HomeMy WebLinkAboutPSD-023-09Claringto~
Leading the Way
REPORT
PLANNING SERVICES
Meeting: GENERAL PURPOSE AND ADMINISTRATION COIMMITTEEn ,/
Date: Monday, February 23, 2009 ~tSDlutt~p~~~~~'j~ ~~
Report #: PSD-023-09 File #: PLN 17.1.10 By-law #:
Subject: ST. MARYS CEMENT APPLICATION FOR ALTERNATIVE FUEL
DEMONSTRATION PROJECT EBR REGISTRY NUMBER: 010-4892
RECOMMENDATIONS:
It is respectfully recommended that the General Purpose and Administration Committee
recommend to Council the following:
1. THAT Report PSD-023-09 be received;
2. THAT a copy of this report be forwarded to the Ministry of the Environment as
comments by the Municipality of Clarington on the Proposed Demonstration Project by
St. Marys Cement in response to the EBR informational posting; and;;
3. THAT all interested parties listed in this report and any delegations be advised of
Council's decision.
Submitted by: Reviewed by:
vid J. Cr P
irector of Planning Services
FUsh
17 February 2009
d v.~,..eQ~~v.~,
Franklin Wu,
Chief Administrative Officer
CORPORATION OF THE MUNICIPALITY OF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L7C 3A6 T (905)623-3379 F (905)623-0830
REPORT NO.: PSD-023-09
1.0 BACKGROUND
2
1.1 Council received not cation from St. Marys Cement (St. Marys) on Wednesday, July
30th, 2008 that St. Marys would be applying to the Ministry of Environment (MOE) for
approval of a demonstration to burn alternative fuels. St. Marys held a public
information session on August 13th and a second session on September 10t". The
purpose of the public information sessions were to provide information to the public at
the beginning of the process so that their feedback and comments could be taken into
consideration in the demonstration project.
1.2 St. Marys applied in September with an amendment, in November 2008 to the MOE for
a Certificate of Approval for the Demonstration Project. Council should be aware that
the demonstration project is a multi-step process that may or may not, depending on the
results of the test and St. Marys business decisions, lead to an application under the
Environmental Assessment (EA) Act and regulations and the Environmental Protection
Act (EPA) for a waste Certificate of Approval (C of A) and an amendment to their
current air emissions Certificate of Approval.
1.3 On Friday, February 6, 2009 the Ministry of the Environment on the Environmental Bill
of Rights (EBR) website posted the following notification on the alternative fuels
demonstration:
The undertaking is exempt from the Environmental Assessment Act by virtue
of Regulation 334 as it is considered to be a research undertaking. An
instrument (i. e., Certificate of Approval) that implements that undertaking is
also exempt from notice requirements under the Environmental Bill of rights,
1993, meaning that a notice of proposal (or decision) on the Environmental
Registry is not required. However, the Ministry recognizes the interest of the
public in the project and has determined that an information posting of the
proposal would best serve the public.
Typically, the Ministry of Environment will wait at least 30 days before a C of A is
issued. A schedule for proceeding with the demonstration is still subject to economic
factors and no timeline has yet been defined by St. Marys to implement the
Demonstration Project.
1.4 The purpose of this report is to provide background and comments on the
Demonstration Project.
2.0 OUTLINE OF THE APPROVAL PROCESS
2.1 St. Marys Cement wishes to carryout an Alternative Fuels Demonstration. The purpose
of the demonstration project is to test alternative types of fuels that St. Marys would like
to use to replace up to 30% of conventional fuel (petcoke). The demonstration project is
to carry out testing to verify that alternative fuel provides the results desired for the
cement making process, and does not adversely affect the air quality.
REPORT NO.: PSD-023-08 PAGE 3
2.2 St. Marys has bet?n working with the MOE to finalize the Alternative Fuels
Demonstration Project and has obtained the necessary permits to undertake the
demonstration. The Pre-Test Plan (PTP) was submitted to the Ontario Ministry of the
Environment, Standards Development Branch in September and amended in
November. The alternative fuels demonstration requires the MOE to issue a Certificate
of Approval. The Municipality has provided comments on the C of A applications to the
MOE in the form of a letter and Council Resolution (Attachment 1). In addition, the
application has been posted on the Environmental Bill of Rights (EBR) website so that
any other interested parties can comment as well.
