of land was used by the Royal Air Force in the early 1900s. The tank was accidently punctured during the excavation and although work was done to secure the tank overnight, a massive downpour of rain ensued later that same evening which flooded the ruptured tank and caused its fuel oil contents to leak into the site storm sewer system. The nearest outfall from the site storm sewer was only 100 yards away, discharging directly into the West Don River. The sewer outfall was directly under Eglinton Avenue bridge and in the middle of a large open green space called Wilket Creek Park; the discharge emitted directly into the river.
Accuworx Inc., an environmental services and emergency response company, was hired by the property owner to contain and clean up the spill. Monday (the next day), the spill made headlines on radio, TV and local newspapers. The location of the sewer outfall in the middle of a large public park was highly visible to the public, and this added additional safety risks to the clean up operations. Several government agencies were onsite including Ministry of Environment, Environment Canada, fire, police, Ministry of Labor and the Toronto Conservation Authority. Mobilizing vacuum trucks, trailers, tankers and remote access vehicles amongst curious onlookers frequenting the park meant Accuworx had to develop a safety plan not only for its workers but also the public who at times walked into the equipment staging area. There are significant challenges when dealing with an oil spill in a body of water that is fast moving and
”Cleaning contaminated vegetation on the shoreline was a challenge due to quickly rising water levels.”
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Vacuuming oil contained by absorbent booms; keeping workers safe from the swift current required special strategies.
This 100-year-old tank was in a parcel of land once used by the Royal Air Force in the early 1900s.
worker caught in the current would be quickly retrieved. The regulatory requirement to have a boat present was ruled out as a potential means of rescue as the current limited the ability to maneuver a vessel in the waters and retrieve a fallen worker. In addition, the current would have made any rescue attempt with a boat difficult — a person would be carried away by the river before rescue workers in a boat could arrive at the worker’s location. It was determined therefore that tying off or “tethering” the workers to an adequate anchor point on the shore and manning the lifeline with two rescue workers (to pull a fallen worker to the shore) was the quickest and safest strategy. These rescue plans were reviewed with Ministry of Labour personnel and deemed satisfactory. Once the boom was deployed, crews were able to recover captured oil using vacuum trucks. Additional river booms were installed downstream for secondary containment. Cleaning contaminated vegetation on the shoreline was a challenge due to quickly rising water levels. Areas covered in oil became submerged. The local conservation authority didn’t permit removal of any vegetation as it served as a natural form of erosion control on the river bank. Washing the vegetation was ruled out as an option by the conservation authority as well. Accuworx removed the oil covered foliage by trimming the brush and taking care to cause no root damage in the process. HMM
with fluctuating levels after a major rainfall. The unique safety hazards required specific work procedures so that employees could carry out the required spill cleanup safely. Access through thick brush on the river bank required the use of a Kubota remote access vehicle equipped with containment supplies; this transported responders down the shoreline of the river safely. The swift current made installation of containment and absorbent booms at the outfall both a physical and occupational safety challenge. Ropes and pulleys were used to reduce the requirement for physical exertion by the remediation crews entering the water, and to limit the amount of manhandling necessary to deploy the containment equipment. All workers entering the river wore hip waders and personal floatation devices (PFD), and all workers who had the potential to fall into the water were required to also use fall protection. Prior to entry a detailed rescue procedure was developed by manage- Jason Rosset, B.A., is President of Accuworx Inc. in ment and the Joint Health and Safety Committee; this Brampton, Ontario. Contact Jason at jrosset@accuworx. was reviewed with the crew in order to ensure that any ca 16 www.hazmatmag.com FALL 2010
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SOIL WASHING Waterfront Toronto uses advanced technology to remediate old industrial land — page 18
SUCCESS UNDER GROUND
New dispersion technology — page 22
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WATERFRONT TORONTO USES ADVANCED TECHNOLOGY TO REMEDIATE OLD INDUSTRIAL LAND
SOIL WASHING
by Laoise Hadley
T
oronto is committed to cleaning up some 800 hectares (or about 1,975 acres) of land in a multi-stage, multi-year series of projects designed to revitalize the city’s waterfront. The three orders of government established Waterfront Toronto in 2001 to oversee the revitalization. Projects include new parks, artificial beaches, recreational areas and residential and commercial (multi-use) neighborhoods. With more than two million cubic metres of soil expected to need remediation, Waterfront Toronto has teamed up with DEC of Belgium and Canada-based Tetra Tech to launch two pilot projects to test the viability of a state-ofthe-art soil management facility. If the pilots are successful, Waterfront Toronto will consider moving forward with, a larger, long-term facility. “Waterfront Toronto’s commitment to sustainability starts from the ground up. We’re leading one of the largest urban brownfield remediation projects in the world, and rather than simply ‘digging and dumping’ contaminated soils, we’re treating them as a resource. We plan to, wherever possible, clean and recycle the soil for reuse on our waterfront projects,” says John Campbell, President and CEO of Waterfront Toronto.
In addition to contaminated water run-off from industrial facilities there have been chemical and oil spills on land and in the surrounding waterways, resulting in subsurface contamination. There’s potential to find varying amounts of formaldehyde, butadiene, manganese and lead. Some of the more hazardous contaminants such as Benzene, PCBs, benzo(a)pyrene, carbon tetrachloride, chlorodibromomethane, chloroform, dichloroethane, trichloroethane, and bromodichloromethane are known to be carcinogenic, or to cause nervous system related illnesses, and require a strict adherence to maximum allowable containment. Much of the Toronto Harbour is landfill, extending a kilometre or more from the natural shoreline. In the early 1900s Ashbridges Bay was filled in and the Port Lands area (Cherry Street to Leslie Street) was created. The bay was filled in partly due to concerns about public health — locals had disposed of sewage, farm animal carcasses and household waste in the bay for years. Having a section of the shoreline filled also allowed for easier access for larger ships as the shore then extended into a deeper part of the lake.
