Comment ID: 194991 COMMENTS…

Comment ID: 194991

COMMENTS FROM ACTION CHAMPLAIN – EBR # 012-8124 29 August 2016. Colacem Canada Inc. wants to build a cement plant in a rural area, in very close vicinity of agricultural and residential zones in L’Orignal, Ontario. The proposed cement site would be located on a rural zoned land with a temporary permit for agricultural use of 55.85 hectares (138 acres) north of the County Road 17 and less than two Kms from the Ottawa River. The proposed site for the cement plant does not allow a heavy industry as per the current Champlain Township Zoning By-Law and the United Counties of Prescott Russel (UCPR) Official Plan. The proposed site would be adjacent to an existing quarry owned and operated by Colacem. The cement plant would operate 24/7, 365 days per year with an increase of the quarry activities to supply the limestone to the cement plant. From the company’s publicly available documents, it is said that the raw materials required for the cement plan would be obtained as follows: • Limestone would be sourced from the adjacent quarry and trucked or conveyed to the plant. • Silica sand and shale would be taken from quarries within approximately 100 Kms and transported by truck via CR 17 to the site. • Iron mill scale could be sourced and transported by truck via CR 17 from the Ivaco Rolling Mills steel based in L’Orignal. • Silica fume and fly ash would be transported by truck via CR 17 to the site. • Bauxite and gypsum would be imported and transported via ship to the Ports of Montreal, Contrecoeur or Valleyfield all located in Québec, and then trucked to the site. • Petcoke would be used to fuel the plant. Petcoke is a solid carbon product that is produced in the oil refining process and commonly used for industrial applications. The petcoke would be imported via ship to either the Port of Contrecoeur or Valleyfield and transported in heavy trucks via CR 17 to the cement site. Petcoke would be stored outdoors on a contained concrete pad. • It is known and well documented that transport is a huge contributor of CO2 emissions or greenhouse gases. The proposed projet would require 80-110 from heavy trucks per hour or 1,900 to 2,640 heavy trucks per day on the Country Road # 17 in the two directions between the site to the various locations as explained above. The raw material would be burned at approximately 1,450°C in a massive rotating kiln, at which point limestone breaks down into its constituent components of lime and carbon dioxide. Colacem would burn petcoke instead of coal, to generate the extreme heat necessary to produce cement powder, creating a much larger amount of greenhouse gases. The lime goes on to form cement powder; the carbon dioxide—38 per cent of limestone by weight—goes up the stack. Burning petcoke (a petroleum by-product) to generate the extreme heat necessary for this chemical reaction would create a huge amount of greenhouse gases. In fact, for every tonne of cement produced, more than three-quarters of a tonne of carbon is released into the atmosphere. The cement plant would have the capacity to produce 4,000 tons of cement powder per day, with an estimated annual production of 1.16 Million tons of cement. This means that 3,000 tons of carbon would be released in the atmosphere per day or 1.09 Million tons per year. It is important to note that the cement industry accounts for more than eight per cent of global carbon emissions and, according to the Environmental Protection Agency (EPA) in the U.S.A., is the third largest source of industrial pollution. Residents living in the 100 kilometers vicinity of the proposed site: UPCR in east Ontario, Argenteuil and Vaudreuil-Soulanges counties in Québec, is estimated at 268,000 inhabitants. Most of them are very concerned about the consequences of having a cement plant located in their living areas. Issues such as air pollution, environmental, water and land degradation, agriculture degradation, nuisances, potential impacts on health, tourism and overall social and economic development are among their concerns. An important matter of significant importance is the loss of property value of residents living in10 kilometers vicinity that could be up to 25% according to the Ontario Municipal Property Assessment Corporation. Another important point is the incidence of cancers caused by environmental carcinogens that could be quite significant compared to other known risk factors for cancer. For the residents of Champlain Township and surrounding areas in East Ontario and in Quebec (Argenteuil and Vaudreuil-Soulanges counties) the cement plant would have a huge negative impact on the air, the soil and the water of the Ottawa and St-Laurence Rivers. These would be caused by dust emissions (less than 10 microns), contaminants and fine particles coming from all sources at the facility, including raw material transport to the sit, raw material storage, raw material preparation, clinker