Ques­tions for West Coast Olefins

The Prince George Citizen - - Opinion -

Ed­i­tor’s note: The fol­low­ing let­ter was sent to The Ci­ti­zen from the Too Close 2 Home group. Ken James of West Coast Olefins has been in­vited to take share his re­sponse with Ci­ti­zen read­ers in this space.

Dear Mr. Ken James,

As you may be aware, we have cre­ated a Face­book-based com­mu­nity group called Too Close 2 Home for Prince Ge­orge cit­i­zens to talk about the pro­posed plas­tic plant site. Our page is a pub­lic fo­rum for con­ver­sa­tion on top­ics re­lated to the West Coast Olefins pro­posed fa­cil­ity in Prince Ge­orge.

As we un­der­stand it, West Coast Olefin’s pro­posal is for an ethy­lene ex­trac­tion petro­chem­i­cal plant with po­ten­tial for up to three ad­di­tional plas­tic plants at 10012 Wil­low Cale Road, within the Prince Ge­orge air­shed.

Our mem­ber­ship is di­verse and in­cludes com­mu­nity lead­ers, sci­en­tists, med­i­cal doc­tors, en­gi­neers and ex­perts in pub­lic con­sul­ta­tion and par­tic­i­pa­tory plan­ning. We are all ea­ger to ob­tain and care­fully con­sider in­for­ma­tion about the pro­posal from West Coast Olefins.

Us­ing so­cial me­dia, we have in­vited the pub­lic to share ques­tions and con­cerns about your pro­posed fa­cil­ity. We have been both com­pil­ing and ex­plor­ing ques­tions, re­search pa­pers and re­lated stud­ies shared by our mem­bers since mid-Au­gust.

As a ser­vice to our mem­bers, we have com­mit­ted to en­gag­ing with you di­rectly, to en­deav­our yo find an­swers to their col­lec­tive ques­tions. Th­ese are ques­tions that mem­bers feel must be ad­dressed in order for them to be prop­erly con­sulted about the plant and its as­so­ci­ated im­pacts, and to care­fully con­sider what is be­ing pro­posed.

As it cur­rently stands, many mem­bers are con­cerned about the lack of in­for­ma­tion be­ing shared by West Coast Olefins, in ad­di­tion to any con­cerns that they have about the plant and the pro­posed site.

Please find the list of com­piled ques­tions be­low. We re­spect­fully re­quest that you pro­vide a de­tailed re­sponse to th­ese ques­tions by Sept. 18. We plan to hold a pub­lic fo­rum shortly af­ter that date and would like to be able to share in­for­ma­tion from your com­pany, to ad­dress mem­ber con­cerns and ques­tions.

If you are un­able to re­spond by Sept. 18, we will share this with our mem­bers as well. Su­sanne We­ber, Zoe Meletis, Marie Hay

Prince Ge­orge Ques­tions for West Coast Olefins Ltd. Sub­mit­ted by Too Close 2 Home:

Re­fin­ing/man­u­fac­tur­ing

1. Which main chem­i­cals will be used in the pro­posed re­fin­ing/man­u­fac­tur­ing process?

2. How will th­ese chem­i­cals be trans­ported to the site?

3. What type of on­site stor­age fa­cil­i­ties will be used and what safe­guards are as­so­ci­ated with such stor­age fa­cil­i­ties?

4. What pre­cau­tions will be in place to pro­tect the chem­i­cals and pro­cesses as­so­ci­ated with the plant from con­tam­i­nat­ing the land, rivers, and ground­wa­ter?

5. How will solid/liq­uid waste prod­ucts be han­dled? What per­cent­age of th­ese is ex­pected to stay in the lo­cal area?

6. Will the plant’s tail­ing ponds be com­pletely cov­ered over, and will this pre­vent as­so­ci­ated toxic fugi­tive air emissions?

7. How high will the plant’s flare stacks be, and how much of the time will flar­ing take place? Which times of day and week will flar­ing be con­ducted (times; fre­quency)? How long are the ses­sions ex­pected to last?

8. When flar­ing does take place with ei­ther planned or un­planned shut downs of the plants, how much of an ad­di­tional air emission load is to be an­tic­i­pated dur­ing such times?

9. What is the an­tic­i­pated pro­duc­tion ca­pac­ity of the eth­ane ex­trac­tion plant, and which prod­ucts and mar­kets will it most closely be af­fil­i­ated with? Is the plant’s max­i­mum ca­pac­ity one mega tonne?