History and site conditions Dating back to the late 1800s, the waterfront areas of Toronto were devoted primarily to industrial use. In addition to a busy port and rail links, there was a foundry and tanneries. There were facilities used for the storage of coal and oil, incineration and garbage disposal and other various manufacturing companies.
Laoise Hadley 18 www.hazmatmag.com FALL 2010
“The Waterfront Toronto soil washing pilot is due to be completed by November 2010.”
View from the west southwest of the entire soil washing pilot site. Photos courtesy of Waterfront Toronto / Alan Gibbins, anglersthreemultimedia
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Soil Washing Technology Soil washing technology has been around for many years and has been used effectively in Brazil, the United States, the Netherlands, Belgium, the UK, Sweden, and other parts of Europe. In the Waterfront Toronto project there are two proponents demonstrating similar but subtly different soil washing technologies: Tetra Tech is using technology from Stuyvesant Environmental Contracting Inc. (SECI), a subsidiary of Netherlands-based Boskalis Dolman bv; DEC is part of the DEME group — a Belgian holding company. The technique is designed for a water-based volume reduction process, using particle size and density separation. The treatment principle is based upon the fact that most contaminants “normally” are concentrated in the fine-particlesize fraction of the soil due to the exponentially high particle surface area, coupled with associated particle charges. The “fines” fraction is generally taken to identify those particles smaller than 63 µm in diameter (or approximately 200 mesh). Oversize material is removed through various screening steps such as fixed bar screens, rotating trommel screens, log washers, and wet vibrating screens. (The selection of the screen is tailored and selected for the specific site.) The sand is separated from the fines using hydrocyclones and up-flow classifiers, and is then dewatered using high-frequency dewatering screens. The fines (suspended in a large water volume) are coagulated, flocculated, and settled in pre-thickeners and clarifiers. Water is removed for reuse or discharge, and thickened solids are dewatered using belt or plate and frame filter presses. The focus is on minimizing the volume of contaminated material to be disposed of by extracting clean material (sand, debris) for beneficial use and by dewatering the fine (contaminated) fraction as much as possible. A traditional soil washing process has three major stages (pre-conditioning, sand separation and polishing and mechanical dewatering). In general the following output fractions are generated in the three stages: 1. Oversize material: Generally all of the mass greater than 2 mm, this fraction includes everything from pea gravel to gross oversize materials like concrete rubble, tree limbs, tree trunks, old reinforcing steel, and so on. 2. Sand fraction (sometimes called the “coarse” fraction): Material <2mm and >63µm; the sand fraction consists of coarse and fine-grained sand. The interface between the sand and fines of 63µm is standard, but is not fixed for processing purposes as smaller particles may be usefully included in this fraction. 3. Fines fraction: All material <63µm, this fraction includes clays, silts, and decomposed organics. (Note that the above describes the Stuyvesant technology. In the DEC system, Step I is a two-step process. Everything above two inches (the oversized fraction) is separated, and then the “gravel” fraction (between 2 mm and two inches) is removed. This maximizes the reusable fraction.) After sampling and physical and/or chemical analysis, the coarse material and the sand is potentially ready for beneficial use. Based on experience in the European market this material can be marketed as aggregate material to the construction industry. The separated fines are potentially contaminated. The mechanically dewatered fines can be further treated by, for example, stabilization, solidification or thermal treatment. This additional treatment is not an integrated part of the soil washing process. DEC says that lab-scale tests suggest soil washing can be optimized to elevate the removal efficiencies of the contaminants (metals, PAH, hydrocarbons, etc.) from the reusable fractions. Contractors and equipment vendors have had the opportunity to gain a lot of experience in other countries, resulting in sophisticated plants and technologies. The throughput of the plant has increased to 100-150 tonnes of soil per hour, meeting or even out-producing excavation capabilities. Modern plants have a high level of automation, resulting in an optimum process efficiency and minimum use of (chemical) additives like, for example, polymer used for the mechanical dewatering of the fines. Modern equipment is built on standardized container frames. Once on site, all the individual plant parts (containers) are stacked together and connected, resulting in a quick (and cheaper) mobilization. Due to this plant design the process is flexible as well. Additional plant parts can be added easily and/or unnecessary plant parts can be left uninstalled. A modern plant has a footprint of between 1,000 m2 and about 2,000 m2, making it a financially attractive option for brownfield redevelopment. Soil washing technology is used in treatment centres in Belgium and the Netherlands that act as central points for soil to be transported to and cleaned up by a range of techniques (biological, soil washing, thermal desorption, stabilization, etc.). — With notes from Bastiaan Lammers (Tetra Tech/Stuyvesant) and Sven De Puydt (DEC/DEME)
Soil washing Very often the method to deal with impacted soil is simply to “dig and dump” in which the excavated soil is literally trucked away and dumped in a landfill, with new, clean soil brought in to replace the excavated soil. This wastes time, treats soil as waste and needlessly uses up precious landfill
space. Soil washing, in contrast, recycles the soil for beneficial reuse. The Waterfront Toronto pilot project is underway and is expected to process up to 50,000 cubic metres of soil. There are two proponents — DEC and Tetra Tech — demonstrating different soil washing processes at mobile FALL 2010 HazMat Management 19
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(Top) Aerial view of the DEC/DEME facility. (Below) Aerial view of the Tetra Tech/Stuyvesant facility.
soil washing plants strategically positioned in the Port Lands area of the waterfront. At these plants the performance of the technologies will be assessed as well as the cost effectiveness of each process before committing to a larger full scale facility. The Port Lands area is close in proximity to the areas being remediated, resulting in less traffic between where the soils originate and the soil recycling facility. (See sidebar for a detailed description of the soil washing technologies.) 1. 1. 1. Soils excavated from waterfront projects are transported to the mobile pilot soil recycling facilities where they undergo testing for contaminants prior to cleansing. The soil washing method can treat soil contaminated with metals and low-level pollutants. However, any soil found to contain hazardous materials are disposed of in accordance with Ontario Ministry of the Environment regulations. The Waterfront Toronto soil washing pilot is due to be completed by November 2010 with reports from the two operators expected within weeks of completion. If the results are positive and the project demonstrates that soil washing is viable economically and technologically, Waterfront Toronto will consider proceeding with a fullscale facility to continue to remediate soils from other areas in the waterfront.
