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Thursday, July 13, 2017

Landfill's biomass incinerator application concerns some area residents

East of the Crowsnest Pass/Pincher Creek Landfill
Chris Davis - Cowley area landowners Duane and Lynne DeCock are concerned about plans by the Crowsnest Pass/Pincher Creek Landfill (CNPC) to operate a biomass incinerator, composed of two 5-tonne chambers. The landfill is approximately 2.5 miles northeast of the DeCock property, according to a letter they sent to Alberta Environment and Parks Regulatory Approvals Center on July 11, 2017.

According to  CNPCL stats, the landfill currently receives annual biomass averages of 200 - 250 tonnes of wildlife carcasses and 700 tonnes from pig and chicken farms. It currently isn't approved to handle beef carcasses, but (with the addition of a biomass incinerator to its operations) projects an average 200 to 250 tonnes per month for 3 months during calving season, and regular cattle mortality averaging another 600 tonnes per year.  CNCP recently issued a public notice stating they have applied  to Alberta Environment and Parks (AEP) "for an amendment to an existing approval to construct operate and reclaim the proposed incinerator".  AEP dictates the public consultation requirements.  Costs associated for the project will come from landfill operations, according to CNCP  A final price tag estimate isn't anticipated before next year sometime.


In September of last year CNPC hosted a series of three open houses in Blairmore, Lundbreck and Pincher Creek regarding the possibility of installing and operating a two-stage combustion biomass incinerator at the landfill site.  At that time CNPC administration said the process would likely take at least 2 years to achieve approval and start the project.  CNPC illustrated plans for a smokeless low-emission two-stage incinerator burning at 1000 degrees Celcius.  It's estimated to reduce volume and weight of material burned by over 95%.  It's capable of destroying animal prion diseases, including bovine spongiform encephalopathy (BSE or mad cow disease), scrapie that affects goats and sheep, and chronic wasting disease which affects deer, elk, and moose.  With CFIA approval, CNPC will be able to receive BSE biomass.  According to CNPC "If we don't get CFIA approval, we won't move forward."

Many area livestock producers have been asking for better ways to eliminate carcasses from the landscape to avoid attracting bears and other predators.

In their July 2017 letter to the regulatory body the DeCocks said:

 "Our first and main concern with the proposed incinerator is the particulate matter/toxins released from the incinerator. We are directly downwind of the landfill so this is an obvious concern for us. Although the models and simulations of the incinerator claimed to be below guideline for all regulated fumes, the models didn’t seem to take bioaccumulation into consideration. Just because they meet guidelines right at the stack, doesn’t say anything about how much is accumulating in our dugouts that any particulates from the incinerator could deposit into these and other bodies of water. We have cattle on our land year-round and there are many bird and amphibian species that inhabit our dugouts."

"Research has shown that air borne particles/toxins can travel distances from the source (Dr. Paul Connett, PhD in Chemistry, specializing in Environmental Chemistry and Toxicology), and we don’t feel confident that “with wind, comes dispersion” (as quoted from North Shore Environmental Consultants in the open house) is a very scientifically sound justification to incineration. We don’t see how that is different than saying “dilution is the solution” to water contamination.

"Another concern we have for the proposed incinerator is the potential future amendments of the approval to accept more than just animal carcasses, agricultural plastic and clean wood into the incinerator chambers. If there are not enough of those three to meet the mix ratios, we anticipate the landfill applying for an amendment to accept other types of waste, which will introduce more potential toxins to the environment.
"The Crowsnest Pass and Pincher Creek communities pride themselves with being environmentally conscious and we are worried that the general use of incineration discourages environmental stewardship and goes against the vision and mission of both the Crowsnest Pass and Pincher Creek communities (quoted below).

'The Vision of the Council of the MD of Pincher Creek is a community that manages growth and supports our western heritage while preserving our natural environment. Our Mission is to preserve and enhance our Western Canadian lifestyles and the natural capital of the MD of Pincher Creek through sound decision- making and good governance for the community.'

"We also don’t think the landfill has their due diligence with community involvement about this project. Apart from putting the application on their website (without letting anyone know it was up there) and handing out letters to only a handful of surrounding landowners), they have not put in any effort in getting feedback from the rest of the community.  When they did hold open houses, the overall feel from the community was resistance and it doesn’t seem the landfill has listened to its community members. Although we understand they are not legally required to do more than this, in a small community, it is important for these big decisions to have more community involvement. The landfill claims to have considered other options such as composting, but has not made their research studies available to the public.

"The landfill sent us a letter to let us know they applied for this amendment, but in the letter they did not even include the most recent approval number. As far as we know, they are currently operating under Approval No.  18701-02-00, yet in their public notice, dated June 2017, they said they were operating under Approval No. 18701-01-02.  If a letter of concern addresses the wrong operating approval, we worry that the letter won’t even be considered valid in the eyes of AEP.

"Please consider this letter as a formal opposition to the proposed operating approval amendment to operate a biomass incinerator at the Crowsnest Pass/Pincher Creek Landfill.

"If the incinerator is passed, we want confirmation that the landfill is going to be collecting baseline soil and surface water (including our dugouts) data that is publicly available, sharing any future amendments with the public, and directly sending us a copy of their annual regulatory reports so that we can ensure compliance."

