Comments on NAOSC's Public Disclosure Document
NAOSC's proposal for a bitumen upgrader west of
Bruderheim needs to be examined within the context of the impact of
intensifying construction of petrochemical plants in the Industrial
Heartland zones of Strathcona and Lamont counties on environmental quality
of adjacent areas.
By Walter Schneider
Note: Aside from absolute and unalterable facts, this article contains
comments that are my own that do not necessarily reflect
position of FOLC or
the opinions of all members of FOLC.
Without a doubt, the construction of ever more bitumen upgraders and
related petrochemical plants in the Industrial Heartland zones of Strathcona
and Lamont Counties will be welcomed by those looking for jobs in the
construction and operation of petrochemical plants close to home.
Others look forward to other positive consequences of the increased construction in our
area of Alberta, such as increased tax-revenues and increased opportunity
for retailing and light industry, but there will be trade-offs. Some
of those trade-offs are escalating housing prices (those increased by a
factor of about three within the last three years), escalating wages and
increasing prices for consumer goods.
Public Disclosure Document (Upgrader) - March 5, 2007
(off-site, 2.4 MB PDF file) presents a very pretty picture. It
presents many pretty pictures (none of which look like the photo on the right),
namely rural settings with pristine blue skies that were used as the
background on which the text of the document is shown.
It remains to be seen whether NAOSC will be able to live
up to its subliminally presented image of being exceedingly
environmentally friendly. Those pictures bear no relationship to real
life here and to the fact that background levels of pollution are on the
Far from causing
pristine blue skies, the emissions from
the proposed bitumen upgrader will be a substantial addition to the
poisonous atmospheric pollution that increasingly over the years
manifested itself as a brown haze (often very heavy, dark and
menacing — see photo at right) and acidic rains, mists and fogs that
ever-increasingly corrode the quality of the environment and of our
lives here. (More photos)
Over the years objectionable levels of pollution have become more and more
frequent and are more and more often visible, even though air-quality
monitoring data (somewhat difficult to obtain for the construction of
long-term trend indicators) produced by monitoring agencies identify no
problems of great concern.
Any corporation will present itself in the best of possible lights.
It is practical and logical to do so. It would not be
reasonable to expect someone like NAOSC to show itself in the
context of the worst possible circumstances.
NAOSC deserves credit for the quality of their public relation
efforts and their awareness of concerns regarding the environmental
impact of their proposed upgrader. Not once (to my
knowledge) have they downplayed or denied the validity of any
concerns expressed about the environmental impact their upgrader
facility would have.
Still, the proposed NAOSC upgrader (and others to come) will be right at
Bruderheim's back door. We will get to smell its effluents,
and we will have to suffer the consequences of increased air
pollution. Without a doubt, NAOSC will design its upgrader to
operate within permissible limits. However, exceptions will occur with
all industrial facilities. Exceedences of air-quality standards are to
be expected at times, and the emissions from the NAOSC upgrader, even in the unlikely circumstance of being
within acceptable limits at all times, will add to and increase the
level of pollution produced by all plants in the Industrial
Every one of the environmental impact assessments for all of the
refineries and upgraders operating in the corner of Strathcona
County to the west of us (the Industrial Heartland) identified that the facility it related to
would add negligible and acceptable levels of air pollution, but not
one of them ever identified that the cumulative effects of the
emissions by the plant in question and its neighbours would raise
the background pollution levels to increasingly frequent
unacceptable levels. It is little consolation to people living
downwind from polluting plants to learn that unhealthy and damaging
concentrations of air pollution were caused by "building-downwash
effects" (virtually the only explanation ever offered when
emission exceedences are reported by the
Fort Air Partnership).
Building-downwash effects that cause
objectionable pollution levels to be measured at a ground location
near and downwind from an emitting source of pollution are consequences, not causes, of
excessive pollution emissions, although it can be and is being
argued that they cause high pollution levels to be measured by the
air monitor installed for a given source of pollution. A given
single air monitor will not come close to capturing all building-downwash effects
it is intended to measure. It will only tell us about
pollution levels during a specific building-downwash condition when
the wind blows at a specific speed or higher from the emission
source towards the air monitor. Unless a ring of air monitors
surrounds a source of pollution, we will not be able to tell how
many of those building-downwash conditions occur at that source of
emission. Moreover, air-quality monitors located on the ground
near sources of emissions are not likely to show emission
exceedences when there is little wind, even though under those
conditions communities at nearby locations could well experience
objectionable air-quality conditions that defy being detected at the
We can experience the equivalent of a building downwash effect
when we sit around a camp fire whose smoke causes our eyes to smart
and makes us move upwind from the fire to escape the smoke. Air
monitors cannot move around a source of emission to a location where
high pollution levels downwind from a source can be measured.