Laoise Hadley is a freelance writer in Barrie, Ontario. Contact Laoise at l.hadley@rogers. com
Sustainable Soi lutions
Proven Technologies Stuyvesant Environmental Contracting undertakes soil washing, sludge dewatering, river bed remediation brownfield development and beneficial re-use of aggregates. Modern separation and dewatering plants can be a valuable technique applied in your project. Early involvement of Stuyvesant Environmental Contracting in remediation projects can result in a financially attractive material balance with low investment and project costs. Stuyvesant Environmental Contracting www.stuyvesantenvironmental.com is the North American affiliate of Dutch based Boskalis Dolman. www.boskalisdolman.com
Stuyvesant Environmental Contracting Inc 3525 N. Causeway Blvd, Suite 612 | Metairie, LA 70002 | USA | Telephone Office: (504) 831 - 0880
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PRIMAWAVE HELPS INJECT REMEDIATION FLUID MORE EFFECTIVELY, LOWERS COSTS
SUCCESS UNDERGROUND
U
nderground remediation projects can be costly and time consuming endeavours for land developers. Managers can often encounter difficulties getting remediation fluid into close contact with target contaminants. Numerous injection points are often required with fluid coming to the surface instead going underground, a phenomenon commonly known as “daylighting.” Reaching contaminants in hard-to-reach areas, such as under buildings, can be especially challenging. Edmonton-based Wavefront Technology Solutions has developed an innovative process called Primawave that works with remedial injection equipment already being used onsite. The technology helps treat sites quickly while reducing costs by as much as 40 per cent, saving thousands of dollars in the process. Primawave works by using powerful bursts to disperse remediation fluid underground to effectively reach contaminants with pinpoint accuracy. The tool helps reduce the number of injection points with its increased efficiency while still reaching contaminants over a large area.
22 www.hazmatmag.com FALL 2010
Primawave’s beginnings emerged from academic research that Wavefront President and CEO Brett Davidson conducted at the University of Waterloo in 1997. He managed a group headed by Dr. Maurice Dusseault called the Porous Media Research Institute that studied the flow of fluids underground. In particular, his group examined cold heavy oil production, the
by Patrick Hicks
“Primawave helped decrease the number of required injection points by 75 percent from a planned 483 injection points to 120.”
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stability of boreholes and anecdotal information about how earthquakes can increase fluid flow in Alberta’s and Saskatchewan’s heavy oil fields. Davidson’s and Dusseault’s research eventually connected them with Dr. Tim Spanos at the University of Alberta who had developed his own theory on liquid flow. The trio proved in a laboratory that sending controlled bursts of fluid underground could increase the flow of oil to extraction wells. Patents were obtained and a company was formed around the technology shortly afterwards. Field trials were conducted in Alberta from November 1998 to February 1999. The trials provided very positive first-time-out results demonstrating that the technology could increase oil recovery by up to 34 per cent. After successfully marketing the technology to oil producers across North America, Wavefront decided to apply the technology’s principles to facilitate remediation projects. The principles of increasing the flow of fluids underground for the purposes of extracting oil were the same for increasing the distribution of remedial fluids underground. Instead of using pulses to “sweep” oil from underground, the technology could facilitate remediation fluid being placed in close contact with contaminants. Underground remediation projects often require numerous injection points because the fluid does not spread Clean Earth 1/4 ad Sept 2010
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readily to affected areas. The remediation fluid passes underground through the path of least resistance, leaving contaminated areas untouched unless another injection point is established. Standard piping or fittings are used to connect Primawave tools between the injection pump and a standard injection well or direct push injection point. Primawave sends out powerful bursts of injected fluid up to 600 times per minute depending on subsurface flow characteristics. The fluid is forced to move through the ground with greater uniformity regardless of permeability or soil variability. Davidson compares how Primawave works to a water hose with a kink in it. The pressure from the tap drives the water from the end of the hose at about 50 to 55 pounds per square inch. With a kink in the hose, energy builds behind the kink. “The host acts like an accumulator,” says Davidson. “People think that more pressure is being created but that’s not possible. You can’t create pressure when it’s still coming from your house. What you’re doing is storing energy.” When the kink is released, the stored energy accelerates the flow of water until it returns to the naturalized flow. Primawave works similarly downhole as it stores and releases the energy driving remediation fluid into a contaminated site. With conventional remediation injection, the fluid
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finds the path of least resistance underground. By adding a pulse, the fluid moves more extensively underground and gets into close contact with the contaminants. Put more technically, the Primawave pulse causes a momentary elastic flexure of the formation pore structure. The pulse moves fluid into and out of a larger number of pore networks, obtaining a more uniform front to increase remediation fluid dispersion. What makes this a game-changing technology is that it increases the efficiency of existing equipment with minimal additions. Instead of drilling more injection points, the system increases efficiency with existing production strategies and reduces remedial product daylighting.