production, cement grinding, cement distribution with heavy trucks to the Port of Montreal (the cement would be for exportation). The gas emission of CO2 produced by the intense circulation of heavy trucks along County Road # 17 needs to be included in this assessment. According to the US Environment Protection Agency (EPA), the cement industry is the third highest polluter in North America. A cement plant could have major impacts on the environment and health of people living in hundred of kilometers around. In the province of Quebec, a new cement plant is being built in a remote area, Port-Daniel, right on the Atlantic sea front. They will be implementing the most advanced production technology; transportation of raw materials and finished products will be using ships. But even then, it was said in 2014 to be the most pollutant project in Quebec history. This cement plant would be the third heavy industry within a 5 kilometers radius, IVACO Steel Mill and the L’Orignal Quarry, owned by Colacem. The approving authorities need to consider the cumulative effects of the cement plant and those of the other industries in the vicinity. Residents of both the rural area and the village of L’Orignal, as far as 5 km away, can hear noises and smell odours from IVACO, day and/or night. In this beautiful countryside setting, you cannot keep your windows opened in the summer time. The EPA says that cement plants could be responsible “of visual impairments, respiratory cardiovascular diseases, damage to lung tissues and adverse effects on central nervous system, children and elderly more strongly affected”. A very recent study conducted in Spain concluded in 2015 that “…excess cancer mortality was detected in the vicinity of these installations (heavy industries) as a whole and principally in the vicinity of cement installations”. The residents of L’Orignal are very concerned by the compliance on all conditions and monitoring practices. Who will ensure the monitoring of all outputs of this cement plant? Who will ensure the good environment and health protection of the population? Canada ranks at the last position of the OECD countries, which means the norms and emissions limits are very low. Do the government authorities know about the very toxic nature of the dust or particulate matter that would emanate from the quarry, the cement plant and heavy truck circulation? Do government authorities know that dust or particulate matters have on the health of the population and on the negative socio-economic impacts of the community under such prejudice? Here are some facts: • According to the EPA, the cement industry is the 3rd highest polluter in North America. • According to Environment Canada, mercury (Hg) can be released into the air by cement kilns. In 2013, Ontario had the highest level of mercury emissions, representing 27% of total national emissions in Canada which came mainly from the iron and steel, cement and concrete industry. Mercury can be transported through the air and settle in the water or on the ground. It can be transformed by microorganisms into methylmercury, a toxic form of mercury that is harmful to both humans and wildlife. Methylmercury is bioaccumulate in the food chain and can enter our body by ingestion of contaminated food. Mercury accumulated in the vegetation can also be rejected again in the air during a forest fire. Mercury and its compounds are included in the list of toxic substances under the Canadian Environmental Protection Act Environmental Protection (1999) (CEPA 1999). • According to the results of a study published in May 2001 by the Scientific Panel on toxicological risk assessment of the National Public Health Institute of Quebec (INSQ), toxic material from industrial sludges contained in the cement kiln dust may contain heavy metals, cadmium, arsenic and dioxins and furans. According to INSQ, hazards to human health are too high. These contaminate from 50 to 90% more than the dust, ash and other residues. • According to a recent article in the Toronto Star, “Ontario had the fourth-highest level of releases to air of carcinogens out of 60 state and provincial jurisdictions in Canada and the United States in 2012”. This shows that the people of Ontario are not adequately protected with the existing regulations and laws. • The health of a population can have very serious socio-economic impacts. We should take example of best practices in some other countries such as Germany that has amongst the most stringent emissions controls and regulations in the world. • The cement plant project proposal claims the use of “advanced” technology but would be subjected to regulations and emission guidelines that date back to 2003 and earlier. Therefore, emission limits and regulations need to be urgently updated. In addition, emissions should be monitored on a more frequent basis by the government to ensure compliance. • As per a recent study, the impacts of a cement plant having a chimney of close