[This is the first in a three-part series]
In 2017, Environment Minister (now Premier) Iain Rankin approved Lafarge Canada’s proposal for a one-year pilot project to burn scrap tires in its 55-year-old cement plant in Brookfield near Shortts Lake, about 13 kilometres south of Truro. The company is part of Switzerland-based LafargeHolcim — a global giant in the production of cement and aggregates with revenues in 2019 exceeding $27 billion.
Cement manufacturing is a booming industry, but also an energy-intensive one, responsible for 7% of world-wide CO2 emissions. The industry claims that replacing conventional fossil fuels like coal and petroleum coke with “alternative” or waste fuels is a good way of greening cement. The company claims the fuel is “cleaner” and has the “potential” to lower its greenhouse gas emissions by 30% for every tonne of coal replaced and could also result in a 10-15% reduction in nitrogen oxides — gases that contribute to the production of smog and acid rain. 1
The plan to use tire derived fuel (TDF) at the Brookfield plant involved injecting 350,000 tires a year (6,000 tonnes) — 15% of the kiln’s total fuel input — into a cement kiln where they would, according to Lafarge, “combust faster than the eye can see” in a 1,450 degrees Celsius inferno.
Lafarge had already been burning “alternative” fuels as a way to “decarbonize cement” at the Brookfield plant. An industrial approval granted in 2005 allowed the company to burn glycerine, used waste oil, and solid shredded wastes (SSW) such as plastics and chipped asphalt shingles. In 2017, the company said these provided up to 30% of its fuel needs and that scrap tires would “increase the use of lower carbon fuels” to almost 50%. 2
When it comes to human health or the environment, Lafarge says the effects of burning tires would be “beneficial to benign,” with “no significant adverse effects other than a slight increase in truck traffic.”
Not only was Rankin’s 2017 decision to approve the plan deeply disappointing to many opposed to the idea, it was also a radical departure for the government.
For years the prospect of diverting scrap tires away from socially and environmentally acceptable recycling and engineering applications had been met with vociferous public opposition including from the Citizens Against Burning Tires (CABOT) and the Ecology Action Centre. Both argued that burning tires and other waste fuels, rather than recycling them, would increase hazardous pollution, and would not reduce overall GHG emissions from a life-cycle analysis (LCA) approach, undermining the real progress that needed to be made to fight climate change.
The pushback from citizens was also fueled by the fact that Lafarge would be paid for burning the tires. A portion of an environmental fee ($4.50/tire) collected by Divert NS from Nova Scotians when they purchase new tires would be given to Lafarge, amounting to a de facto fuel subsidy for the cement giant.
Fast forward to today, Lafarge receives $1.07 for every tire it burns and between August 2019 to December 31, 2020 (the most recent data available) the company was paid $410,199 to burn roughly 390,666 tires. 3
Rankin’s decision also seemed to strongly contradict the earlier advice the provincial government had received on the matter. In 2006, when the Resource Recovery Fund Board awarded a contract to Lafarge for processing 900,000 used passenger tires as TDF, a proposal that was conditional on approval by the NSE, the public outcry led the government to commission two reports on TDF.
The first, by a group of engineers led by Michael Pegg at Dalhousie University, found that studies on emissions using TDF showed “significant variation,” and also pointed to the potential increase in dioxins and furans, carcinogens that bio-accumulate and are akin to biological hand grenades.
The second report was written by an Advisory Committee that was established to evaluate the available management options for used tires in the province; it ranked TDF lowest on a list of 13 options, citing health and safety issues involving stack emissions, landfill emissions, and groundwater contamination. 4
In a news release at the time, environment Minister Mark Parent said he did not anticipate the use of TDF in the province in the “foreseeable future.”
Lafarge’s plan needed something to lend it credibility. Sometime around 2007 Lafarge “partnered” with Dalhousie University engineers — including Mark Gibson, an associate professor in the Department of Civil and Resource Engineering at the time. In its literature, Lafarge refers to the university as an “independent partner” and the researchers’ work in support of scrap tire-burning as “independent science,” but as we’ll see, the claims were shy on accuracy.
Furthermore, documents obtained by the Halifax Examiner through a Freedom of Information request reveal that senior government scientists within Nova Scotia’s Department of Environment (NSE) raised serious pollution-related questions and concerns about Lafarge’s 2017 EA registration document — but the project was approved anyway.
‘Poorly written, baseline testing not defined, air dispersion modelling unclear’
According to documents obtained by the Halifax Examiner, in 2016, Lafarge’s Environment Director, Robert Cumming, approached NSE about a plan for a one-year pilot to burn TDF in order to “confirm” the company’s “understanding” that an environmental assessment was not required for the project.