Projects
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Last year in New Jersey, a two-acre former industrial site was redeveloped for residential use and had high concentration levels of chlorinated and non-chlorinated organic compounds requiring treatment. The schedule called for rapid remediation of the contamination with minimal impact to adjacent property owners. Primawave helped decrease the number of required injection points by 75 percent from a planned 483 injection points to 120, reducing time in the field by more than one month. In addition, remedial costs were reduced by more than 40 per cent. “Remediation strategies tend to concentrate on chemistry, not remedial product delivery,” says Davidson. “When results like this can be generated, it becomes apparent that fluid delivery is also very important in the overall cost of a project. In the New Jersey case, the cost of the Primawave equipment easily paid for itself.” In addition to being an effective remediation strategy, Primawave is simple to use. Operators can use Primawave literally “out of the box” by following instructions included with the equipment. Operators simply use a standard piping or fitting to connect Primawave between the injection pump and a standard injection well or direct push injection point. The simple, low-maintenance design allows for onthe-fly adjustments to match site-specific characteristics. Primawave has been employed throughout Canada and United States and last year saw new international projects in Australia and Denmark. Wavefront was also acknowledged earlier this year in the Toronto Stock Exchange’s Venture 50 as one of the strongest performers in the clean technology category, and has been verified as an effective environmental remedial strategy by Environment Canada’s Environmental Technology Verification Program. An image of the Primawave technology appears on the cover of the Brownfields Marketplace supplement on page 17.
Patrick Hicks is Vice President of Wavefront Technology Solutions Inc. in Raleigh, North Carolina. Contact Patrick at patrickh@ onthewavefront.com
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CleanTech Canada THE FUTURE OF ELECTRICAL VEHICLES IN CANADA
BRIGHT OR NOT-SO-MUCH?
W
ho killed the Electric Car? is a 2006 conspiracy-type documentary on the creation, limited commercialization, and deliberate destruction of General Motors EV1 electric vehicle during the 1990s. The film downplays the fact that the car cost far more and offered far less than comparable gas-powered vehicles. Flash forward to 2010 and GM is on the cusp of launching a new electric vehicle, the Chevy Volt. The wealthy and environmentally conscience amongst us can now have their electrical vehicle at a starting price of $41,000 US. (This does not include government rebates.) Not too far behind the Chevy Volt will be a battery-powered Ford Focus, Mitsubishi i-MiEV, the Nissan LEAF, and Toyota Prius Plug-In Hybrid. Despite the view among some that e-vehicles are new technology, they only need to look around the world to see them in use. According to Electric Bikes Worldwide Reports, there are approximately 40 million light e-vehicles in use around the world. A good number of the world’s golf courses utilize electric golf carts. In Nepal, a fleet of 400 e-buses operate within the city and Toronto’s iconic street cars are powered by electricity (as in many other cities).
Canadian opportunities In Canada there are two e-vehicle companies: ZENN (Zero Emission No Noise) Motor Company and Dynasty Electric Car Corporation. ZENN, centered in Toronto, has over 500 of its low-speed e-vehicles in operation around North America but has moved from selling e-vehicles to developing and deploying technologies. Dynasty, headquartered in Delta, British Columbia, has been selling neighbourhood electric vehicles (NEVs) since 2001. The sales challenge for the company in Canada is that their NEV can only be legally driven on roads in British Columbia. Greater potential sales are available in the U.S., where 45 states allow low-speed vehicles on roads, and overseas — specifically China and India. The development and sale of e-vehicles is only one opportunity
by John Nicholson 26 www.hazmatmag.com FALL 2010
“Experts and car industry executives believe a majority of initial e-vehicle purchases will come through fleet sales.”
available to Canadian companies as the move toward e-vehicles grows. There are tremendous challenges and opportunities related to the provision of electricity to re-charge the growing number of e-vehicles in Canada. Electricity generation, transmission, and distribution will all be affected as e-vehicles become more common in Canadian driveways.
The future of e-vehicles Hybrid vehicles that combine gas and electric motor, considered as a harbinger of pure e-vehicles, have proven it’s possible to wean consumers away from gasoline-powered automobiles. In 2009, it was estimated that 1.5 per cent of all passenger cars sold were hybrids. More interestingly, worldwide sales of hybrid cars increased 33 per cent from 2008 to 2009. It appears that e-vehicles are here to stay. With advances in technology, more government incentives, and the reduced cost of vehicles as more are produced, it’s likely that the prediction that one in 20 vehicles on the road in 2020 will be electric may actually come true. One example of a government incentive is the Ontario program that provides up to $10,000 in rebates for purchasers of plug-in vehicles. Add the further incentive of green license plates that will allow e-vehicles to use the High-OccupancyLanes on major highways and one can easily envision a growing legion of smug and sophisticated e-car drivers in Ontario and other provinces. An online survey conducted by the Consumer Electronics Association (CEA) found that 40 per cent of respondents would be willing to test drive an e-vehicle. The CEA study shows that consumers are concerned about their relative cost, reliability, battery life, driving distance before recharge (approximately 160 kilometres), and time for battery recharge (anywhere from 20 minutes to eight hours). Experts and car industry executives believe a majority of initial e-vehicle purchases will come through fleet sales. An example of a fleet purchase is the plan by the Ontario government is to have 20 per cent of eligible new public sector passenger vehicle purchases to be electric by 2020. The environment and potential cost savings (1.25 cents per kilometre vs. 7.5 cents per kilometre for a gas-powered car) are the two primary reasons cited for considering an e-vehicle according to the CEA study. Government incentive program wills help sell some cars but they won’t last. The ability of auto companies to get beyond first adapters and the environmentally conscious and assuage concerns will determine the overall success of the e-vehicle market. John Nicholson, M.Sc., P.Eng. is based in Toronto, Ontario. Contact John at john.nicholson@ ebccanada.com
CleanTech Canada COST, EFFICIENCY AND OPERATIONAL BENEFITS FOR INDUSTRIAL AND MANUFACTURING COMPANIES
N
ENERGY MASTER PLANS
by Jerry Carter & Zach Platsis
ot too long ago, making decisions about a company’s energy management and sustainability was a fairly uncomplicated process for most facility managers. But today it’s different. For industrial and manufacturing companies with large campuses or multiple facilities, possibly operating with different production systems and scattered across various geographic locations, managing such a task can become a significant challenge. The importance of the problem is magnified even further for those facilities that have high energy usage, deal with hazardous materials or have sizable waste disposal issues. The solution for resolving the integration of energy and sustainability projects and assets in large industrial, manufacturing and institutional facilities is a fully integrated energy master plan. This is a long-term, broad-scoped plan that puts in place a company’s strategy to optimize all facets of energy efficiency and sustainability. Although the components of the energy master plan are not entirely new, the necessity of putting this all together into
a single integrated package is a new approach, something that many larger companies are now recognizing they need in order to make smarter energy decisions. This approach allows energy managers to recognize opportunities for conservation, sustainable design and renewable energy that more narrowly-focused energy audits might not.