The DeCocks are not the only voices of dissent against the proposed incinerator, just arguably the residents most directly affected by it, should it have effects. Approximately 100 people attended a presentation in Cowley by anti-incineration and anti-fluoridation activist Dr. Paul Connett in August 2016. "Incineration is in the past," he said. According to Connett incineration is extremely expensive, creates very few jobs, and is a waste of energy even when used for heating. He claimed more energy is saved at the global level by recycling and reusing products, and composting.

Biodegrading/composting facilities are being touted as the environmentally friendly future of deadstock removal.  CNPC says they've looked at composting  "however the compost must still be landfilled due to prions, and the liquids need to be disposed of. It's a long process, difficult, and the end outcome is not ideal."

Biomass transportation has to be calculated for any deadstock removal solution.  Odour, potential pathogens, scavengers, and visibility/effect on other traffic have to be accounted for, according to "Large Animal Mortality Composting", a Government of Alberta study.

Council for the Town of Pincher Creek discussed a letter from a concerned citizen back in June 2015, with councillors Doug Thronton and Jim Litkowski being vocal in their opposition to the incinerator plan.  Councillor Lorne Jackson, e member of the landfill committee, defended the project, saying "They would have to follow the European models that we have seen, with basically no emissions that come from those style of incinerators. They situate those units in close proximity to towns and villages, and you can't tell they're there," continued Jackson. "That's how little comes from those plants. They are waste-to-energy facilities that put power back into the communities."   Related link: CNPCL incinerator application.

The Crowsnest Pass Pincher Creek Landfill has certainly invested in recycling, as their new recycling facility attests.  It's a major improvement.  It is self-heated thanks to the recyclables oil burner inside the modern, if sparse, structure, which includes a public area of take-home recyclables like toys, microwave ovens, computer stuff, household items, etc.  Neon tubes are neatly disposed of, separated into glass and chemical elements.  All things recyclable have a place to be sorted and appropriately dealt with.  It is essentially a convenient and improved sorting facility for what would otherwise be waste.   It's even got an out-of-the-wind drive through.

Answering questions asked at their open house, CNPC said they "chose this technology after consideration of the other options available, and believe moving forward with it is appropriate."

"Odour and noise are not expected to be significant," was the answer to one concerns, and  they "will be combusting only biomass and polyethylene" the answer to another

"How can plastics be disposed of without harmful emissions?" was asked. Answered CNPC "In the case of the proposed CNPC incinerator, the plastics are non-chlorinated, there are no/extremely low HCL-related emissions. If the plastic is chlorinated, then emissions management is a much more significant concern, and additional pollution reduction technology would be required to manage this."
In answer to why they were sourcing waste materials "from so far away" CNPC said "A few years prior to 2008 the landfill was struggling to operate financially, however the addition of regional waste assisted with this process. Also, CNPC has a mandate to operate as a regional landfill, with a catchment covering southern Alberta. If the community wants a smaller landfill, that's up to their mandate, however a consequence would be that the tipping fee's would increase by approx. $25/ton."

According to CNPC noise "should not be a concern".

In terms of visibility CNPC says the "furnace is contained within a building, with stack up to 40 feet above ground level. The building will be located at the landfill, besides the new recycle building in the landfill."  It will probably run on natural gas for heating and electricity for the blower.

CNPC says there are 19 years left for the current landfill, with the potential to expand for another 85-90 years.

CNPC's board includes area councillors who report back to their councils, but the board itself can autonomously make the decision to move forward on the incinerator project.

CNPC says the project will benefit it by reducing landfill volumes, "and inevitably carcasses present handling complications in the pit. There is also cost of management as the MDs are subsidizing the carcass removal of beef cattle in the region - hence the landfill was directed to look at other options. Rendering companies are charging 10c/kg to handle the dead animals. Procedure with CFIA requires cleaning, tagging etc. to minimize re-contamination risk. Thre's no revenue in it for CNPC, but it will be close to cost-neutral."

If approved CNPC says approximately 5% of its total waste will pass through the incinerator.

According to CNPS "Carcasses are a growing concern and difficult to manage - e.g. pigs keep on popping up to the landfill surface."

The incinerator would burn for 10-12 hours before operators would let it cool down, clean it out, then start it again.  It would "probably operate at about 3 days/week" except during the higher volumes of calving season. 

CNPC says the bins that keep bears away from deadstock currently provided for ranchers in the area will not be removed.

CNPC: "The project began 5 or 6 years ago; a needs assessment was requested by the Board, we provided it, including wildlife carcasses etc. We looked at composting, we looked at mass burial, with incineration being the preferred technology."

"Directly affected" people can click here for CNCPL's Notice of Application to report your concerns, by August 8, 2017.

To contact Alberta Environment and Parks you can email Minister Shannon Phillips at aep.minister@gov.ab.ca, call 780 427-2391, fax 780 422-6259, or snail mail to:

Alberta Environment and Parks
Regulatory Approvals Center
5th Floor, 9915 – 108 Street
Edmonton, AB T5K 2G8

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