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:
A. 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?
B. 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?
C. Air & Water Quality:
1. Please provide quantitative estimates of expected VOCs, especially Benzene,1,2-Butadiene, 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?
D. 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 "?
D. 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?
E. 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.