2.3 St. Marys is seeking approval of a demonstration plan which is a "test" of the alternative
fuels. It is a time limited trial (40 days) of the alternative fuels and does not
automatically imply that they will be seeking approval for full time use of these
alternative fuels. Should the test results be satisfactory and St. Marys decide to
proceed, they would have to seek approval under the Environmental Assessment Act
and its regulations and Environmental Protection Act, during that process the
Municipality and other agencies would again be asked to comment and all necessary
permits and approvals would have to be in place for St. Marys to proceed.
2.4 St. Marys has identified some potential environmental benefits to using alternative fuels:.
• cost benefit through the reduction of fossil fuels;
• a sizeable reduction in St. Marys green house gases emissions; and
• a viable use far post recycling and post composting residuals (otherwise they
would be landfilled).
2.5 The purpose of the time limited demonstration project is to gather site-specific air
emission data at the St. Marys plant in Bowmanville to determine the feasibility of using
the selected alternative fuels that are being tested.
2.6 A condition of the Certificate of Approval by the MOE is the provision for the
requirements of other legislation to be met. In other words, the issuance of the
Certificate of Approval does not relieve St. Marys from complying with other legal
requirements, such as the Planning Act.
3.0 SCHEDULE
3.1 The demonstration is expected to last approximately 37 days in Bowmanville including
equipment set-up, initial fuel delivery baseline testing, ramp up and alternative fuels
testing. Total alternative fuel usage is anticipated to be approximately 3,800 tonnes.
3.2 At this point St. Marys do not have a specific start-up date identified.
REPORT NO.: PSD-023-09
4.0 ALTERNATIVE FUELS TO BE USED IN THE DEMONSTRATION PROJECT
PAGE 4
4.1 St. Marys has ident~ed post recycling and post composting residuals as alternative
fuels for their cement manufacturing facilities. Tires are not considered to be post
recycling or post composting residuals and will not be used in this demonstration
project.
Table 1: Alternative Fuels for the Demonstration Project
Alternative Fual Descri t'ron
Primarily film plastic bags removed from compost generated from
1. Post-Composting some residential organics collection programs as well as plastic film
Residual Plastic Film associated with sanitary paper products (e.g. diapers) that are
allowed in these ro rams.
2. Post-Recycling Paper Residues remaining after the pulping of paper recovered from
Biosolids recycling programs. This material will be composed of
a roximatel 20% moisture, 40% cla and 40% biomass.
3. Post-Recycling Residual Plastic and other contaminants (film plastic, bottles, coated paper
Material etc.) removed during the processing of the recycled paper from
Blue Box ro rams.
4.2.1 Expected Air Quality Impacts associated with the Use of Alternative Fuels during the
Demonstration Protect
St. Marys expects off-site air quality to be very similar to the existing emission levels
from the conventional fuel (petcoke).
4.2.2 Ambient Testing to Verifv that there will be No Off Site Impacts During the
Demonstration Protect
While St. Marys predicts that there will
demonstration project, St. Marys, will
off-site concentrations of metals anc
conventional and alternative fuel use
standards. Sampling locations will be
plume.
5.0
5.1
be not be an increase in air emissions during the
conduct off-site ambient monitoring to verify that
organic compounds are comparable between
and that levels remain well below any applicable
chosen based on the dispersion of the kiln stack
OVERVIEW OF THE DEMONSTRATION PROJECT
Summary of Cement Manufacturihg Process
Cement manufacturing essentially consists of combining materials bearing calcium
oxide, silica, alumina and iron oxide in a rotary kiln at very high temperatures (1450 °C)
to produce cement clinker. The clinker is subsequently cooled and ground with finishing
materials such as gypsum, limestone and slag to produce cement.
REPORT NO.: PSD-023-09
~A2C G
In order to generate the required high temperatures to form clinker the kiln systems fuel
is pneumatically fed into the kiln through one fuel pipe and also to the pre-calciner prior
to the kiln. The demonstration project will replace up to 30 percent of conventional fuel
with alternative fuel.
During the demonstration project at the Bowmanville plant, Alternative Fuels 1, 2 and 3
will be fed to the kiln and calciner as presented in the following matrix.
