Northern Pulp mill during a shutdown in October 2o18. Photo: Joan Baxter

Wastewater from Northern Pulp’s mill is being discharged into the Bay of Fundy.

Since July 2020 Northern Pulp has been shipping run-off and “landfill leachate” from its hibernating pulp mill site on Abercrombie Point in Pictou County to Colchester County’s municipal sewage treatment facility in Lower Truro, which discharges into the Bay of Fundy.

Invoices obtained through a Freedom of Information request show that between July 2020 and June 2021 Northern Pulp shipped more than 25 million litres of its wastewater to the Central Colchester Wastewater Treatment Facility (CCWWTF).

Central Colchester Wastewater Treatment Facility from promotional video.

Northern Pulp has paid the Municipality of the County of Colchester more than $800,000 for handling all that wastewater, much of it exceeding municipal by-law limits for chemical oxygen demand, or COD, a measurement of pollutants in wastewater that is critical for accurate modelling of how effective an wastewater treatment process has been.

A promotional video for the Lower Truro treatment plant says it handles “sewage from 40,000 people every day,” serving “communities from Hilden to Millbrook, the town of Truro, Valley and Bible Hill, and from as far away as Kemptown,” about 32 kilometres from the facility in Lower Truro.

There is no mention of industrial wastewater from further afield.

Google map showing location of CCWWTF in Lower Truro.

The Municipality that owns the treatment facility has been remarkably quiet about its agreement to dispose of Northern Pulp’s industrial wastewater.

In 2013, when the public learned that the Municipality was planning to dispose of fracking wastewater in its Debert sewage treatment plant, there was widespread public outcry that eventually led to Council passing a sewer-use policy that banned the disposal of waste from hydraulic fracturing in municipal sewage treatment plants.

In contrast, there has been no public outcry at all about Northern Pulp using the facility to dispose of its industrial wastewater. Then again, there has also been precious little public information about the arrangement.

Media coverage of Northern Pulp’s wastewater being trucked to the Central Colchester facility for treatment has been so scarce that it has attracted almost no public attention.

Behind closed doors

A short article by Maurice Rees in the April 2021 edition of The Shoreline Journal reported that at the “March 11th committee meeting council Michelle Newell’s Public Works directors [sic] report included a mention” of the arrangement with Northern Pulp that allowed it to send wastewater “from their sewage lagoon, pulp mill and leachate from pulpwood storage” to the Colchester facility.

Google map showing Northern Pulp mill site on Abercrombie Point, Pictou County, Nova Scotia.

Rees also reported that then-Councillor Tom Taggart — now a Progressive Conservative MLA — asked Newell how much the Municipality received for handling the wastewater, and she replied that Northern Pulp had paid about $40,000 a month for the wastewater disposal.

Rees also reported that the permit had been extended until December 31, 2021, “with compensation amounting to approximately $70,000/month which is derived from three truckloads per day.”

Council committee minutes from that March meeting show only that a report from the director of public works — Michelle Newell — was “circulated in the package” for the meeting, but provide no information on its content. After that, the meeting went into “closed session.”

In July this year, the Halifax Examiner emailed Michelle Newell (now Boudreau) asking for details about the deal, what the wastewater contained, how much was being disposed of, and the terms of the contract.

Scott Fraser, director of corporate services for the Municipality, replied that their “process” required a Freedom of Information (FOIPOP) request.

The results of that Freedom of Information request provide insights on how the deal came about, how the Municipality kept the matter out of the public eye, and show that Northern Pulp repeatedly exceeded limits of what was allowed in the wastewater it delivered.

It also appears that Northern Pulp has been telling different parties different things about the source of its wastewater.

Each of these merits a close look.

Northern Pulp seeks a new place to dispose of its wastewater

Northern Pulp representatives’ names are redacted in the correspondence released under the Freedom of Information request, but in one email, the Northern Pulp name that shows up is that of Bruce Chapman.

In documents submitted to the BC Supreme Court where Northern Pulp has sought creditor protection, Chapman describes himself as “general manager (Northern Pulp) of Paper Excellence Holdings Corporation, and general manager” of eight of the nine companies involved in that creditor protection case.

