Thank you very much, Mr. Chairman and committee members.
I'd like to thank the committee for providing us with an opportunity to make a presentation today on Bennett Environmental and its facility in Belledune, New Brunswick.
I'll begin with a brief description of our company and the process it followed in New Brunswick, and then I have a short video to show you so that you can see firsthand the size, scope, science, and technology of this facility.
Bennett Environmental is a publicly traded company on the TSX and has four facilities: Kirkland Lake, Ontario; Cornwall, Ontario; Saint-Ambroise, Quebec; and Belledune, New Brunswick.
Two of our facilities use high-temperature thermal oxidation. Many people don't know what this term means and they immediately jump to visions of incinerators with fire and brimstone that they've seen on TV, or if you happen to have lived in a city that has some of those old municipal incinerators. But let me explain to you clearly that Bennett uses high-temperature thermal oxidation to remove dangerous contaminants from soils, and we destroy these contaminants with a subsequent thermal action.
As I mentioned, the term “incineration” always conjures up fire, but you all know that in a forest fire, soil doesn't burn. Grasses burn, trees burn, structures burn, but soils don't burn. So when we treat the soil, we don't burn the soil. We heat it to high temperatures so we can break down and oxidize the harmful contaminants within the soil.
We have a long track record operating these high-temperature oxidizers, having operated our facility in Saint-Ambroise, Quebec, for the past 10 years. The facility remediates contaminated soils created by industry and governments alike. Organic contaminants such as petroleum hydrocarbons, PCBs, dioxins, furans, pesticides, PAHs, wood preservatives, and creosote are all contaminants that we can treat. We use what the U.S. EPA has called the “best demonstrated available technology”.
In addition, our plant in Saint-Ambroise chose to be audited by a third party, and subsequently achieved registration to the international environmental management standard, ISO 14000, the world's leading environmental standard and accreditation.
Our facility in Saint-Ambroise has successfully completed big and little projects—many projects for the Canadian government; the U.S. EPA; the U.S. Centers for Disease Control and Prevention; the U.S. Army Corps of Engineers; and large corporations in Canada such as Dufferin Construction Company and General Electric Canada. We've even destroyed controlled substances for the RCMP and dangerous chemical components of crystal meth production.
Let me assure you, given the fact that there are only a few facilities licensed in Canada that can remediate these types of contaminants and substances, our Saint-Ambroise facility is under extremely high scrutiny in the province of Quebec with all stakeholders. Each and every year, the Quebec Ministry of Sustainable Development, Environment and Parks audits the facility to ensure that it complies with Quebec's rigorous environmental laws, and each and every year we get better and better at what we do.
Bennett's Belledune facility is the latest generation facility, and as such includes state-of-the-art emission controls, continuous equipment monitoring and automation, and the latest generation in continuous emission measurement right at the emission stack. We monitor carbon monoxide, total hydrocarbons, HCl, sulphur dioxide, nitrogen oxides, arsenic, and other contaminants.
In order to ensure that there are no fugitive emissions from contaminated soil being released into the atmosphere, all material is handled inside a building and under negative pressure. In order to ensure that no contaminants enter the local groundwater, the facility has a liner built under the building. We are state-of-the-art. In fact, we have spent $12 million alone on the emissions control system.
As for the history of the project, it began in 2002. Working with the New Brunswick Department of Environment, Bennett began to follow a thorough regulatory process in order to properly obtain all its permits.
Briefly, the process started with an application for determination to the Department of the Environment and Local Government, as it was called at the time, in compliance with that province's environmental impact assessment regulation.
Following a thorough review of the project, the Department of the Environment approved the project under its EIA regulation. The provincial minister's determination to allow the project to proceed included 24 substantive conditions that we had to meet before we got a permit to construct the facility. Those requirements or conditions included completion of an air dispersion modelling study and a human health risk assessment, along with several other studies.
As part of this rigorous process, the information on Bennett was sent to various federal departments that were part of the province's new review committee, including the Department of Fisheries and Oceans and the Department of the Environment. Subsequently, and following substantive public pressure, the federal departments of Environment, Fisheries and Oceans, Health, and Indian Affairs and Northern Development undertook an intensive review of the documentation that was generated for this project as part of the provincial environmental impact assessment. That was done to determine whether or not the federal Minister of the Environment should refer the Belledune facility to the review panel under CEAA.
Each of these departments spent time reviewing Bennett's application to determine the potential environmental impacts of the proposed facility, and whether there were any triggers under CEAA that would automatically put this application into federal environmental assessment. The federal departments, after consultations and much study, determined that the Belledune project would have negligible impact on the environment, and therefore a federal environmental assessment was not required.
Notwithstanding this determination by the federal government, and at a cost of well over $1 million, Bennett Environmental undertook a number of other studies that, when we consider them in their totality, largely replicated the studies that might have been required under a federal environmental assessment. The studies included a human health risk assessment and an air dispersion modelling study. We did everything we could to remain within the constraints of both the New Brunswick and the federal government regulation.