Moreover, on a calm day none of the people sitting around a camp
fire will smell the smoke from that fire regardless of their
position in relation to the fire, unless they hold their heads right
into the smoke. On a calm day the smoke from that fire will
rise straight up to a fairly high level, spread out at higher
atmospheric levels and never bother anyone in its vicinity.
However, the smoke will descend from those higher atmospheric levels
quite some distance from the fire and can make conditions many miles
away quite unpleasant, especially if the fire is large enough.
All of us experienced such circumstances, even though at those times
we were many hundreds of miles away from forest fires that burned in
British Columbia or Northern Alberta.
Most smoke particles and components of smoke are heavier than air.
That is true also of the vast majority of the components of the air
pollution emitted by the petrochemical plants located in the
Industrial Heartland. The smoke particles from a fire rise into the
air because the air containing them is hot. Hot air is lighter
than cold air, therefore it rises in a cold air layer.
The air containing the smoke will cool off, and the smoke particles
entrained in the cooled-off air — being heavier than the air
entraining them — will
drift downward and come back closer to the ground, becoming more
concentrated in the process, especially if there is no or little
wind. That is
also true of the air pollution emitted by the pollution sources
located in Strathcona County. Raising the height of a smoke- or
exhaust stack will do absolutely nothing to reduce the volume of
pollution emitted, it will merely ensure that the emitted pollution
will be somewhat better diluted by dispersing it over a wider area.
However, just like smoke, air pollution emitted by the industrial
plants in Strathcona County will reach the ground somewhere —
concentrated and within a very short distance from the sources of
emission if the conditions are right, somewhat more diluted and at a
greater distance if the wind blows with sufficient strength.
The weather conditions reflected in the photo shown at the top of
this page would have made it extremely unlikely that objectionable
levels of, say, sulphur dioxide or nitrogen oxides, would have been
measured around 7 a.m. on September 9, 2006 at any of the air
monitoring stations near the plants that caused the pollution that
is clearly visible in the photo. It is doubtful that any
of the air monitoring stations in the Fort Air Partnership's
air-shed zone measured exceptionally high levels of
pollution on that day and at that time. The local air
pollution having caused the brownish to purplish tint of the atmosphere
visible in the photo was concentrated hundreds of feet above ground
where the photo was taken but was sufficiently dense and cool enough to show up as a dark cloud
bank hovering at an apparently lower level about 40 to 60 miles to
the north, well beyond the boundaries of the Fort Air Partnership
air-shed zone. (Keep in mind that the photo was not taken for
the purpose of demonstrating the extent of air pollution caused by
the Industrial Heartland. It was taken as part of a set of
photos showing the integration of industry and agriculture in our
area. The capture of the visible air pollution was accidental
and not even of one of the worst we get to experience here. At
times the visible evidence of the collective air-pollution effects
in this area is far more intense.)
On a windy day the concentration of the air pollution visible in
the photo above would have reached the ground in a much shorter
distance, without having had a chance to become much diluted in
spite of more intense atmospheric mixing.
During certain atmospheric conditions (i. e.: in relatively calm
conditions, with a warm air layer over a shallow layer of cold air)
very high concentrations of air pollution will occur at ground
levels and can at times be as much as one-hundred times higher than
what is normal or average, except that those extremely high levels
are not as likely to be measured in Strathcona County as they are to
be detected in adjacent counties, in Lamont County, Sturgeon County,
Thorhild County or even in Edmonton.
Telling us about building-downwash effects right at emission
sources tells us
nothing about what caused them. Most of all, those
measurements tell us nothing about the air-quality conditions in
locations where no air monitoring equipment exists.
Building-downwash-effect conditions are a symptom and not the
cause of unacceptable pollution emissions. No problem has ever
been successfully solved by talking about its symptoms rather than
about their causes and about the actions required to eradicate those
The residents in this area must
be forgiven and have good reasons for believing that no effective
policing of pollution emissions originating in Stathcona County is
Items from NAOSC's Public Disclosure Document
that should concern residents in Bruderheim and area and in Lamont County.
(Items on blue background and items 4a and 4b were copied from the
The map shown here (on the right) has been edited to show
Bruderheim. Bruderheim is not shown on the original map contained in NAOSC's public disclosure document.
It is very difficult to believe that the omission of the nearest
community neighbouring the proposed NAOSC upgrader was accidental.
It appears reasonable to expect that, if NAOSC does not even show
that community on the map identifying the location of its proposed upgrader, then
the residents of that "forgotten" community
located so near to NAOSC's proposed upgrader do not rank very high
on NAOSC's priority list.
A good number of long-term residents in
remember the long-standing fight of the acreage owners at
Highway 15 south from DOW Chemical.
