Transcript Cornwall Material Resource Recovery proposal

Cornwall Material Resource
Recovery proposal
Status report
December 99
1
Cornwall, Ontario
material resources recovery unit
• Public hearings, attended by Ellen and Paul
Connett, June & August 1999
• application for permit to burn 30,000 ppm
PCB’s, current permitted for 50 ppm
• Cornwall/Massena area already heavily
contaminated with PCB’s
2
Cornwall hazardous waste
incinerator
•
•
•
•
October 1998, began operation
PCB’s from fluorescent light ballast
In the new permit they also want to burn:
pharmaceuticals, chlorofluorocarbons,
electrical equipment, poisonous and reactive
gasses, “controlled substances” and waste
oils.
3
Submission by P. and E. Connett
MRR permit application hearing
September 3, 1999
Email: [email protected]
4
Powerpoint Precis
of Connett submission
• by A. Goddard-Hill, M.D
• Email [email protected]
5
The Connett position
• “We are opposed to the granting of the
Certificate of Approval to MRR to burn 30
Kg of PCBs per metric tonne load, and
other additional wastes, except for the
disposal of confiscated illicit drugs…...
• Rather than allowing a cheap burn of PCBs
Ontario should pursue safer non-burn
alternatives practiced elsewhere”
6
12 Reasons for this position
7
1. A disturbing precedent
for Ontario & Canada
• The equipment is primitive
• This is an incinerator, presented to the
public as a recycling plant for metals
• It is a relatively cheap facility to be built in
an economically depressed part of the
province, thus presenting some attraction to
the community as a source of revenue
8
• PCB destruction is expensive: incineration
is the cheapest option
• a “DRE” of 99.999998% sounds impressive
but is based on test burns under ideal
conditions, and is often greatly at variance
with efficiency under actual operating
conditions
• chemical destruction methods are available
9
but are more expensive
2. Permitting process being
rushed: analysis lacks rigor
• (OWMC hearings (late 80’s) for proposed
hazardous waste incinerator were very
rigorous by comparison and lasted 10 yrs)
• MoE took emissions data from summary
tables rather than from detailed congener
profiles of pcb’s and missed a mistake in
how non-detects were treated in calculations
• Thus, their analysis lacked rigour
10
The mistake
• Proponent claimed that non-detects were
treated as though they were present at
Limits of Detection in the calculations
• this proved not to be the case, as discovered
by Connett, not the MoE (despite the
latter’s claim (Dr. Birmingham) to having
checked all the data
• Resulted in Doubling of dioxin exposure,
11
and thus risk
Consultant error
• Arthur Gordon Environmental Evaluators
Ltd
• made same mistake 15 times in its 3 test
reports
• did not include non-detected dioxins/furans
as “detection limits” in calculations
• their response when questioned on the
matter: “Welcome to the real world!”
12
Is the MoE engaged in the issue?
• MoE inspector attended just one of 3 tests
in March 1999
• (on which day dioxin emissions proved to
be much higher than on other two days)
13
The Big Omission
• Cow’s milk (and other animal fat) pathways
of intake were not included along with
vegetable and inhalation pathways by
Willes in original RA
• When he did so at Connett’s suggestion,
dioxin exposure via animal fat was 3000
times higher than the inhalation pathway
• this translates into a 600 fold increase in
14
dioxin exposure at regional dairy farms
Milk producer
• 5 counties surrounding Cornwall are
#5,7,12,13 and 15 in milk production in
Ontario
• 3 of these counties are downwind of the
facility
15
The Bigger Omission
• PCB emissions were excluded from
calculations of dioxins TEF’s by Dr. Willes
• some PCB’s have a high TEF (toxic
equivalency factor)
• in the absence of this element in the
calculation it is impossible to make an
accurate calculation of dioxin TEQ’s
present in the PCB emission at the facility
16
Consequences: MoE regroups
• As a result, MoE required that another more
closely inspected DRE test burn be done,
this time factoring in the PCB congeners in
the emissions, especially the 12 that have
dioxin-like properties, and that they be
included in the Health Risk Assessment
17
3. Quality of key data
questionable
• Very limited test data were provided
• PCB, dioxin and furan emissions were
relatively low according to this data, which
was not credible for a number of reasons
• emission data “too good to be true”
• other metal reclamation plants of similar
type elsewhere have had very high dioxin
emissions.