Demonstration Period of
Scenario Alternative Fuef Fuel Feed Ramp up Continuous
(Bowmanvitle) Location (days} Fuefuse
(days)
1: up to 30%
replacement of
fuel to the Kiln 1_ post-Composting
Kiln Burner
1
3
with alternative Residual Plastic Film
fuel
2: up t0 30%
replacement of
fuel to the ~_ pt-Composting Residual
Precalciner
1
3
Precalciner with plastic Film
alternative fuel
3: up to 30%
replacement of
fuel to the Kiln 2 -Post-Recycling Paper
Kiln Burner
1
with alternative giosolids 3
fuel
4: up to 30%
replacement of
fuel to the 2 -Post-Recycling Paper
Precalciner
1
Precalciner with giosolids 3
alternative fuel
5: up to 30%
replacement of
fuel to the Kiln 3 -Post-Recycling Residual
Kiln Burner
1
with alternative Materials 3
fuel
6: up to 30%
replacement of
fuel to the 3 -Post-Recycling Residual
Precalciner
1
Precalciner with Materials 3
alternative fuel
Minor modifications will be made to the kiln burner and pre-calciner system at the
Bowmanville plant prior to the demonstration to allow for feed of a second fuel stream.
Alternative fuel is expected to be used over a total of 30 days (including ramp up days
and 18 days of continuous use).
5.2 Alternative Fuels Storage and Handling Svstem
St. Marys will be using a portable Schenck Alternative Fuel Feeding System to
pneumatically feed the alternative fuels into the kiln system. During the demonstration
REPORT NO.: PSD-023-09
PAGE 6
program the system will be housed within a temporary portable structure operating at a
slight negative pressure to prevent material loss and any odour emissions. Alternative
fuels will be delivered to the site in a transport truck that will feed directly into the burner
using an internal conveyor. Material will be transferred into the Schenk system hopper
which will feed a covered conveyor system that will move the alternative fuels to an
isolation rotary gate from which it will be pneumatically transferred to the burner (kiln or
precalciner) as shown in Attachment 2.
Alternative fuels are expected to arrive on site in a feed ready condition for the
demonstration on a just-in-time schedule. It is currently expected that any pre-
processing of the fuel (e.g. size reduction or moisture reduction) will take place off-site
at the suppliers' facilities.
6.0 OVERVIEW OF SAMPLING PROGRAMS PROPOSED BY ST. MARYS
6.1 Air Samoling
The basic premise of any air sampling program is to obtain a representative sample of
the contaminant emissions from a source or facility. Unlike soil and water sampling, air
sampling typically requires that the pollutant be concentrated in order to make it
quantifiable. With air sampling the contaminants are usually extracted from the air,
either onto a filter (e.g. particulate, metals) or into a chemical solution (e.g. dioxins and
furans). St. Marys is proposing an air sampling program that includes source and
ambient sampling as set out below:
Source Sampling (Samoling within the Stack)
Direct sampling of a source (e.g. the stack venting the cement kiln) is performed in
order to obtain an accurate determination of the emission of contaminants from a
specific source. This sampling provides results that can be used with complex modelling
to estimate the concentration of the contaminants at a receptor point (e.g. the property
line of the facility, or a nearby house) from this source. Source sampling usually takes a
fraction of an hour to a few hours. Detailed methods developed by the Canadian or
United States governments outline exactly how this is to be performed for the
contaminant in question.
Ambient Sampling (Sampling in the Environment)
Ambient sampling is the collection of a contaminant away from a particular source(s)
(e.g. the property line of the facility, or at a nearby residence). Ambient sampling
provides the actual exposure to a contaminant at a receptor; however, on its own, it
does not tell you where the contaminants came from. The contribution from a particulate
source to the measured ambient concentration can be determined by placing additional
ambient samplers upwind of the source and first sampler.
Contaminant concentrations at an off site location are expected to be very low in
comparison to the concentration at a source, therefore ambient sampling usually lasts
REPORT NO.: PSD-023-09
PAGE 7
for longer periods of time (10 hours to 30 days) in order to obtain a sufficient sample. As
with source sampling, detailed methods developed by the Canadian or United States
governments outline exactly how ambient sampling is to be pertormed .for the
contaminant in question.