Chemical eventually bought them out (at an undisclosed amount, being
the only buyer), removed the homes from those
acreages and posted "NO TRESPASSING" signs at those properties.
Only a handful of property owners and their families were involved.
It is quite possibly unavoidable that the fate of those people is
nothing other than what is in store on a much larger scale for the
residents of Bruderheim and area.
Neither Bruderheim nor Lamont are presently equipped with
air-monitoring stations. It is necessary right now to address
the long-standing neglect by the
Fort Air Partnership (FAP) to install active environmental
monitoring stations within the boundaries of the most-affected
communities in the Fort Air Partnership air-shed zone. The
monitoring station in the hills of Elk Island Park will not do
residents and property owners in Lamont and Bruderheim much good
when it comes to the need for demonstrating that the quality of
their health and lives is being destroyed.
The FAP's "Lamont"
monitoring station is located at an elevation of 715 m, west of
Range Road 202 and ¾ of a mile south of Highway 15, 4 miles west of
Lamont (elevation 647 m) and 3.5 miles SE from Bruderheim (elevation
627 m). That monitoring station too — being located at a much
higher elevation than either Bruderheim or Lamont, and some distance
from either community — will not do the residents of Bruderheim and
Lamont much good when the valley fills up with pollutants and when
at the same time the
hills south of Highway 15 experience clear air.
On the other hand, having air-monitoring equipment located in the centres of the
communities in Lamont County will give a clear indication of what
air-quality conditions in those communities are at any time,
regardless of which direction the wind blows and regardless of
whether building-downwash effects happened to be detected at any of
the sources of pollution in the Industrial Heartland.
The interests of the residents in Lamont County are not being
served by locating air-quality monitors in locations where the
modelling of the Fort Air Partnership air-shed zone dictates they
should be located. Locating them according to that would not
permit to detect whether the models are flawed. Locating them in the
of the communities in Lamont County would not only provide
measurements of actual conditions for Lamont County residents, it
would provide clear indications of whether the models adequately
address the conditions for the County's residents. After all,
no county-residents reside in the hills of Elk Island Park. The
quality of the air that the county-residents in the valley must
breathe during an inversion can be quite bad, while monitors in the
hills may show no problems at all.
Perhaps even more importantly, having those air-quality monitoring
stations in place in the centres of their communities will give the
residents of those communities the assurance that the
pollution-emitting sources don't try to rely on the low probability
that building-downwash effects will actually be detected when they
occur. After all, regardless of what happens at the sources of
air pollution, those community air-quality measuring stations would
tell without any doubt about the level of risk the residents of
those communities are exposed to at any given time. The
absence of air quality monitors right at the centers of the
communities in Lamont County is a grave concern, as illustrated by
this recent news story: "Sulphur
Dioxide Poisons Bulgarian Village of Galabovo".
As per the "2005 Air Quality Summary" chart shown on this
Lamont experienced the second-lowest air quality of the communities
listed (note that the value identified for Lamont was not derived
within the boundaries of Lamont, and that Bruderheim is not
If the value shown for Lamont is close to reality,
then for 3.5 percent of the time in 2005 Lamont residents had to breathe air
that was not good for consumption. We don't know what things
were like in Bruderheim as far as air quality goes because
Bruderheim residents don't count, perhaps because they would kick up
a fuss if they knew what they are breathing.
"Percent of Time Air Quality Rated Good" is not a good indicator of risks
posed by dangerous emissions. All it takes is one extremely
bad instance, and we all suffer permanent damage or worse.
However, going by the 2005 Air Quality Summary chart, we can be made to
believe that on average we should feel quite good. We would
then be just like the man who's got his feet in a bucket of ice
water and his head in the hot oven. Going by the law of
averages, he should feel comfortable.
Disposal of waste by-products
It appears that as of now NAOSC has
given much thought to the disposal of all of the waste-products of its
When asked about what NAOSC anticipates with respect to storage
requirements for waste sulphur, NAOSC's
representatives at NAOSC's open house in
Bruderheim, Jan. 25, 2007 (and again at NAOSC's subsequent open
house in the Lamont Recreation Centre's arena meeting room), stated
that, except for a maximum of three day's buffer storage, NAOSC
will not store waste sulphur at the site of its proposed upgrader.
The process flow diagram contained in NAOSC's public disclosure
document for its proposed upgrader shows absolutely no waste
products being generated by the plant (although some of the more
detailed flow process diagrams shown in the displays presented at
their open house in Lamont do).
Going by the process flow diagram contained in NAOSC's public
disclosure documents, it would logically follow that NAOSC's upgrader is the chemical equivalent of a perpetual motion
engine. Perpetual motion engines are a physical impossibility;
but if someone were almighty and could built one, it would produce
no waste of any kind.