18
(lack of)
Pollution control devices
• low emissions only been achieved
previously by more elaborate facilities using
longer residence (burn) times, and far more
advanced air pollution equipment such as
spray dryers, lime injection, activated
carbon injection and baghouse filters
• this facility has only a single wet scrubber
as a pollution control device, so why is it so
effective? (no explanation offered)
19
4. Facility failed particulate
guideline in EVERY test
• Failed in 9/9 tests to meet the 20 mg
standard
• problem: most of the dioxins and furans
and as well metals (Pb, Cd, Cr, As) are
concentrated on these particulates, esp very
small particles, so high releases of
particulates are an important route of escape
for the chlorinated organic chemicals and
heavy metals into the environment
20
5. Over reliance placed on short
term tests to estimate long term
dioxin and PCB emissions
• only 6 test samples, 3 in Nov 1998 and 3 in
March 1999 were taken, on which total
health Risk Assessment and permitting were
based
• these are the DRE (“destruction and
removal efficiency”) tests of the incinerator
21
• second set of 3 samples taken when facility
only operating at Half capacity
• proponent’s consultants (Kolymeychok,
Willes) interpreted emission tests
• but Connett said: “Statistically there is no
way that an average from these 3 tests is
either accurate or a “conservative” estimate
annual emissions”
22
Ideal vs Actual
• proponent has not established what “actual”
emissions might be over an extended period
of time and outside of the “ideal” conditions
of the test burns (operates at 750 deg C)
• measurements were not taken during
startup/shutdown intervals and upset
conditions when furnace temperature is
favorable for dioxin formation
• dioxin forms in a 200- 400 deg C “window”23
6. No emission data was
presented for other wastes
proposed for burning
• Permitting for the burning of wastes other
than PCB’s is being applied for without any
testing whatsoever
• e.g. other facilities burning electrical scrap
have very high dioxin emissions
• each category of waste should be subjected
to rigorous test burns prior to approval
24
pharmaceuticals
• No health Risk Assessment prepared on the
incineration of pharmaceuticals
• no chemical analysis of the scrubber water,
fugitive ash emissions and ash handling
25
7. Permitting is insensitive to the
history of the area
• Affects Cornwall, 3 Mohawk Nations, and
communities in New York State
• already affected by dioxins, furans and
PCBs from two aluminum smelters,
Reynolds and Alcoa, across the river at
Massena, NY, documented in annual TRI
• IJC identified Cornwall-Massena area of St.
Lawrence River as one of 42 “Areas of
26
Concern”
8. Need to know existing body
burdens of PCB’s & dioxins
• In order to assess impacts on health
• currently there is a lack of such data
• current burdens from other sources may
already have contributed to various illnesses
• local residents should therefore not be
subjected to further burdens of toxic
contaminants
27
Health Risk Assessment
4 components
• Stack pollutant emission measurement
• dispersion models, to calculate max annual
ground level concentrations of same
• estimate of human exposure by various
Pathways including air inhalation and food
ingestion
• compare calculated exposure dose to
regulatory standards
28
Cornwall public health unit
• Dr. Bourdeau, Medical Officer of Health
• espoused the standard view of the Ontario
public health community that cancer and
non-cancer illness are due to lifestyle
factors (smoking, lack of exercise, diet) and
have little to do with toxic chemical
pollutants in the environment……..
29
Medical Officer of Health
• quoted 1996 Harvard Report on Cancer
Prevention to explain cancers:
• 30% from smoking, 30% from obesity and
fat and lack of exercise,
• and 2% from environmental sources.
• (he also noted lower male:female birth ratio
in Cornwall)
30
Dr. Richard Clapp,
Boston Univ School of Public Health
• The Harvard Report “was another in a long
series of reports emphasizing the role of
personal lifestyle choices in creating risk of
cancer…This view has been touted by
industry groups seeking to reduce federal
and state regulation of carcinogens in the
workplace and the general environment.”
•
Int’l J of Health Services, 28:4
31
And the MoH….