Cumming thought it would qualify instead for an NSE “Pilot [Operating] Approval process.”
But a few months later in an email to Jeffrey Parks, the environmental assessment specialist with GHD, the consulting firm Lafarge hired to work on the proposal, the province’s environmental assessment officer Bridget Tutty said that NSE had decided a Class 1 EA would be required and that the process “will determine if the provided information is sufficient to understand the potential impacts of the project.” 5
Class 1 “undertakings” are usually “smaller in scale” and require the proponent to submit a registration document which then undergoes a short public review period, as well as an internal review. Depending on how this goes, the minister can require that more details be provided through a “focus” report before anything is approved.
But internal Department of Environment emails obtained by the Examiner reveal that the EA process in this case did not actually guarantee that the proponent would have to publicly disclose all the pertinent information, or all the potential impacts for that matter, or how they would be mitigated against.
A quick aside here is necessary to define some terms.
Every year Lafarge has to submit a “stack test” report so the company hires a third party testing agency that puts probes into the kiln stack to sample emissions, which are then sent to a lab for analysis. Using a mathematical simulation called air dispersion modelling, it’s possible to input the stack test results into a model, along with other parameters like stack height and weather data, to see where the emission plume would land downwind of the stack and in what concentrations. These concentrations can then be compared to regulatory limits. So the composition of the fuels being used during the stack test is an important piece of the puzzle.
If, hypothetically, Lafarge burned 100% petroleum coke for the baseline testing, then pretty much anything would likely come out burning “cleaner,” even scrap tires, since petcoke, a byproduct of oil refining, is probably the filthiest fuel source around.
Sharon Vervaet, a government scientist in NSE’s Industrial Management Unit, and Kathleen Johnson, in the department’s Inspection, Compliance and Enforcement division, reviewed Lafarge’s plan and noted a number of errors, inaccuracies, and missing information.
In particular, Vervaet and Johnson pointed to a section of the registration document that identified the stack testing that would be conducted during what are called “baseline conditions” – in this case, without tires – followed by stack testing after the TDF system was commissioned. But the scientists noted that Lafarge did not specify which fuels would be used during baseline conditions and that, “The proponent should define baseline conditions.”
The internal government reviewers also noted that for Lafarge’s 2017 EA registration document, GHD used Lafarge’s stack test report dating back to 2010 to generate the air dispersion modelling emissions for the majority of air contaminants, but again, did not indicate what fuels were being used, something the reviewers said, “the proponent must identify.”
According to NSE spokesperson Barbara MacLean, Lafarge was required — prior to the pilot study being approved — to disclose the percentage fuel mix that would be used for “baseline testing,” but it’s unclear if the same was required of the 2004, 2010, or 2014 stack tests, all of which she says GHD used in the EA registration document for the air modelling. None of the additional information appears to have been made public.
Asked by the Examiner about the percent composition of the fuel mix Lafarge was currently using, Robert Cumming replied that the company’s “specific fuel mix is trade confidential.”
During the review period, NSE also received a letter from a person whose name was redacted in the documents obtained by the Examiner. But the person claimed to have “direct experience” working in management and quality control in the cement industry.
That person pointed to a lack of information in the registration document about the potential for the injection of whole tires to “destabilize” the operation of the kiln, leading to higher emissions through the kiln stack or the creation of more cement kiln dust (CKD).
“Many jurisdictions only allow rubber tires as fuels if they are first shredded and delivered into the front-end of the kiln where other traditional fuels are added…Kiln instability will often overwhelm electrostatic precipitators and render them ineffective thereby releasing excessive contaminants into the environment uncontrolled,” the person wrote.
It is also well known in the industry that emissions can increase during start up or shut down of the kiln, incomplete combustion, or a kiln “upset.” Large emissions of persistent, carcinogenic, and neurotoxic compounds such as dioxin and furans, polycyclic aromatic hydrocarbons (PAH), and volatile organic compounds (VOCs) are associated with these events.
The Lafarge plant has a history of pollution incidents — a subject we’ll return to in Part 2 of this series — and it would have been prudent to include the potential for this in the EA document. But only potential emissions under normal operating conditions were reported.
Darrel Taylor is a senior water quality specialist in the Sustainability and Applied Science Division of NSE. The documents obtained by the Examiner reveal that Taylor pointed to Lafarge’s omission of any potential impacts of the project on surface water, including Shortts Lake, which is the nearest body of water, and is assumed to be fish/ aquatic life habitat.