The first written record about the wastewater arrangement seems to be an email from Northern Pulp to Michelle Newell (now Boudreau), the Municipality’s public works director, and Don Cameron, wastewater treatment manager, on June 8, 2020, which reads:

As we discussed, Northern Pulp is looking for options for treating our rain water run-off and landfill leachate. Under the Ministerial Order (MO 60003), we must collect and send stormwater and landfill leachate for treatment…

The Ministerial Order had been issued on May 14, 2020 by then-Environment Minister Gordon Wilson to Northern Pulp, requiring the company to cease sending any wastewater from the pulp mill site to Boat Harbour by April 30. Northern Pulp was instructed to “ensure all potentially impacted stormwater and landfill leachate generated at the Facility is collected and transported to a facility that is Approved to treat the constituents in the wastewater unless otherwise authorized by the Department in writing.”

In other words, without Boat Harbour, Northern Pulp needed to find a new place to dispose of all its wastewater. In an email to the Municipality, the company wrote:

We estimate that the run-off will average three to four truckloads (a total of 90,000 to 120,000 litres) per week and the leachate will average 10 to 14 truckloads (300,000 to 400,000 litres per week), depending on the amount of rain that we receive…

As you can see from the test results, both streams meet the guidelines for the parameters we tested, except for the COD [chemical oxygen demand] of the leachate, which averaged 960 mg/l compared to the limit of 600 mg/l.

Asked how long Northern Pulp would expect to haul wastewater to Truro, the company replied:

… we will need to haul the rain water run-off for a period of weeks and the landfill for approximately a year …

The last new material was added to the landfill in April and we are in the process of qualifying capping material so we can cap the landfill. Experts tell us that we will need to haul leachate for a year after the landfill is capped.

Not only did Northern Pulp continue to ship its wastewater to the facility in Truro for months rather than weeks, but by the end of the 2020, it was asking for permission to increase the volumes and number of loads per day. But we’ll get to that.

First, there are some questions about how the first approval was granted.

Another secret meeting

On June 11, Newell wrote to Northern Pulp saying she had discussed the proposal with her CAO, and they would have to do a legal review and then pass it on to the Municipality of Colchester County Council at the next meeting on June 25, 2020.

Whatever happened at that Council meeting remains a mystery. There is no mention of the Northern Pulp deal in the minutes, and we can only guess that the “legal matter” that was dealt with in a closed session (the secret part of the meeting) was the company’s request to dispose of its wastewater in the Lower Truro sewage treatment facility.

The day after the meeting, Newell wrote to Northern Pulp saying that the Municipality would be willing to accept wastewater from its “Pictou site, pending the results of the remaining lab analyses.”

By this, she meant the lab results of the wastewater that Northern Pulp was to send.

Which brings us to the next mystery: If the samples showed the wastewater was not suitable for treatment in the facility, why was Northern Pulp allowed to go ahead with the deliveries?

Testing the wastewater

On June 26, Northern Pulp wrote to Newell to say the company was “sure” it would “be able to work out an arrangement which is mutually beneficial.” The company also told her that it had “collected samples” of the wastewater and “forwarded them to a lab.”

On June 30, 2020, Northern Pulp sent the results from two sources of what the email referred to benignly as “water” that the company would be sending to Truro for treatment.

The email said the two sources were from the “forebay,” namely the mill yard and stormwater collection, and that the company was still waiting for the results from Bureau Veritas labs of samples it had taken from the landfill leachate.

On July 9, Don Cameron, the wastewater treatment manager, replied to Northern Pulp that the Municipality had tested the samples itself for Ultra Violet Transmittance (UVT), and that the result was “not good.” UVT is a water quality test that measures the amount of UV light that can pass through a water sample. Wrote Cameron about the Northern Pulp wastewater:

The leachate sample was 0% and the run off sample was 13.2%. The normal limit we have imposed on corporate customers is greater than 45%. We may be able to dilute this out with other incoming waters in our sanitary sewer but won’t know until we try a load.

Northern Pulp suggested a trial load be the next step.

Central Colchester Wastewater Treatment Facility UV tank.

Apparently that trial load satisfied Cameron. On July 17, he wrote to Northern Pulp:

After discussions yesterday and reviewing data from the load delivered this week, we are prepared to do a week long trial. Our understanding is that would amount to 7 loads of leachate and possibly some of the run-off water as well. If at any time we have trouble treating the leachate we will ask that deliveries stop and a decision be made as to our ability to handle the product.