• ...Had not read any of the reports prepared
by the Mohawk Nations concerning the
impacts of PCBs and other contaminants on
the Mohawk people
• ...claimed that the high admission rate of
children with asthma to hospital in the
Cornwall area was related to cigaret
smoking in the family home but had no
local data to support this conclusion
32
Eastern Ontario (Cornwall)
public health unit
• Ontario public health (HPPA) legislation
mandates a report on local hazardous waste
sites and environmental risks every 5 years,
with annual updates
• State of Environment Report from the
Eastern Ontario Health Unit, May 1994
• no report or update since
•
Dr. Doshi, epidemiologist, EOHU, August 31,1999
33
9.Health risk assessments
underestimate risks to residents
• As done by proponent and regulator (MoE)
• Drs. Willes (proponent), Birmingham
(MoE): assumptions not conservative;
PCB’s not included in dioxin TEQ measure
• role of dioxin as potential Hormone
Disruptor not considered at all in RA
• no current data on dioxin levels in breast
milk of local residents provided or
34
considered
• RA only considers effect on individuals at
point of maximum exposure, but > 1/2 of
emissions are spread beyond this point
• I.E. effect of long distance transport beyond
point of maximum impact and cumulative
effect that this together with other similar
facilities could have on the Ontario food
chain was not considered
35
• Willes: female child is most sensitive
“target” to be considered in doing RA
• Connett: female child one generation
removed would be more representative,
having received exposure in utero as a fetus,
then received breast milk from a mother
who has accumulated a body burden over
20 years, in addition to the child’s
subsequent exposure during growth
36
Synergism and cancer
• Exposure to dioxins could be synergistic
with cigaret smoking:
• cigaret smoke is an “initiator” of cancer
• dioxin is a “promoter” of cancer
37
10. Maximally exposed
individuals could exceed new
WHO TDI for Dioxin
• based on new WHO standard of 2.5 - 4
pg/kg/day body weight for dioxin intake,
(revised in 1998 from 10 pg), the Ontario
standard will likely also be adjusted
downward sometime during the course of
the 20 yr operating life of the incinerator
38
11. Other preexisting sources of
exposure in the community
• Pcb’s, dioxins and furans already
contaminate the community from multiple
other sources
• one new source (e.g the proposed facility)
may push individuals over the threshold of
Tolerable Daily Intake
39
12. One year delay
• If the permit is granted, a one year delay
should be stipulated to allow for the
collection of additional data so that the
project can be put on a more scientifically
rigorous footing
40
Letter to Dr. Bourdeau
from A. Goddard-Hill, M.D, Sept 20, 1999
• “Recently I received a copy of E and P Connett’s
submission to the public hearings on the matter of the
MRR facility.I have summarized these and put them on my
website.As you are quoted in their submission I would be
grateful if you would review my precis and make any
suggestions or corrections that you have.”
• (No reply was received)
41
Globe and Mail
October 18, 1999, Martin Mittelstaedt
“Proposal Calls for bargain basement
PCB furnace”
42
“Small company says it has passed all the
tests, but critics worry about proliferation of
hazardous waste incinerators”
• MRR SRBP Inc proposal: to use $3.5
million scrap metal furnace as hazardous
waste incinerator to burn PCB’s at 600
times current regulatory limit
43
• “Usually people say small is better”,
Damian Rodriguez, president, MRR...
“We are not trying to lower regulatory
standards, we are setting new standards”
• these small furnaces are not used in U.S. for
pcb destruction according to U.S.
manufacturer, United Group, Topeka,
Kansas (handle anything up to 499 ppm)
Ross Ragland, United’s retired chief engineer)44
PCB incineration
• Perhaps 6 incinerators in North America
licensed to handle high level pcb’s (which is
US is defined as > 500 ppm)
• Bovar ( Swan Hills, Alta) unit cost $400
million to build
• Ontario gov’t spent $80 million in
unsuccessful 10 yr attempt to build a site to
handle pcb waste
45
MMR Cornwall pcb burning
• currently licensed to burn up to 50 ppm
• last year’s permit stipulates removal and
proper disposal of higher concentrations
prior to burn
• current proposal: raise limit to 30,000 ppm
to allow burning of electrical light
equipment heavily contaminated with pcb’s
without costly stop of removing
46
contaminant for destruction elsewhere
MRR
corporate structure
•
•
•
•
Damian Rodriguez, President
Jan Strmen, Vice president
9 shareholders
other owners: 3 doctors, a lawyer and
several small businessmen
• Quebec based company
47
Response of hazardous waste
industry to proposal
• Martin Hassenbach, PCB Containment
Technology (a company which collects
pcb’s for destruction elsewhere):
• “We have some concerns that the ministry
seems to be relaxing the standards under
which the industry operates. If this is
approved, standards of getting rid of PCBs
would be lowered.”