In 2015, research by St. Mary’s University graduate student Jocelyn Kickbush analyzed the mercury, arsenic, and selenium concentrations in the tissue of four fish species found in Shortts Lake, including gaspereau, smallmouth bass, chain pickerel, and white perch.
Kickbush found that mercury and arsenic concentrations “in many individuals of all four species” from the lake exceeded the World Health Organization (WHO) daily tolerable intake limit. 6
At elevated levels, mercury can cause significant damage to the human central nervous system. Kickbush pointed to the nearby cement plant — 100m from Shortts Lake — as “an important potential contaminant source.”
In his review, Taylor stated that “concerns regarding potential impacts to Shortts Lake, including water quality and fish related impacts, were expressed during public consultations,” suggesting that the concerns warranted mention in the proposal itself.
And yet, there appeared to be no requirement for Lafarge to address these concerns.
Taylor also noted there was no mention of municipal or public drinking water supplies, and whether these exist down-gradient in the watershed. While Taylor acknowledged that surface water related protection measures and monitoring were included in the company’s industrial approval, “no assessment of surface water impacts has been provided in the report to support these measures.”
It would be prudent to include such information related to any potential impacts from either air emissions or any changes in process or waste materials such as ash or slag resulting from TDF use, and to propose suitable mitigation measures and/ or monitoring programs as may be needed.
The Examiner asked NSE why Lafarge was not asked to provide further information with regards to potential impacts to surface water, for instance, given this was recommended by one of the department’s own reviewers, and given it was a concern raised on numerous occasions during the public consultations?
MacLean, replied, but didn’t really answer the question:
Our staff work to assess projects and provide advice with the best science available. These comments and observations were taken into account through the requirements of the pilot to provide pre and post data and interpretation. Continuous monitoring of stack air emissions is required as well as pre and post surface water monitoring. These measures will determine what if any impacts to surface water may result from the project. The requirement for surface water monitoring is detailed in a condition in the Industrial Approval.
Given there were aspects of the project that were unresolved, as well as potential for adverse effects, it was well within Rankin’s discretion to ask Lafarge to provide a focus report.
But instead, Rankin approved the project with conditions.
Is Dalhousie “independent”?
As previously stated, Lafarge described Dalhousie University as an “independent partner” and the researchers’ work in support of scrap-tire-burning as “independent science.”
But between 2007 and 2017, the year Lafarge’s proposal to burn TDF was approved by Rankin, Lafarge paid in excess of $80,000 for Dalhousie University research on the use of asphalt shingles, waste plastics, and scrap tires as alternative fuels, including $18,000 towards Mark Gibson’s 2015 study, which gave Lafarge’s plan the credibility it needed for approval. 7
The funding from Lafarge was not disclosed in Gibson’s study, and the study was not peer-reviewed. Gibson has publicly stated that Lafarge funds were never directly paid to him.
At the time, Gibson was an associate professor at Dalhousie’s Department of Civil and Resource Engineering. The Lafarge funds helped Gibson secure a further $125,000 over five years from the National Science and Engineering Research Council (NSERC).
As well, as of September 2017, Lafarge Canada was listed as donating between $250,000 and $499,000 to Dalhousie University.
In 2007, Gibson was also a member of the group that advised Environment Minister Mark Parent and ranked TDF lowest on a list of 13 options for scrap tires, most of them involving recycling. At the time, Gibson thought the recycling options were a better choice than TDF.
But in an interview with the Halifax Examiner, Gibson said his thinking has since changed based on “the urgent need to reduce the carbon footprint of cement production to help combat climate change and to improve air quality emissions from the Brookfield cement plant.” Gibson also said that using scrap tires as fuel “provides a consistent, predicable and reliable additional option for waste tire manage in Nova Scotia.”
In his 2015 study, Gibson predicted what the “theoretical” emissions would be from Lafarge’s kiln stack if the company burned 30% scrap tires by conducting combustion tests using a tube furnace in his Dalhousie University laboratory. He measured the emissions from each fuel source: tires, coal, and petroleum coke. 8
Gibson said he also sent samples of the coal, petcoke, and tires to an independent lab that did a chemical breakdown of the chlorine, carbon, hydrogen, nitrogen, and sulphur.
“Knowing these results and knowing the kiln operating characteristics and the kiln feed material used to make clinker one can estimate the resulting emissions of these chemical compounds,” explained Gibson.