6.2 Raw Material and Fuel Sampling
The raw material feed into the kiln, the conventional fuel (petcoke) and the alternative
fuels will be sampled three times each day when they are being used during the
demonstration test. A specific sampling. protocol will be followed to ensure that
representative raw material and fuel characteristics are recorded for the demonstration
project.
6.3 Noise
Noise measurements will be taken during the demonstration project to determine if
there are any incremental noise impacts associated with the alternative fuel feed
system.
7.0 COMMENTS
7.1 St. Marys demonstration project would provide them with site specific information to
support their research and theoretical analysis that burning alternative fuels will have no
effect or reduce their current emissions. St. Marys anticipates that they should be able
to reduce their cost, non-renewable resource footprint and green house gas emissions
by using residual waste products for up to 30% of their fuel.
7.2 While these are anticipated benefits the proposal by St. Marys to use alternative fuels
changes their current operations to also include the processing of residual .waste. As
such, the Municipality's comments to MOE have included the requirements that the
applicant apply for a temporary zoning by-law for the demonstration project.
Staff are prepared to support an application from the St. Marys for a temporary zoning
approval for the duration of the research demonstration project (40 days).
Should St. Marys demonstration project be successful, they would be required to
complete an Environmental Assessment under the regulations of the EA Act and EPA
Act for the. use of an alternative fuel on a full-time basis. At that time the Municipality
would require St. Marys to seek approval on a permanent basis for the operation
through an Official Plan amendment and Zoning By-law amendment.
7.3 Staff have met with representatives from St. Marys Cement to discuss the need for a
temporary Zoning By-law amendment for the demonstration project however an
application has not been filed to date.
REPORT NO.: PSD-023-09
8.0 CONCLUSIONS
8.1 The Municipality encourages St. Marys to meet with Staff and
consultation and planning applications for the temporary zoning
approvals.
PAGE 8
begin work on their pre-
by-law and site specific
Attachments:
Attachment 1 - Letter/Council Resolution to Municipality of Clarington
Attachment 2 - Kiln/Precalciner
Interested parties to be notified of Council and Committee's decision:
Tesfaye Gebrezhi
Andrew Neill
Wilson Little
Martin Vroegh
Phil Dunn
Glenda Geis
Attachment 1
To Report PSD-023-09
Energizing Ontario
November 25, 2008
Tesfaye Gebrezghi, Supervisor
Environmental Assessment and Approval Branch
Ministry of Environment
2 St. Clair Avenue West
Floor 12A
Toronto, ON, M4V 1L5
Dear Mr. Gebrezghi:
NOU 2 8 20D8
MUNiCIPAtITY OF GLAF,i1hGT014
RE: ST. MARYS CEMENT FOR AN At.TEP,P;ATI`JE f=t1EL
DEMONSTRATION PROJECT
FILE NO.: E05.GE
At a meeting held on November 24, 2008, the Council of the Municipality of
Clarington passed the following resolution:
"THAT the Ministry of Environment be informed that, with regard to the
Application as amended by St. Marys Cement for an Alternative Fuel
Demonstration Project at the Bowmanville Plant, MOE Reference Number
0349-7K2LHZ, the comments of the Director of Planning Services as set
out in his letter of November 3, 2008 to Mr. Martin Vroegh with regard to
compliance with the Municipality's Zoning By-law and applicable
provisions of the Planning Act have not been addressed to the satisfaction
of the Municipality at this time."
~rfie; CMO
Clerk
PLB/ta
cc: A. Neill, Senior Waste Engineer, Ministry of the Environment
David Crome, Director of Planning Services ~,.
Dennis Hefferon, Solicitor
CORPORATION OF THE MUNICIPgLITy pF CLARINGTON
40 TEMPERANCE STREET, BOWMANVILLE, ONTARIO L'IC 3A6 T 905-623-3379
Ef*ergtzing ~+n+wrlo
November 3, 2008
Pr",a; ti~~; l'rcagh
Environment Manager
St. Marys Cement Inca
410 Waverley Road So! nth
Bowmanville, ON L1C 3K3
RE: APPLICATION FOP. APPROVAL ~F'~"v'ASTE DISPOSAL SITES,
ALTERNATiV~ FUEL DEMONSTRATION FRO~tECT, BOLrttMANVILLta ST.