to 165 feet (50 meters) could affect the quality of air and agricultural soil in and around a 15 km radius. • The height of the planned cement plant chimney with its cooling tower being approximately of 410 feet (125 meters), the particulate matter being extremely light, the impact on the quality of air could easily surpass the mentioned area of 15km radius. • Colacem would burn petcoke instead of coal, to generate the extreme heat necessary to produce cement powder, creating a much larger amount of greenhouse gas. • In the province of Quebec, a new cement plant is being built in a remote area, Port-Daniel, right on the Atlantic sea front. They will be implementing the most advanced production technology; transportation of raw materials and finished products will be using ships. But even then, it was said in 2014 to be the most pollutant project in Quebec history. • Do the approving authorities consider the cumulative effects of the cement plant and those of the other industries in the vicinity? • How can cumulative effects of many industries be effectively monitored, and environmental and health protection efficiently provided, with multiple heavy industry sources, the cement plant adding its massive adverse effects to those of two other ones? • An Italian study confirmed this in 2011: “Results show an association between exposure to cement plant emissions and the risk of cardiovascular and respiratory diseases: this association is particularly strong for children”. • A very recent study conducted in Spain concluded in 2015 that ‘’...excess cancer mortality was detected in the vicinity of these installations (heavy industries) as a whole and principally in the vicinity of cement installations”. • More than 1,300 heavy trucks, 16 hours per day, from 3:00am to 7:00pm as well as occasionally 24 hours per day, would bring an increased concentration of dust, diesel trucks pollutants emissions and noise, could be a source of stress for many road users and roadside property owners, increase the risk of severe road accidents. • Who will monitor the outputs of this cement plant? Who will ensure our environment and health protection? • As per a recent study, the impacts of a cement plant having a chimney of close to 50 meters could affect the quality of air and agricultural soil in and around a 15 km radius. The cement plant in L’Orignal would be 125 metres of height. • In addition, using petcoke instead of coal to generate the extreme heat necessary to produce cement powder, would create a much larger amount of greenhouse gases. • EPA says that cement plants could be responsible “… of visual impairments, respiratory cardiovascular diseases, damage to lung tissues, adverse effects on central nervous system, children and elderly more strongly affected.” • A study conducted in Spain concluded in 2015 that “…excess cancer mortality was detected in the vicinity of these installations (heavy industries) as a whole and principally in the vicinity of cement installations”. • Particulate matter PM2.5 is the most threatening. The particulates are so fine that they could penetrate the blood vessels through the lungs and seriously affect the health of human beings. • The height of the planned cement plant chimney with its cooling tower being approximately of 125 meters, the particulate matter being extremely light, the impact on the quality of air could easily surpass the mentioned area of 15km radius. Studies from Europe show that carbon particles go intercontinental taking the jet stream path, thus polluting beyond the source region. • Agriculture is the region's main industry. A farmer in the vicinity of the targeted site grows organic produce. The announcement of a cement plant possibly being built in the region lead to the rumor that he had already lost his organic certification. • The Ontario Ministry of Agriculture’s website mentions something about the impact of a cement plant on agriculture the government authorities should know: “Particulate matter such as cement dust deposited on vegetation can inhibit the normal respiration and photosynthesis mechanisms within the leaf. Cement dust may cause chlorosis and death of leaf tissue by the combination of a thick crust and alkaline toxicity produced in wet weather. The dust coating also may affect the normal action of pesticides and other agricultural chemicals applied as sprays to foliage. In addition, accumulation of alkaline dusts in the soil can increase soil pH to levels adverse to crop growth.” • Lower productivity of agricultural fields could have a direct impact on revenues from agriculture activity. Costs and required input in areas affected by a cement plant could be higher in comparison to control areas. This proposed project, if implemented, would increase Ontario’s CO2 gas emission and would put Ontario at a point of no return regarding the management of green gas reduction. The political and economical cost of this would be enormous for Ontario.