Four stages of an integrated plan An integrated energy master plan is individualized for each company, but includes the following four-stage parameters: 1) Investigation: The first phase of an integrated and comprehensive energy master plan is investigation. What is a company trying to achieve with such an initiative? What is, and what is not to be considered within the scope of the plan? This involves interviewing key personnel relative to known and unknown problems regarding energy, production and maintenance issues. It also includes identifying constraints, such as financial, physical, cultural, zoning and any other limitations that
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may be intervening factors in an energy strategy. The investigation also includes review of historical utility bills, a review of the company’s carbon footprint and emissions, gathering of relevant facility, electrical and mechanical drawings, specification sheets and automated energy management system records. 2) Visioning: This phase brings together key decision makers, such as the CEO, the head of energy or the head of facilities, to understand what their vision is. Is it to reduce energy consumption over a period of time, to manage risks, or to add renewable energy? What exactly is their goal, their vision? How do these goals tie in to the overall business objectives of the company, including factors such as product line changes and expansions, and facility build-outs or acquisitions that would influence decisions? What do they want to end up with ten years from now, so that can be backed up into a five- or ten-year plan. It presents an in-depth review of the findings from the Investigation phase, including quantifying and visualizing system consumption and output; benchmarking to baseline and best practice systems; summarizing objectives and critical issues; identifying opportunities to pursue; and considering potential paths to follow. Critical to this phase is a clarification and modification of the vision for the energy plan, as needed to achieve its stated goals, and to determine what is to be included and not included in the plan, as well as to determine how to manage constraints. 3) Analysis: A company now looks at all of the opportunities available, compared with the clarified vision and plan. It more closely investigates those technologies that can be utilized, and assembles basic costs and a phasing schedule to stagger the introduction of the technology as deemed most effective. A multiple-approach master plan is then drafted.
This part of the plan assesses energy and water efficiency, facility and equipment enhancements, heat and water recovery, control systems, sustainable systems, utility billing rate structure, peak shaving and shifting, and onsite power generation including renewable energy. 4) Deliverables: The last phase encompasses finalizing the energy master plan. This comprehensive plan includes an investment plan, energy targets, building sustainability targets, emissions and carbon footprint targets, operational targets, informational targets, and maintenance and upkeep targets. The plan also identifies final budget and resource commitments. This section phases in all of the technologies and how the capital spend will be administered. It puts together any kind of internal communications tools that will be needed — everything needed to understand what this plan is, how to communicate the plan, how to present it to management, and then how to implement the plan. For optimized feasibility, integrating both facility and process systems with a company’s overall sustainability objectives is ideal for a complete and integrated approach. Jerry Carter is Senior Associate, LEED AP BD+C and Business Leader for SSOE Group’s Sustainable and Renewable Solutions in Toledo, Ohio. Contact Jerry at jcarter@ssoe.com Zach Platsis, LEED AP O+M, is Energy Specialist for SSOE Group’s Sustainable and Renewable Solutions in Toledo, Ohio. Contact Zach at zplatsis@ssoe.com
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28 www.hazmatmag.com FALL 2010
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wastewater-treatment
Industrial Wastewater Treatment Newalta’s Surrey, BC facility by Dave Ellwood
B
ilge water, bunker sludge, BTEX water and oily water are some of the wastewater streams processed at Newalta’s state-of-the-art wastewater treatment facility in Surrey, B.C. The five-acre facility specializes in the treatment of hydrocarbon-contaminated wastewater, with the capacity to handle about 20 million litres annually. Whether it comes from a sump at a gas station or the bilge of a marine vessel, any liquid waste stream that does not meet discharge criteria set by local regulators must be properly handled either onsite or at a specialized wastewater treatment facility prior to disposal. Large industrial operations typically have their own wastewater treatment solutions built into their processes, but smaller to medium-size enterprises often look to a partner like Newalta to help manage wastewater issues. With growing global concerns about water safety and conservation, as well as increasingly strict environmental controls regarding the discharge of wastewater, Newalta’s Surrey facility plays an important role in helping industry recycle wastewater by removing contaminants before safely returning the water to local sanitary sewer system.
In addition, valuable product can be recovered in the process. In keeping with Newalta’s “What if Waste Wasn’t?” — philosophy, approximately 25 percent of the wastewater treated at Surrey is recovered as valuable hydrocarbon that is sold by the company for reuse as an industrial fuel oil.