48
Globe and Mail
Nov 4, 1999, Martin Mittelstaedt
“PCB Disposal plan in Cornwall
approved despite objections”
49
Ontario Environmental
Assessment Board decision
• MMR SRBP proposal approved, Nov 1, 99
• Board Chairman, Pauline Browes: “I was
moved by the fact that many residents,
including many community leaders,
expressed their objection to the proposed
additional wastes, particularly PCBs, being
incinerated.”
50
Reason for approval
• “There is no evidence that the facility will
worsen the health of people living in the
Eastern Ontario city.”
• approval conditional on further tests, this
time overseen by MoE, to show that the
furnace can achieve high rates of pcb
destruction before allowing commercial
operation
51
Other requirements of conditional
approval by Browes
• 5 yr review of fugitive pcb emissions
• monitoring of contaminant levels in
vegetation near the plant
52
Appeal of EAB decision
under section 34(1) b,
Environmental Protection Act
Paul and Ellen Connett
Nov 30, 1999
53
Problems with Judge Browes
decision
• “If the destruction of PCB’s were this
simple it would have been done this way
years ago.” P. Connett, appeal submission
54
Grounds for Connetts’ appeal:
they claim that Judge Browes :
1. Made serious factual errors
2. Made arbitrary undefended
judgements
3. Ignored key arguments
4. Selectively deferred to authority
55
1. Factual errors
• 1. Mistook pcb/dioxins exposure rates for
exposure ratios
• 2. Assumed that Ontario dioxin TDI
standard will remain at 10 pg/kg/day when
it probably will be decreased to 1 - 4 pg to
conform to the 1998 WHO standard
56
2. Arbitrary and undefended
judgments
• 3. “I am satisfied that the calculations of the
three test burns be averaged” (rather than
using the 95% upper confidence level, as
Dr. Connett had argued)
• 4. “Dr. Connett questioned variances of
emissions that could occur during start-up,
shut down and upset conditions. I
considered these elements and believe that
those circumstances can be controlled.” 57
3. Ignoring key arguments
• 5. Accepted absolute measure of dioxin
esposure increments rather than putting
them in the relative context of levels to
which local residents are already exposed,
combining which put residents over the
current Ontario standards of tolerable
exposure
58
Did not wait
for MoE study results
• 6. Ignored the recommendations to await
the results of dioxin and furan testing being
done by MoE (Phytotoxicology and soil standards
section, George Crawford) on various media
surrounding the MRR site to understand the
background environmental burden
• (counties surrounding MRR incinerator
rank as some of the highest producing dairy
counties in Ontario)
59
Mother’s milk
• 7. Ignored recommendation to do studies of
background dioxin levels in human breast
milk prior to approval
• (At last measure in 1992, Canadian human
breast milk contained 25 times the current
Tolerable daily intake standard for a 6
month old infant)
60
Burning pharmaceuticals
• 8. Ignored absence of information on
potential problems posed by burning waste
drugs
• (MoE witnesses could not cite ONE
published paper on the expected emissions
or fate of these emissions.Neither was any
risk assessment on this aspect done
• (top 4 categories of chemicals causing
61
cancer include pharmaceuticals)
Other waste streams that EAB
has permitted MRR to incinerate
• Oil contaminated containers and debris and
electrical equipment
• compressed gases and cylinders
• 9. Ignored absence of risk assessment on
this aspect, in particular the absence of any
information about the amount of PVC
plastic in these sources
62
Long range transport beyond
point of maximum impingement
• 10. Ignored the absence of information
about the bulk of dioxin emissions, well
over half, that go beyond the maximum
point of impact, adding to the cumulative
load of dioxins in the Ontario food chain via
long distance transport.
• (health risk assessment looked only at
impact of dioxins on the maximally exposed
individual)
63
PCB congeners
• 11. ignored absence of information about
PCB congeners in test burns
• (PCB ambient air concentrations are
predicted at 26,000 times higher than
predicted dioxins/furan concentrations, yet
the Certificate of Approval for DRE test
burns does not require congener specific
profiles of PCB’s)
64
Asthma
• 12. Ignored key information about asthma,
which has an excessively high incidence in
the area. However, significance of the
MRR’s test burns having failed MoE’s
particulate standard 9 out of 9 times was
not ascertained.