“If you line those up next to each other you can see, when tires are compared with the coal-coke mixture we have a lot less sulfur…which is highly toxic when you breathe it in and it forms sulfuric acid, which is one of the components of acid rain.” * Gibson also said the tires contained less nitrogen and therefore emits less nitrogen oxides when burned.
Overall, Gibson’s study showed that, in theory, when 30% of the coal-coke fuel mixture is replaced with TDF there would be a 21% decrease in SO2, 23% decrease in NOx, and a 1% decrease in CO2 emissions from Lafarge’s kiln stack.
But the fuel analysis also found that tires contain about four times more chlorine than the coal-coke mixture. 9
“This is what a lot of the local community jumped on,” said Gibson. “They know that if you have chlorine in the fuel, it can form dioxins and furans in the kiln stack.” But Gibson said the amount of dioxins and furans that is produced is below the regulatory limit. More chlorine in the tires also means the emission of more hydrogen chloride (HCl), a toxic, corrosive, colourless gas. 10
Gibson now lives in Baltimore, Maryland and is President of Air Quality and Exposure Science at AirPhoton, and involved in airborne COVID-19 sampling of indoor spaces. He officially left Dalhousie University in August 2019 and now works as a consultant. He said in an interview that having an existing relationship with industry and access to an industrial facility, helped him to get the NSERC grant while at Dalhousie. 11
“That’s what they want to see when they give you these grants. If you have an industrial collaboration, then they see the value in the research you do. That’s when they give you the research funding.” 12
I asked Gibson about his current relationship with Lafarge.
“Lafarge didn’t want to lose the person who had been involved since 2006,” he responded. “And likewise I invested a lot of time in the projects and the research, but also with the community … So when Lafarge came to me and said, ‘We’d really like you to continue on this,’ we negotiated a contract.”
Gibson’s next “deliverable” to his client is to review the results of all the emissions testing programs that have been done to date: the baseline testing (without tires) was conducted in July 2019 and emissions testing with tires was done in October 2019 and again in October 2020. Even though the one-year pilot project officially ended in August of 2020, the company was granted a 14-month extension by NSE until October 2021 because of time lost time during their winter shutdown and delays due to COVID-19.
According to Lafarge’s Environment Director, Robert Cumming, “the purpose of the testing is to confirm the expected beneficial effects and to assess any other changes between operations with and without scrap tire use.”
Lafarge plans to share these results with the public in the spring.
Renowned toxicologist weighs in
In response to Rankin’s 2017 approval of Lafarge’s plan to burn tires in its cement kiln, five members of Citizens Against Burning of Tires (CABOT) filed an application for a judicial review arguing that the aging cement kiln was not designed to burn tires and that doing so would result in toxic emissions. They argued Rankin’s approval was “unreasonable” given the unknowns and the “strong potential for adverse effects” on surface water, groundwater, and human health.
In early 2018, CABOT requested that new evidence from an internationally renowned toxicology expert, Dr. Douglas Hallett, be admitted as part of the evidence.
To say that Hallett is renowned in his field is an understatement. His involvement as an investigator or expert witness in many high-profile contamination events in Canada and the US, including Love Canal and the Hagersville tire fire, have earned him celebrity status. His entire professional career has been spent assessing and testing the impact of toxic chemicals on humans and the environment.
Hallett is also no stranger to Lafarge’s tire burning aspirations. He was retained as an expert witness in the 2007 environmental review tribunal when the Loyalist Environmental Coalition, Lake Ontario Waterkeeper, and Gordon Downie and the Tragically Hip appealed Ontario’s Ministry of Environment’s approval of Lafarge’s plan to burn alternative fuels, including tires, at its cement plant in Bath on the shore of Lake Ontario. The Tragically Hip were involved because the cement plant was located near their recording studio.
Lafarge and the Ministry of Environment appealed the review, but the judge ruled in favour of allowing the tribunal to proceed. When the Tribunal’s review was set to begin, Lafarge decided to cancel the project, a move some argued was to avoid having to “subject the proposal to the scrutiny of an independent tribunal.” However, a source familiar with the case indicated it had more to do with the fundraising potential provided by the Tragically Hip.
In his affidavit for the Nova Scotia judicial review, Hallett argued that the conclusion that the Lafarge Brookfield project could be operated without significant adverse impacts or environmental effects was not based on accepted science or empirical evidence. He pointed to inadequacies in the air dispersion modelling as well as a lack of information on N-nitrosodimethylamine (NDMA) — both subjects we’ll be returning to in Parts 2 and 3 of this series.
But Hallett’s expertise had not only come late in the game, there was no real place for it in the Lafarge’s fast-tracked environmental assessment. The Class 1 undertaking did not automatically include a formal public review and hearing, which is where Hallett’s expertise could have come in.