FACILITY OVERVIEW
Built in 1997, the Surrey facility originally specialized in used oil treatment. In 2002 when Newalta acquired its North Vancouver used oil re-refinery, Surrey diversified and changed its focus to concentrate on wastewater treatment. Newalta operates a diverse network of 85 facilities across Canada, allowing it to capitalize on a broad base of waste management expertise and capabilities. In 2007, the Surrey facility’s wastewater processing capabilities were enhanced with the addition of a rotary drum vacuum filtration unit, electro-coagulation unit and tricanter centrifuge. These upgrades expanded the facility’s capabilities from batch discharge to continuous discharge, meaning the water, once processed, is discharged directly and continuously into the sanitary sewer instead of having to be stored in tanks for discharge in batches. “The technology upgrades allow us to treat large quantities and recover hydrocarbons with minimal manpower,” says Jagdeep Grewal, the plant’s branch manager. “This means a safer and more productive operation.” Wastewater containing crude oil, solvents, inks, suspended and dissolved solids or other contaminants comes to the facility from various sources including marine vessels, gas stations, refineries and pipeline spills. Bilge water, which is a combination of rain and sea water which leaks into a ship and collects in its bilge, is a key waste stream managed at the facility. In addition, the facility has the capability to handle waste from environmental emergencies such as tanker spills, pipeline breaks and ruptured freighter fuel tanks, as well as from event-based industrial projects such as At a flow rate of over 150 litres per minute, the electro-coagulation unit tank cleaning and refinery shutdowns. at Newalta’s Surrey facility continuously removes unwanted metals “We can recycle virtually any regulated wastewater from wastewater. requiring third-party disposal in the Lower Mainland
“Valuable hydrocarbons are recovered from slop and wastewater through a number of processes, the first of which involves natural separation in settling tanks.”
FALL 2010 HazMat Management 29
wastewater-treatment
Branch Manager Jag Grewal, background, supervises the “ALAR” Unit, which uses vacuum filtration to pull solid waste to the surface of a rotating drum.
and recover value from what was once considered waste,” says Grewal. “With our people and first-class technology we’re versatile and adaptive to the needs of our customers and able to help them with their sustainability objectives.”
WASTEWATER TREATMENT PROCESS Valuable hydrocarbons are recovered from slop and wastewater through a number of processes, the first of which involves natural separation in settling tanks. From
there, centrifugation separates oil, water and solids. Once fuels have been recovered for reuse and larger solids have been collected for offsite disposal, the wastewater is then ready for further treatment. Wastewater is treated through a combination of treatment technologies to make it suitable for discharge. Treatments are designed for specific waste streams and combinations of methods are used based on analytics. The basics of each treatment method employed at Surrey are as follows: Chemical treatment: from simple pH adjustments to complex treatments, such as the precipitation and removal of metals from waste streams. Vacuum drum filtration: a rotating drum uses internal vacuum pressure to pull solid waste to its surface where solids are continuously scraped off and collected for offsite disposal.
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www.arc2010.atlanticclra.ca 30 www.hazmatmag.com FALL 2010
wastewater-treatment
Electro-coagulation: positive charges from aluminum or iron plates cause metals to precipitate out of waste streams. Carbon filtration: water is filtered at the final stages prior to discharge into the local sanitary sewer system. Solids handling: solids are sent offsite to an approved facility for either disposal or further treatment. The facility acts as a “one-stop-shop” for customers, primarily operating water and sludge processing technologies, but also managing a range of slop fuel wastes and solid waste streams. “We are seeing an increased focus on sustainability from our customers, especially related to responsible water management,” says Alice Chung, Regional Manager of Newalta’s B.C. operations. “Surrey’s adaptive approach to wastewater recycling helps customers achieve environmental sustainability and exemplifies the culture at Newalta, which is to continually find better, more efficient ways to manage waste streams.” HMM
The ALAR unit’s blade scrapes off the filter media from the surface of the drum and these RemTech2010 1/2 pageoffsite. ad:Layout 1 9/21/10 3:05 PM Page 1 solids are collected for transport
Dave Ellwood is Sales Representative with Newalta Corp. in North Vancouver, BC. Contact Dave at dellwood@ newalta.com
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workplace-safety
IRS Your Internal Responsibility System by Lynne Bard
M
”The review and change stage creates the cyclical nature of the IRS System.”
any of us have Corporate Responsibility Statements as part of our corporate philosophy, mantras, in our vision, missions and value statements, yet do we live up to our corporate responsibilities when it comes to health and safety? The provincial governments across Canada are evaluating their health and safety legislations, compliance mandates and enforcement of legislative requirements. These changes affect the IRS within your organization. What is the IRS? It is not the US Internal Revenue Service we so often here about in the news and in the movies. The IRS is your Internal Responsibility System; an underlying philosophy of the occupational health and safety legislation in all Canadian jurisdictions — government legislated, mandatory across the country! And it is everyone’s corporate responsibility in the workplace. The “IRS” is the very foundation of health and safety in the workplace, establishing workers and employers responsibility for his or her own safety, for the safety of their co-workers and for development of the health and safety management system for your organization. Although the acts and regulations in your province may not impose or prescribe the steps you must take to comply, it holds employers, supervisors and workers responsible for determining the best-practice steps for your operation and industry to ensure health and safety of all workers in the workplace. It’s therefore imperative that you understand your provinces legal requirements in compliance with OH&S Legislation. Many provinces such as Ontario and Nova Scotia have recruited additional health and safety inspectors with the desire to educate and enact compliance, reduce the number of injuries and deaths across their respective provinces and enforce corporate responsibility/IRS. Inspectors are authorized to conduct workplace inspections and investigations to determine whether employers are in compliance with safe and healthful workplace standards in the province. Organizations are uncomfortable with an inspector coming to their organization because they do not know what to expect. Their first visit is usually proactive and fact finding; however it may be in response to a complaint from an employee, worker, or in response to an accident that your health and safety representative reported to the Department or Ministry of Labour (dependant on your jurisdiction). Here is some really great advice to help you prepare — Do’s and Don’ts:
A) DO NOT’S:
B) DO’S:
• DO politely invite them in; ask if they would like a cup of coffee while you contact your Health and Safety Representative to assist the inspector with the visit. • DO ask to see their credentials. Inspectors carry a badge (similar to that of a police officer), an ID Badge with their picture on it which serves as their warrant to investigate your organization and a business card. If they do not have proper ID (do not accept a business card only — anyone can print business cards) ask them for a phone number to phone and confirm who they are; and • DO ask the officer to state the purpose of their visit. Oblige them with the information they request in a timely manner. In preparation for an inspection, first ensure your IRS is up to date, that you have conducted your required inspections of the facility and documented them, and that all other health and safety requirements have been met or exceeds the regulatory requirements in your province. In developing your IRS processes, procedures and overall management system a few tips are provided for your reference: 1. The Planning Stage: This is the most critical stage in the process — the assessment of your organization and facilities. Document all steps in the process development of your IRS, processes and procedures; always getting the approval of senior management (owner, president or CEO of the company). 2. The Do Stage: a) During this stage in the process you will establish policy, procedures, protocols and training; establishing timelines, strategy and performance measures. b) Establish your management system processes, procedures and check systems. By establishing your IRS philosophy in everything you do, you will increase productivity, reduce costs and build a sustainable, reliable and cohesive workplace and above all a healthy safe workplace. 3. The Check Stage: During this stage in the process you will audit/check the system to ensure it is functioning properly: efficiently and effectively. 4. The Review and Change Stage: The review and change stage creates the cyclical nature of the IRS System. It’s critical that you review and update procedures, policies, and training; establishing new system procedures with additions and changes to the operations of your business minimally annually but more frequently as changes occur in the organization. HMM
• DO NOT send them away because they do not have Lynne Bard is President and Senior Consultant of Beyond an appointment, Rewards Inc, based in Guelph, Ontario. Contact Lynne at • DO NOT tell them that you do not have time for info@beyondrewards.ca health and safety or • DO NOT get upset with them. They are there to do their job — ensuring your workplace is safe! 34 www.hazmatmag.com FALL 2010
environment-business
GHG Trading in Canada Be ready when it arrives by John Nicholson & Kathleen Bai, M.Sc., B.Sc.(Eng.)