• (Dr. Bourdeau attributed higher local
incidence of asthma to smoking despite
having no supportive evidence to present) 65
4. Selectively deferred to the
authority of 3 out of 4 experts:
• Dr. Birmingham, MoE regulator, had signed
off on calculations on dioxin exposures
made by Dr. Willes. These subsequently
were proven to be incorrect by Dr. Connett
• Dr. Willes, consultant paid by the proponent
• Dr. Bourdeau, MoH public health expert
• Dr. Paul Connett, dioxin chemist for the
dissenting side, whose arguments often
66
went unanswered
Support for the Connett appeal
of EAB decision
A. Goddard-Hill, M.D
December 5, 1999
(see letter to Lieutenant Governor
elsewhere on web site)
67
»
December 5, l999
• The Lieutenant Governor in Council
• Re: Appeal of the Browes Decision of the Environmental Assessment
Board, case number 98-123, pertaining to Material Resource Recovery
SRBP Inc, November 1, 1999, Paul and Ellen Connett
• Dear Lieutenant Governor,
• Please accept this letter in support of the Appeal being made to you
under the Environmental Protection Act, section 34(1)b by Paul and
Ellen Connett in their submission to you of November 30, l999.
•
……..next page
68
• The reasons for my support are as follows:
• 1. The content of the Connett appeal is substantial and significant.
• 2. One reason given for the acceptance of the proposal is that “there
no evidence that the facility will worsen the health of people living in
Eastern Ontario.” I believe that in the general case of incinerator
emissions there is substantial evidence in the medical literature that
these may have a negative impact on human health. For full detail
please refer to the relevant content of my website, (best accessed with
Microsoft Explorer).
•
……next page
•
69
• 3. In the specific case of Cornwall, I wrote a letter to Dr. Bourdeau, the
local Medical Officer of Health, to ask for his response to the
Connett’s claims about local human health effects. He did not reply.
This is somewhat surprising as under the Health Protection and
Promotion Act I believe that he has an obligation to answer the
concerns of citizens in projects of this type. It therefore seems that the
process of public participation has not been completed. (Please refer
to the specific Powerpoint presentation on my website which
summarizes the Cornwall issue and includes my letter to Dr.
Bourdeau.)
•
…...next page
70
• 4. The assessment of the potential impact of MRR incinerator
emissions on the surrounding agricultural lands has not been
completed, and does not meet, for example, the standard of the
European Union. For instance at a meeting of agricultural ministers of
the EU in Brussels in September 1999 David Byrne, commissioner for
food safety in Belgium has called for systematic monitoring of beef
and fish for dioxin and pcb’s. Byrne said there was obviously a
problem associated with rearing animals close to some industrial
facilities, and in particular near waste disposal incinerators. Byrne
was referring to a new Belgian report that found pcb and dioxin
residues in 10 of 1000 cattle tested after recent food contamination
problems in Belgium. (The Lancet, October 9, 1999)
• Thankyou for your consideration.
• Sincerely yours, A. C.Goddard-Hill
71
Letter of Acknowledgment
December 20, 1999
to Dr. Goddard-Hill
from Suzanne Wilson,
Manager, Executive Council Support
Ontario Cabinet
72
• “I note your support for the Appeal of this
decision by Pault and Ellen Connett.”
•
Suzanne Wilson
73
Response to the Ontario MoE,
MRR reply submissions
to the Connett petition
Paul and Ellen Connett
February 17, 2000
submitted to the Ontario Cabinet
74
• Facility adds to background exposure of
community to dioxins, pcb’s to the extent
that community will be exposed to more
than safe limit of dioxin exposure using
WHO and province of Ontario standard
• alternative “closed loop” treatment systems
are available which render this technology
unnecessary
75
The penny drops:
MoE says
• “The Canadian background exposure for
dioxins and furans (I.e. amount that
Canadians are already exposed to on a daily
basis) ranges between 2 - 3 pg TEQ/kg/day.
Given that the WHO TDI of l pg TEQ/kg/d
is less than one half the current Canadian
estimated background exposure to dioxins
from all sources, it is unlikely that any
facility could meet this expectation.”