10. West Coast Olefins Ltd. has pub­licly sug­gested that up to three plas­tic plants can be ac­com­mo­dated on the 300-acre site to uti­lize the ethy­lene pro­duced by the eth­ane plant. What are the ex­pected emissions into the PG air­shed in terms of ex­pected in­creases in truck, rail and car traf­fic with all the pro­posed fa­cil­i­ties at the pro­posed site lo­ca­tion in Wil­low Cale, through all phases in­clud­ing con­struc­tion through to on­go­ing op­er­a­tion? What im­pacts are you an­tic­i­pat­ing with in­creased road and rail traf­fic, and what mea­sures will you take to mit­i­gate those po­ten­tial im­pacts?

11. If the main prod­uct is plas­tic pel­lets and the ma­jor­ity of those will be shipped to Asia, how many rail cars are go­ing to be needed to trans­port the pel­lets to Asia through Prince Ru­pert? Will this put an ad­di­tional strain on rail, rail com­pa­nies, and/ or com­mu­ni­ties with rail lines? If so, how will the com­pany work to mit­i­gate as­so­ci­ated neg­a­tive im­pacts?

12. How much ex­tra rail line is go­ing to have to be built by CN in order to con­nect with and serve your site?

13. As the cur­rent CN rail ca­pac­ity to Prince Ru­pert is al­ready at max­i­mum ca­pac­ity, will CN be build­ing more rail­ways to Prince Ru­pert to ac­com­mo­date the ex­tra rail car traf­fic?

14. Will this in­crease in rail traf­fic bring west­erly pas­sen­ger rail traf­fic t to a halt? Can you pro­vide ev­i­dence to re­as­sure com­mu­nity mem­bers that rail ca­pac­ity can be aug­mented with­out in­creased con­flict or risk?

15. It is our un­der­stand­ing that the Port of Prince Ru­pert is also cur­rently op­er­at­ing at max­i­mum ca­pac­ity. Is the port ca­pa­ble and pre­pared to ac­com­mo­date and ser­vice all the ex­tra tanker traf­fic, un­load­ing, stor­age, and load­ing of one mega tonne of ethy­lene prod­uct?

16. How will you mit­i­gate fugi­tive plas­tic pel­let and dust losses around Prince Ru­pert and the har­bour area, bear­ing in mind the wel­fare of the ma­rine an­i­mals that live there?

Process

1. Will this pro­posed plant be built with flex­i­ble process pro­duc­tion lines? What con­sid­er­a­tions have been given to plan­ning up­grades to more en­vi­ron­men­tally sus­tain­able pro­duc­tion meth­ods and process?

2. Where ex­actly will the raw sup­ply for the ethy­lene pro­duc­tion come from and how is it go­ing to be trans­ported to the new fa­cil­ity? Many res­i­dents have ex­pressed con­cerns that your fa­cil­ity will re­quire an­other pipe­line to be built to sup­ply it with the raw ma­te­ri­als. Due to the re­cent pipe­line ex­plo­sion last fall near Shel­ley, BC and sub­se­quent vol­un­tary (and manda­tory) re­duc­tion in use of nat­u­ral gas through­out the prov­ince, most British Columbians are now aware that the Enbridge pipe­line is still only per­mit­ted to run at 85 per cent of its ca­pac­ity and is re­spon­si­ble to sup­ply­ing much of the cen­tral and south­ern in­te­rior’s nat­u­ral gas for both com­mer­cial and res­i­den­tial cus­tomers. How do you plan to ad­dress th­ese con­cerns?

Air & Wa­ter Qual­ity

1. Please pro­vide quan­ti­ta­tive es­ti­mates of ex­pected VOCs, es­pe­cially Ben­zene,1,2Bu­ta­di­ene, and formalde­hyde, as well as the ton­nage per an­num of fine par­ti­cle emissions dur­ing all phases of the pro­posed devel­op­ment and its on­go­ing op­er­a­tion.

2. Do you have wind maps to sug­gest where the emissions from this fa­cil­ity will travel- how far, how fre­quently, and how long can we ex­pect to ex­pe­ri­ence emissions in each area of the city? What de­gree of ac­cu­racy is as­so­ci­ated with th­ese maps? Which ar­eas will be most af­fected and how will you mit­i­gate th­ese ef­fects?

3. Please pro­vide planned pro­ce­dures and tech­nolo­gies that will be used to ad­dress the VOC emissions men­tioned.

4. Please in­clude the es­ti­mated car­bon emissions from trans­port­ing prod­uct and wastes to and from the site, stor­age, de­liv­ery, etc.