Still, NAOSC appears to be aware of the problems it needs to come
to terms with, as "impurities such as sulphur, nitrogen and heavy
metals" need to be removed from the syncrude NAOSC will produce.
Aside from the problem of waste-sulphur disposal, it will be a bit
of a problem to deal with the heavy metals (amongst them will be
mercury, nickel, vanadium and concentrated radioactive isotopes of heavy metals)
On account of its toxic qualities, environmental activists call pet-coke "the
fuel from hell"
Waste by-products storage-space
NAOSC states that the site for its
will occupy 700 acres, although
the terms of reference for the environmental impact assessment study
(off-site, 154 kB PDF file) mention 1,350 acres. That would
appear to be large enough for a few waste-sulphur storage blocks and
petroleum coke (a.k.a. pet-coke) storage piles, but it
is not likely enough space for all of the waste sulphur and pet-coke produced by
the upgrader during the span of "over 50 years".
(Update April 30, 2007: It must be stressed that NAOSC's
representatives stated at both of their open houses in Bruderheim
and Lamont that all of the waste sulphur NAOSC will produce will be
sold through the sulphur market, and that pet-coke is not intended
to be stored at all. The latter would be converted to synthetic gas.)
NAOSC intends to produce synthetic gas (syngas) from the pet-coke its upgrader
produce if or when phase 2 of the upgrader goes into production.
Some of the pet-coke (all of it, according to NAOSC's
representatives at their open house in Lamont) will be re-used in phase 2 of the upgrader,
which is quite a few years off in the future (slated for 2015).
How much storage space will be used for the pet-coke, and how will that
pet-coke impact the environment in our neighbourhood? The keyword
in "will ...eliminate most of the petroleum coke waste by-product"
is most, the point being that we don't know how much
pet-coke or other waste byproducts will be left and require disposal
or long-term storage. It appears that we won't get to know the
details of that until the detailed engineering for the upgrader is
Will the excess pet-coke and
excess waste sulphur
be stored in Lamont County, thereby making further use of Lamont County
cesspool for Strathcona County's profitable petro-chemical industry?
The answer to that provided at NAOSC's open house in Lamont was,
Conflicting production figures for phase 1
- On page 10 of its public disclosure document NAOSC states:
The Phase 1 upgrader facility will produce approximately
12,000 cubic metres (65,000 barrels) per day of SCO (SCO
stands for synthetic crude oil — folc.ca
- On page 13 of its public disclosure document NAOSC states:
We expect the first phase of the upgrader, with a capacity of
12,000 cubic metres (76,000 barrels per day) of bitumen feed, to
be operational in 2012.
Those two statements are not compatible. A volume of 12,000
m3 cannot equal at one time 65,000 barrels and at another
time 76,000 barrels. However, it is quite possible that the
difference of 11,000 barrels per day between the bitumen feed and
the output in the form of SCO represents the volume of waste
by-products in their various forms that will have to be removed in
upgrading bitumen to SCO.
NAOSC will be more meticulously clear and
precise when it goes through the engineering stages of its project.
When it comes to operating such a facility, the
magnitude of the difference shown between the two statements identified above exceeds
by far what can be expected from instrument errors and often
results in catastrophic failures of production facilities and
operational logistics. They can very possibly result in
expensive re-engineering and modifications of operational plant,
while the people residing in the neighbourhood must cope with the
consequences of the fallout of malfunctioning processing facilities until the
required corrections have been made. (I. E.: The startup of Syncrude's
new Coker 8-3 in May 2006 caused noxious fumes to be emitted.
The foul-smelling emissions motivated Alberta Environment to order
the coker to be shut down. After expensive modifications,
Syncrude announced in November of 2006 that they had solved the
problems with the flue-gas-desulphurization unit of the coker and
had restarted the coker.)
NAOSC will without a doubt estimate the production figures for its
proposed upgrader facility with better accuracy than
demonstrated in those two statements quoted above. At its
Jan. 25, 2007 open house,
NAOSC identified that it cannot be precise about
waste-by-product figures unless it first does the detailed
engineering for its facility. That means that unless NAOSC
first does the detailed engineering for its plant it cannot
accurately address many concerns about the environmental impact its
plant will have. The emission and byproduct figures contained
proposed terms of reference for the environmental impact assessment
for its upgrader facility (off-site, 154 kB PDF file) are no
more than first estimates. However, NAOSC representatives
stated at their open house in Lamont that they wish to put their
upgrader into operation and will therefore design and implement
whatever it takes to meet applicable emission standards.
Posted 2007 03 07
2007 03 08 (inserted comment on air quality)
2007 03 09 (expanded the discussion of building-downwash
2007 04 20 (added location details for the FAP's
"Lamont" monitoring station)
2007 04 30 (made edits based on information provided by NAOSC at its open
house in Lamont)