76
MoE data not made available
• For some reason despite repeated requests,
the Connett’s could not obtain data
published by the MoE on background
readings of dioxins and furans (as
determined by MoE analysis) in the
Cornwall readings
• their response to the reply to the Appeal is
therefore considered to remain incomplete
77
Pharmaceuticals, PVC’s in the
waste stream
• No health risk assessment done on
incineration of these materials
• PVC’s, found in discarded electrical
equipment which is to be included in the
waste stream for incineration, are notorious
for producing dioxins when incinerated
• neither was data on the amount of PVC’s to
be incinerated available
78
Dairy country
• The bulk of dioxin emissions from the
facility, well over half, go beyond the point
of maximum impact (impingement), and
thus may enter the Ontario food chain
through local milk production
• counties surrounding Cornwall rank number
5, 7, 12, 13 and 15 in milk production in the
Province of Ontario
79
PCB congeners
not identified in the Risk Assessment
• About a dozen PCB’s have dioxin-like
toxicity
• It is necessary to know what PCB congeners
are in the emissions (not in the waste itself)
so they can be included in the final dose
calculation
• this data is not available
80
Asthma
• MoH confirmed higher rates of asthma in
the community compared to provincial
average
• he attributed this to smoking habits in the
population but no data was made available
to support this hypothesis
• MRR test burns failed Ontario particulate
standards for air quality 9 of 9 times
81
Dr. Birmingham
MoE consultant at the hearings
• Review of his credentials and research work
is given
• has participated in other such hearing in the
province: e.g.Norampac Trenton, & generic
landfill site study for Province of Ontario,
1999, (which came up with the following
interesting finding: see next slide)
82
(Cancer risks from landfill chemicals:
from 1999 MoE landfill study)
• The combined total cancer risk to the Hawk
was 4:1000, (which is below the level of
concern set at 1:100)
• from Human Health risk Assessment: the
combined cancer risk from landfill
emissions is 1:250,000 to
1:100,000;drinking water contaminated
with landfill chemicals (e.g. vinyl chloride)
posed risks of 1:1 billion to 1:1,000,000 83
Abridged Health Profile,
City of Cornwall, submitted to the
hearings by EOHU, July 99
• For the years 1991 - 1995, the “major
causes of death” were significantly higher
than Province of Ontario averages for:
• males: ischemic heart disease, lung cancer,
chronic obstructive lung disease, mva’s and
suicides
• females: for ischemic heart disease, lung
cancer and chronic obstructive lung disease.
84
Second Letter of support
for Connett appeal
A. Goddard-Hill, M.D.
March 12, 2000
85
Letter….
March 12, 2000
•
•
Re: MRR SRBP Inc, Case Number 98-123
Your file: P2/99
•
•
Dear Ms. Wilson,
Thank you very much for your reply of December 20, 1999 acknowledging
my letter of support for the Connett appeal of Judge Browes’ decision
regarding the CoA application by MRR SRBP.
I now have read the Connett’s reply to the MoE/MRR response to their
original petition, which is dated February 17, 2000.
It is clear from this document that the concerns raised by the Connetts in their
original appeal have gone largely unanswered by the MoE, MoH and MRR.
The appellants’ central point in essence is that emissions from the facility will
add significantly to the existing burden of pollution already borne by the
community, thus posing additional risk to human health.
•
•
86
•
•
•
•
•
They further note that safer alternative technologies are available for the
disposal of PCB waste.
It is therefore very doubtful that facilities of this type should continue to
operate.
The International Joint Commission has designated the Cornwall area as an
industrially polluted “area of concern”, one of a number in the Great Lakes
Basin. Another of these is the Bay of Quinte area and there are at least a dozen
more on the Canadian side of the Great Lakes.
Within the last year the Canadian federal government (Health Canada) has
identified higher rates of human disease and death in these polluted areas of
concern as compared with provincial average rates.
Furthermore the provincial and municipal governments (public health
departments) have recently confirmed these epidemiologic trends in both the
Cornwall and Bay of Quinte areas.
87
•
•
•
Therefore inviting industry to add to the existing burden of industrial
pollution in these communities is not sensible. The approval of the continued
operation of this particular facility will set an important precedent for the
Province of Ontario.
In our region of the Bay of Quinte there are now proposals on the table for a
hazardous waste incinerator in Trenton, and as well for municipal waste
incinerators in Peterboro, Northumberland and possibly near Napanee as an
alternative to the proposed expansion of the Richmond Township provincial
landfill. (In addition the MoE has recently acknowledged that medical waste
incinerators continue to operate in our and other communities in the province
with virtually no regulation or pollution control whatsoever.) All of these will
have an impact on the Bay of Quinte watershed if constructed, a watershed
which is already highly polluted.
This is a very serious matter. We can be grateful to the Connetts for advancing
the debate on this issue. I remain in full support of their Appeal.
88
•
•
I would like to talk to you about how the Ontario Cabinet intends to proceed
on this issue. Please call me at my office.
I would also be grateful if you could send me a copy of the MoE
measurements of the levels of background dioxin/furan levels as completed by
Mr. George Crawford.
•
Best wishes.
•
•
Sincerely yours,
A. C. Goddard-Hill
89