MARYS PLANT
PzFiOE REFERENCE Nl~M1=ER 0349-7K?i cal
VVe are strongly encouraging St. Marys' to schedule apre-consultation meeting with the
fviurucipal Staff to review the issues outlined in our (sitar of October i T" to the MinictrY of
Environment regarding the land use issues related to the alternative fuels demonstration.
St. Marys has been aware since early su~"i~mer that the Municipality of Ciarington has
concerns and the St. Marys prnjeCt team has been advised at meetings on September
2"d, and again en October turn to schedule pre-consultation. This is in addition fo the
ens-on-one discussions vvifh members of your project team and staff. The need for pre-
consultation was reiterated to your consultant, Mr.. Brian Zeman again on October 28'n.
Thank you far providing a complete oo~y of the Certificate of Approval application which
we received on Thursday, October 305. It virll assist in the Prlunicipality's assessmert of
whether the residual materials to be used as alternative fuel constitu±e >vasfe for the
purposes of the Environmental Protection Act
In Section 2 of the application it stales:
Based on review of fhe project description, it is St: Marys' opinion That
no Planning Act approvals are required. t'he use of iris r@Sldla!
material for a portion of its feet for the cement manufacturing plant is not
a change in land use; and, even if the burning of a fuel were to be
considered a land use, it is still permitted as an accessory use to the
prfncinal Lase,
This statement was made without prior consultation with the Municipality regarding the
interpretafian of the "~untcipality'S Zoning By-la~~: and applic^h~ prny,^gtnn3 Of tia
Ftanning ACt. I am 3Ure thct yoU are aLNare from Cur meson On e o u`~ tied
f:~:,'nicipal.y.E.tr^vfigly di$a^r€e9 `JViti s f~^ s„ ,,.„ s ~ OCfCb„r 14 that tale
y h S~. riary5 S~atcniEni. ~n she iviCiniCip8liiy'S ylewihe
proposed use of any part of St. Marys (and for the purpose of transporting or sterinn
waste fhn P1 permits{dh s de~rrtfle~+Municipality's Zoning By-law. The Municipaiiiy has
nor'f e ~ • i• 'et I pr., a IOn and Our fop
sated (but unsu~ccessfulj attempts to
have pre-consultation of this matter. In fact, a copy of our fetter to the Ministry dated
October 17 'was sent to you.
~, ~ ,
40 TEM
CARP ORATi O,y ~OF TY,E MUN{CIRALiTY f~E CLARiNGTOi<1~ ~,~
4ANCESTREET, BOWM1dANVILLE, ONTARIO ~L1C 3A6' T 905-523-3379
A Certificate of Approval for fhe alternative fuels project under Section 27 of the
Envirognm~ntal Protection Act does not override the provisions of the Municipality's
ZGmn B -law. Rather it is our un..erstanding ±hat ir. Section 12 of applications for a
Provisional Certificate of P,pprova! for a waste disposal site the proponent is required to
.r•.xlude a copy of munixipai p{alining appfGVa{.
Further, we understand That the Ministry includes a condition in the Provisional
Gerf{fixate of Approval that Lnfcr~;~s the ov/~ier Gf the ste that the requirements of tfia
certificate do not relieve or inhibit them from complying with any other legislation,
statutes, or legal obligations.
The example below {s taken frorn FCofA &"x05-6Z&JivJ, issued to Miller iNaste for fhe
Claringten CempGSt Facility:
a•0 Dther Legal Dbl{gallons
4.1 The issuance of, and compliance with, this Certificate does not:
a) relieve any persGn of any Gbligation to comply wiih any prevlsiGn of any
applicable statute, reg~~!ation or ether legal requirement;
Conc{us{on
The R lunic;oality, therefore, is xenxerned That if Si. A4arys undertakes its proposed
alternative fuels project the provisions of Zoning By-law 84-63 which apply to all persons
in the Municipality including St. Marys, necessarily will be breached.
'tNe would be happy to facilitate a meeting between our Development Review Planning
Staff and your consultant as the necessary pre-consultation step for the land use
approvals required.
Yours truly,.
6~ ~ ! 9~--
David J. Crome
Cuexfor of Planning Services
fsh
Cc: Mr. Tesfaye Gebre~ghi, P~inistry of fhe Env;ronmert
Mr. Brian Zeman, Mi-tBC
Attachment 2
To Report PSD-023-09