I
n the free world, anything can be traded — pork bellies, orange futures, home mortgages, derivatives — anything. Therefore the trading of greenhouse gas (GHG) emission credits shouldn’t be too much of stretch. The argument for market-based solutions for the reduction on GHG, such as a cap-and-trade system, is that they are the most effective and efficient means of lowering the emissions of GHG while providing industry the choice of either reducing emissions and/or buying credits. As long as there are established rules on how to measure the credits and consummate the trades, the efficiency of the market should take care of the rest.
the cap-and-trade program beginning January 2012.
GET READY AND CREDIT FOR EARLY ACTION
Under the WCI, entities in participating jurisdictions whose annual emissions exceed 10,000 metric tons of CO2e per year are required to report their 2010 emissions next year. Keeners that are part of the WCI program will get extra credit for taking early action to reduce there carbon emissions. Under WCI’s Early Reduction Allowance (ERA) program, reductions in CO2e between 2008 and 2011 are eligible. If the experience under the United Nations Clean Development Mechanism is any guidance, entities need EXCHANGES The GHG emissions trading market (typically referred to consider if the investment to achieve an ERA are to as the “carbon trading market”) is mainly centred in worth it. Europe, with 68 percent of all global trading in 2009 taking place through the European emissions scheme on GHG TRADING WINNERS the European Climate Exchange (ECX). Carbon trad- The certainty of a North American carbon trading maring on the ECX in 2009 was valued at e73bn ($100bn ket grows greater every month. Capped entities within Canadian). On September 10, the ECX spot price for an WCI jurisdictions that begin trading in 2012 will need emission allowance of one tonne of CO2 equivalent units to decide whether to reduce their emissions or purchase credits. (CO2e) was approximately $20 CDN. Although industries that produces vast amounts of Besides Europe, a significant amount of carbon trading takes place through the United Nations Clean CO2 (i.e., electrical utilities that use non-renewal energy) Development Mechanism ($22 billion in trades in will incur are cost for their emissions, there will definitely 2009) and the United States Regional Greenhouse Gas be winners amongst GHG generators. Initiative ($2.2 billion in trades in 2009). Similar to the need to only having to outrun fellow Besides the ECX, there is the Montreal Climate campers when confronted by a bear in the woods, capped Exchange (MCeX), the Chicago Climate Exchange companies can gain an advantage over their competitors (CCX), Tanjin Climate Exhange (TCX) in China and by addressing the looming CO2 trading market now. For Envex in Australia. example, some companies have already taken advantage of early reduction allowances. For non-capped entities, there will be opportunities CANADIAN TRADING MARKET In Canada, four provinces (Quebec, Ontario, Manitoba, to participate in the system by generating offset credits. British Columbia) have joined forces with seven U.S. Depending on the cost of implementation, it may be a states to form The Western Climate Initiative (WCI). cash-positive undertaking. The sectors considered to The goal of the WCI is to develop a cap-and-trade sys- have the greatest potential to generate emission credits (and cash) are agriculture and forestry. tem for its member jurisdictions. Protocols have already been established for a number In July, WCI released a roadmap document, Design for the WCI Regional Program, that partner jurisdictions of ways of generating offset credits including soil sequeswill use to implement cap-and-trade programs. A major- tration, manure management, and forest management. ity of the partners in WCI are focused on implementing Farming operations and forestry companies may be los-
”The sectors considered to have the greatest potential to generate emission credits (and cash) are agriculture and forestry.”