5. How many mil­lions of plas­tic pel­lets and how much plas­tic dust will be lost into the en­vi­ron­ment per an­num, both as in­evitable and ac­ci­den­tal fugi­tive plas­tic losses dur­ing all phases of pro­duc­tion, stor­age, trans­port and de­liv­ery. What ef­forts will be taken to re­duce such losses?

6. How will you mit­i­gate emissions, spills, or chem­i­cal ex­plo­sions at your fa­cil­ity? What risks ex­ist for ad­ja­cent fa­cil­i­ties, Hag­gith Creek, and the Fraser River should a spill, ex­plo­sion, or fire oc­cur at your fa­cil­ity? What strate­gies will you have in place to en­sure fur­ther con­tam­i­na­tion does not oc­cur fol­low­ing a fire? What is your re­sponse strat­egy to min­i­mize im­pacts while en­sur­ing worker safety?

7. How will you pro­tect the salmon and stur­geon liv­ing in the Fraser River, from both ac­ci­den­tal and in­evitable plas­tics losses into the river?

8. What emissions stan­dards are cur­rently in place for the newest fa­cil­i­ties in the world, and ex­actly how do you plan to meet or ex­ceed th­ese?

9. How do th­ese con­tem­po­rary plant emission stan­dards (see pre­vi­ous ques­tion) com­pare to what you in­tend to build in the bowl of Prince Ge­orge on Wil­low Cale Road? How does the pro­posed plant for Prince Ge­orge com­pare with the Joffre plant in Red Deer (that you have pub­licly ref­er­enced)?

10. Would the chief op­er­at­ing of­fi­cers of this com­pany want this fa­cil­ity in their back­yard? In their chil­dren’s air­shed?

Site Se­lec­tion

1. Why have you cho­sen this site for your pro­posed fa­cil­ity? How did this site win out over al­ter­na­tive sites?

2. What me­te­o­ro­log­i­cal data did you use in de­ter­min­ing the best site for your petro­chem­i­cal plant?

3. How did prox­im­ity to res­i­den­tial neigh­bour­hoods and schools, as well as the ALR des­ig­na­tion for the land upon which the site is pro­posed, fac­tor into your site se­lec­tion?

4. How does this kind of project fit in with the global need to re­duce the pro­lif­er­a­tion of plas­tics?

5. Both Sarnia, On­tario and the Louisiana Gulf Coast which have big petro­chem­i­cal eth­ane crack­ing plants are re­ferred to as “Can­cer Al­leys”. What con­vinc­ing ev­i­dence can you of­fer that in 10-15 years Prince Ge­orge will not also be re­ferred to as “Can­cer Al­ley “?

Hu­man Health

1. How do you plan to re­spond to well doc­u­mented long-term hu­man health im­pacts and con­cerns as­so­ci­ated with sim­i­lar ex­ist­ing fa­cil­i­ties else­where in the world?

2. Can you pro­vide ev­i­dence that your pro­posed fa­cil­ity will not cause long-term neg­a­tive hu­man health, en­vi­ron­men­tal, and air qual­ity im­pacts both on site and in the greater com­mu­nity?

3. How will you pro­tect work­ers in your fa­cil­ity from exposure to toxic heavy me­tals like lead and mercury, arsenic and cad­mium? How will you seek to pre­vent worker nanopar­ti­cle dust in­ges­tion/in­te­gra­tion, exposure to toxic chem­i­cals and gas emissions?

4. How do you plan to mon­i­tor lev­els of exposure for your work­ers re­gard­ing in­hala­tion of nanopar­ti­cles, chem­i­cals, and gas emissions? If exposure, acute, and/or long term health im­pacts are re­ported, how will you work to ad­dress th­ese in terms of re­duc­ing harm to work­ers and im­prov­ing the health and safety of the plant?

5. The City of Prince Ge­orge is a sig­na­tory to the Blue Dot cam­paign (09-14-2015). As a Blue Dot com­mu­nity, our City Coun­cil has com­mit­ted to pro­tect­ing res­i­dents’ rights to a clean en­vi­ron­ment. This in­cludes the right to breathe healthy air. What data can you sup­ply res­i­dents to as­sure them that the pro­posed plant will not compromise this?

En­vi­ron­men­tal As­sess­ment & Com­mu­nity En­gage­ment

1. Do you have dead­line dates for the Provin­cial En­vi­ron­men­tal As­sess­ment Process and can you share those with our group?

2. Will the pro­posed plant be sub­ject to reg­u­la­tion un­der the Oil and Gas Ac­tiv­i­ties Act as amended by Bill 23- 2015 ?

3. Please pro­vide dates, times, and lo­ca­tions for the next pub­lic in­for­ma­tion ses­sion/s you will be of­fer­ing in our com­mu­nity.

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