As the Examiner reported here, Nova Scotia Supreme Court Justice Denise Boudreau rejected CABOT’s motion to bring forth any new evidence from Hallett and in 2018 Justice James Chipman denied the group’s appeal and upheld the minister’s decision saying it “easily passes muster and must be regarded as an outcome within the range of reason.”
Judge Chipman’s decision did not assess the merits of the science but it did send a message of warning to community and environmental groups who challenge the court on environmental matters when it awarded court costs of $5,000 each to Lafarge and to the Crown.
In Part 2, the Examiner will delve deeper into Mark Gibson’s study, GHDs air modelling, and Hallett’s revealing affidavit.
Cover photo: Lafarge Canada, Brookfield cement plant. Photo taken on a recent site tour of the facility during “winter shut-down,” when operations were on hold for yearly maintenance of machinery. Photo: Linda Pannozzo
- Lafarge has five cement plants in Canada: Brookfield (NS), Richmond (BC), Exshaw (AB), Bath (ON), and St. Constant (QC). According to Jessica Assaf, corporate communications for eastern Canada, “all five plants are either using or have permits to use either scrap tires or ‘tire fluff’ which is derived from scrap tire shredding processes.” ↩
- See page 7 of the “Consultation Report,” found here: https://novascotia.ca/nse/ea/lower-carbon-fuel-tire-derived-fuel/appendices.pdf ↩
- Total passenger-tire-equivalents (PTE) and revenue to date were provided by Carolyn Pierce, the communications manager with Divert NS. Pierce also says Lafarge is eligible to receive up to 30% of the available volume of PTE annually. Pierce says the last quarter (January to March 2021) has not been finalized/ completed yet. ↩
- See Table 4: Assessment of alternative options to TDF, on page 46. Each of the 13 uses of scrap tires was assigned a ranking from 1-4 (ranking criteria are explained on pages 19-20, but in essence 1 is the best and 4 the worst). TDF and pyrolysis were both given a ranking of 4. Pyrolysis is a highly energy-intensive process that melts the tires and recovers all the various components and then sells them. According to Mark Gibson, a China-based firm was interested in investing in a massive pyrolysis plant in NS. All the other options involved recycling the scrap tires, involved little if any industrial processing and therefore were deemed “safe” from an environmental and health/ safety perspective. ↩
- According to NSE, a Class 1 environmental assessment typically takes 50 calendar days of process time to complete. However, the assessment may be extended if the minister decides that more information — a focus report or environmental assessment report — is required. The amount of time it takes the proponent to prepare the registration document will depend on the complexity of the undertaking and the amount of information already available. ↩
- Kickbush also analyzed the contaminant levels in fish in Morris Lake in Halifax County and found mercury and arsenic levels in fish there also exceeded WHO daily tolerable intake limits. In her study she noted that Morris Lake is approximately 3km away from the Imperial Oil Refinery, “a regionally important contaminant source.” ↩
- According to Dalhousie spokesperson Janet Bryson, this is how Lafarge funding between 2007 and 2017 broke down:
- Gibson used a Tropospheric Emissions Monitoring of Pollution (TEMPO) remote sensing package. ↩
- Based on Exova lab’s analysis of the fuel sources, Gibson’s study reported that used tires contain 752mg/kg of chlorine compared to 183 mg/kg of chlorine in the 50-50 coal-coke mixture. ↩
- Citing Carrasco, et al., Gibson noted that HCl could be suppressing the formation of dioxin and furans, and even though it’s at higher levels, is still within environmental standards. Carrasco, F., N. Bredin and M. Heitz (2002). “Gaseous contaminant emissions as affected by burning scrap tires in cement manufacturing.” Journal of Environmental Quality. 31 (5): 1484-1490. ↩
- Gibson is currently a registered Professional Environmental Engineer with Engineers Nova Scotia, a Nova Scotia Registered Professional Chemist, a Chartered Scientist (UK, Science Council) and also a qualified Chartered Chemist (UK, Royal Society of Chemistry). ↩
- Over the last 20 years, lucrative alliances between universities and industry have become ubiquitous features on campuses across the continent. There are incentives for university researchers to seek out private funding, as they are often matched by federal or provincial funds. But industry–university partnerships are fraught with ethical considerations: Does the funding subvert academic freedom? If funding is contingent on commercialization potential, then what happens to basic science and unimpeded scientific inquiry? If researchers have no choice but to align themselves with industry partners in order to get funding, then who is doing research in the public interest? ↩