FALL 2010 HazMat Management 35
environment-business OHE is a multidisciplinary firm that specializes in providing high quality services in the field of environmental and health and safety consulting. We are a Canadian company with our head office located in Mississauga, Ontario and a network of associate companies strategically located in major centres across Canada.
ing money-making opportunities by ignoring the carbon trading market. Page 1 Municipalities should also look to carbon trading markets 496 South Service Road • Mississauga, ON L5G 2S5 as potential revenue sources. Any smart municipality would be examining the urban forestry protocol to determine if it could generate revenue through either the creation of ERAs or offset Kilmer Brownfield Equity Fund L.P. OHE/MC7607/HMM.indd 1 5/12/09 4:06:48 PM allowances. Canada’s leading fund dedicated to the redevelopment of brownfields The carbon trading market will certainly also be a boon to brokers, accountants, consultants, verifiers and other environPutting Private Equity to Work mental professionals. HMM
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John Nicholson, M.Sc., P.Eng. is based in Toronto, Ontario. Contact John at john.nicholson@ebccanada.com Kathleen Bai, M.Sc., B.Sc.(Eng.), is an expert in GHG emissions reduction validation, having worked at Lloyd’s Register Quality Assurance as a CDM validator and Bureau Veritas Certification as an environmental and quality lead auditor. She currently works at SNC Lavalin
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Intrinsik . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
Aird & Berlis LLP. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
Kilmer Brownfield Equity Fund . . . . . . . . . . . . . . . . . . . . . . . . . 36
AMEC. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 Atlantic Reclamation Conference. . . . . . . . . . . . . . . . . . . . . . . 30 Canadian Law Book. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 37 CERCA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32-33 Clean Earth Solutions Ltd . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 EnviroTech . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 FCM Green Municipal Fund. . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 First Response . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 GroundTech . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31
Lacombe . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 MMM Group. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Miller Thomson LLP. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Newalta. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 OHE. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 Pinchin Environmental Ltd. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 Proeco . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Stuyvesant Environmental . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
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Sustainable Development Technology Canada. . . . . . . . . . . 28
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XCG. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Hazco. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
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legal-perspective
Smith v. Inco
A precedent for contaminated sites?
J
by Dianne Saxe
”If this judgment is upheld on appeal, it would set a very important precedent for other cases of historic contamination, whether by industries or by government.”
uly’s decision in Smith v. Inco opens the door for private lawsuits for historical contamination across the country. Inco (formerly the International Nickel Company) operated a nickel refinery in the Town of Port Colborne for two-thirds of a century. Port Colborne fought hard to get the refinery and was proud to have it. It was the financial mainstay of the town. People moved to Port Colborne to take advantage of the economic opportunities, especially the well-paying jobs created directly and indirectly by the refinery. When the Ministry of the Environment was set up and the Environmental Protection Act came into effect in 1971, Inco complied with the new air regulations and obtained and complied with air permits. Nevertheless, nickel particles were emitted into the air and settled in the vicinity — no secret to local residents. The refinery closed in 1984. Sixteen years later, Ontario’s Ministry of the Environment released a study of phytotoxicity (toxicity to plants) in the Port Colborne area. The study received a great deal of publicity, focused on concerns about health (which ultimately proved to be groundless). The public mood changed “from one of tranquility to one of great concern.” Two main things happened as a result. First, the ministry commissioned a community-based risk assessment (CBRA) to evaluate the risks posed by the nickel to human health and the environment. The CBRA concluded that the ministry’s generic criteria for nickel contamination (based on phytotoxicity) were too stringent for the Port Colborne conditions, and established a special standard of 8,000 parts per million for the Port Colborne area. Twenty-five homes exceeded this standard; 24 of them were cleaned up by Inco under ministry direction. That left hundreds of homes with contaminant levels that met the CBRA standard, but did not meet generic ministry criteria for nickel in the rest of the province. These are the main property owners who sued. (None of the claims involve health impacts.) Many, perhaps most of them, purchased the properties after the nickel was already present. (The court judgment does not indicate how many of the property owners who owned property after 2000 had owned the property when the nickel was deposited prior to 1984. Given the frequency of real estate turnover in Ontario, many of them likely from bought the property long after every particle of nickel was deposited. Justice Henderson did not seem to consider this relevant.) Second, local real estate companies decided to protect themselves by inserting disclosures about the nickel into agreements of purchase and sale. This, according to the judge, caused local residents to “discover” that nickel contamination was bad for property values. This started
38 www.hazmatmag.com FALL 2010
the limitation period running again, allowing the Port Colborne residents to sue Inco so many years later. Did Port Colborne residents really suffer a loss of property value? The data cited by Justice Henderson is far from clear, but he concluded that property values in Port Colborne had risen more slowly than property values in the nearby city of Welland, by about $36 million. Was this lag because of the nickel, because of unfounded concerns about the nickel, or because of other factors entirely? According to Justice Henderson, it must have been the nickel, relying on the “commonsense principle that environmental contamination in a community will affect residential property values in that community.” He does not discuss why, if this was a “commonsense principle,” the people in Port Colborne only discovered it in 2000. On these facts, Justice Henderson ordered Inco to pay its Port Colborne neighbors $36 million in compensation for lost property values, plus legal costs. Unsurprisingly, Inco has appealed. The Smith v. Inco decision therefore stands for several controversial and somewhat circular points: First, that private lawsuits may be based on retroactive application of current environmental principles to historic behavior that was legal at the time. Second, that the mere presence of nickel particles is material physical damage to property, whether or not they exceed ministry standards, if there is a loss in property value. Third, that ambiguous evidence about loss in property value should be interpreted as proving such a loss, in light of the “commonsense principle” that contamination adversely affects property value. Fourth, that industries are strictly liable for current lost property value due to past activities, if that past activity was “non-natural” (Rylands v. Fletcher). For this purpose, virtually any industrial activity is non-natural. Inco’s refinery was “non-natural” because Inco brought nickel onto the land for the purpose of refining it. Moreover, once the nickel was brought onto the land, Inco processed or refined it, thereby creating airborne nickel particles. The nickel was not naturally on the land, and the nickel particles were not naturally on the land or in the air over the land. Further, the refining of nickel was not an ordinary use of the land; it was a special use bringing with it increased danger to others. If this judgment is upheld on appeal, it would set a very important precedent for other cases of historic contamination, whether by industries or by government. HMM
Dianne Saxe, Ph.D. in Law, is one of Canada’s leading environmental lawyers with her own practice in Toronto. Contact Dianne at dsaxe@envirolaw.com
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