If I leave you with one thought today, it is to ask you to remember that facilities such as Bennett Environmental are remediation facilities. We are part of the solution to cleaning up man-made problems. We are not a problem. Our facilities take contaminants that are currently in the environment, contaminants that are currently at risk to men, women, and children in the air and water they consume; we take those soils, safely handle them, and permanently destroy the organic contaminants.
Finally, there are a number of issues I'd like to clarify after having read the notes of a previous witness you heard from in November. In my opinion there were very many errors, but because of time constraints I will only focus on a few. I read with interest that you were told that over three tonnes of PCBs and over ten tonnes of chlorinated hydrocarbons could be allowed to be treated in Belledune. I can assure you that these numbers were generated only as a scare tactic, and are indeed very misleading.
The truth of the matter is that Belledune facility's draft permit to operate limits it to treating soils with PCB concentrations of up to 33 parts per million. At first blush, some of you may think this is high, but I'd like to draw to your attention what the Canadian environmental quality guidelines suggest as acceptable limits for PCBs in commercial soils and industrial sites: 33 parts per million. In other words, the guidelines that the Government of Canada has adopted imply that it is acceptable to build an office building or a grocery store on soil contaminated with 33 parts per million of PCB. That, ladies and gentlemen, is a fact today.
Additionally, PCB material up to 50 parts per million is acceptable to be put in a landfill today. In other words, soil with 50 parts per million--that's 17 parts per million more than I'm allowed to treat--can simply be put in a dump, a dump that doesn't have any emission control systems to deal with PCB emissions that may be dispersed by the wind as the soil is unloaded and moved around.
I ask you to imagine the potential impacts of this soil being dumped on a regular basis, not far from a river, not far from a stream, not far from the ocean, and I'd like you to compare this to the extensive fugitive emission controls and monitoring systems that our company has spent $12 million on in Belledune. I ask you to draw your own conclusions to the fact that you can legally dispose of higher PCB concentrations than I'm allowed to treat in a dump.
Now let me get back to the comments the other witnesses made about us taking 3,000 tonnes of PCBs. Let me tell you, in order for that to happen, each and every tonne of soil we would procure would have to contain 33 parts per million of PCBs--theoretically achievable, but highly improbable.
Another thing I'd like you to know is that it would be ludicrous for us to chase this kind of soil, because you can put in a landfill PCBs that are contaminated with 50 parts per million. Landfills charge $30 a tonne. Our process charges 15 to 20 times more than $30 a tonne, so you're not going to see me and our sales team out there chasing around soils that have 33 parts per million of PCB contamination.
With regard to dioxins and furans and the contentions made about our facility in Saint-Ambroise, that we were the source of dioxins and furans in the environment, this is simply and demonstrably not true: lies, lies, and more lies. Monitoring of dioxins and furans in the air and soil around the facility demonstrates that our facility in Saint-Ambroise is not adversely affecting the area and not polluting it with dioxins and furans. In our effort to be among the best environmental citizens and to differentiate ourselves from our competitors, in December 2005 we voluntarily agreed to dioxin and furan limits in Quebec of 60 femtograms TEQ per cubic metre. Just so you know, your own criteria, the federal government's criteria, for dioxins and furans is 5,000 femtograms. We agreed to be below 60 femtograms. Your own criteria is 5,000 femtograms. Our system is 80 times more stringent.
In order for you to have a good understanding of what this means, I'd like to use an analogy of a grain of salt. If dioxin and furan emissions were compared to a grain of salt, your Canada-wide standard would permit stack emissions of six grains of salt a week, or 280 grains of salt a year. We do better than that. We are less than one grain of salt a week, or less than 52 grains of salt a year.
Continuous air monitoring around the facility demonstrates that the Saint-Ambroise facility meets this extremely stringent voluntary criterion. We are the only plant in Quebec that has voluntarily signed on to this standard. As a result of our technology and experience and track record, we are one of the only facilities in the world that has the proven capability to safely and effectively treat soil contaminated with dioxins and furans. Because of this fact, in January 2006 the Quebec Ministry of Sustainable Development, Environment and Parks gave us an upgrade to our permit to treat soils contaminated with dioxins and furans. The contamination can be unlimited dioxin and furan in the soil.
With regard to any potential impact that we would have in Belledune, I want to point out that the facility is located more than a kilometre and a half away from Baie-des-Chaleurs. All of our emissions dispersion models demonstrate that we would have negligible impact on land. Again, I want to stress that emissions from the facility are required to meet extremely stringent criteria established by federal and provincial governments.
As I wrap up, Mr. Chair and committee members, I would like to take the opportunity to show you this quick, short video. As they say, a picture paints a thousand words. It was shot in April of this year and really does demonstrate the size and scope of our facility. It gives you a firsthand look at emission control systems that can ensure 99.9999% destruction removal efficiency.
At the close of the video I would be happy to answer your questions.
[Video Presentation]