Deliveries can be made from 7:30 am to 3:00 pm so unloading can be complete by 4:00 pm … Any analysis you do on these products we would appreciate if you share your results with us.

On August 4, Newell wrote to Northern Pulp to say that there were “parameters” missing in the data the company had sent to her, meaning data that were required by the municipal by-law governing wastewater treatment in the facility. On the same day, Newell also issued an official approval for Northern Pulp to continue to ship its wastewater to Truro until the end of 2020.

The approval set the allowable amount of wastewater at 100 cubic metres (100,000 litres) per day, although higher volumes could be permitted with prior approval of the wastewater treatment manager.

Deliveries were be made between 8am and 3:30pm on weekdays only, and the cost would be $30 per cubic metre, or $0.03 per litre.

The approval also permitted Northern Pulp to exceed the discharge limit for chemical oxygen demand (COD).

However, in accordance with the Municipality’s sewer use by-law and policy, the approval stipulated that Northern Pulp abide by this “extra-strength wastewater discharge agreement” and that:

COD must not exceed 3,000 mg/L [milligrams per litre] at any time. A surcharge rate of $0.385 per kg of COD will be applied for amounts exceeding the By-law limit of 600 mg/L.

Northern Pulp fails to abide by the limits

It didn’t take Northern Pulp very long to break that rule.

On September 10, Don Cameron wrote this to Northern Pulp:

The COD for your wastewater has climbed in September ranging from 3430 mg/L to yesterday’s 6590 mg/L. Our agreement clearly states we will not accept water with a COD over 3000 mg/L. Please advise how you will correct this going forward.

Northern Pulp replied that it was “not aware the COD jumped up…” The rest of the sentence is redacted from the documents obtained by the Examiner. Then, “We will take corrective action immediately and add more Forebay (stormwater) wastewater to dilute the tanker truck loads prior to delivery.”

Not keen on media coverage

But perhaps the most confounding issue about this arrangement with Northern Pulp is the secrecy that seems to shroud it. Not only was the arrangement never discussed in a public session by the Municipality of the County of Colchester Council, it also appears that pains were taken to keep it out of the media.

Take, for example, this November 2020 email from the public works director to Northern Pulp:

I was asked by my CAO [Chief Administrative Officer of the Municipality of the County of Colchester] about an article on allNovaScotia referencing the shipment of your wastewater to our plant in 2021. Can you advise as to how that information came to find itself online?

Northern Pulp replied:

With respect to AllNovaScotia, I believe they reported on the most recent report of the Monitor (Ernst & Young, or E&Y) on our Companies [sic] Creditor Arrangement Act (CCAA). In the report, E&Y reported on the various activities at the mill, including the shipping of wastewater. The report (Fourth Report or [sic] the Monitoring October 30 2020) can be found on the E&Y website …

The report did not state that we have a contract for wastewater for 2021. It stated that we have been shipping wastewater to you and that we may have to work on either onsite treatment or shipping more wastewater in 2021.

Contradictory stories

Since June 2020, Northern Pulp — a Paper Excellence company that is part of the global corporate empire of the billionaire Widjaja family of Indonesia — and eight of its affiliates have claimed to be insolvent and been under creditor protection in the BC Supreme Court, which the Halifax Examiner reported on here, here, here, and here.

Documents revealed as part of the creditor protection case in the BC Supreme Court can be illuminating, not just because at times it appears that Northern Pulp is misleading the court, but also because they indicate there are contradictions between what the company says it is doing, and what it is actually doing.

The relevant section, “BH [Boat Harbour] Operations & Decommissioning Plans,” of the BC Supreme Court Monitor’s Report to which Northern Pulp referred in its email of November 3, 2020 to Newell is a case in point, and if accurate, also worrisome.

The Northern Pulp effluent pipeline before it was decommissioned and Boat Harbour closed to pulp effluent. Photo: Joan Baxter

The report indicates that the wastewater being treated in Truro is not just from the mill site, but also coming from the mill’s former effluent treatment facility in Boat Harbour, something that was not included in the approval or discussions with the Municipality.

This is what the 4th Monitor Report says:

Wastewater – the Petitioners have entered into a contract with the Municipality of Colchester to dispose of wastewater from BH [Boat Harbour] through the Colchester Treatment Facility in Truro, Nova Scotia. The Municipality of Colchester post filing waste water treatment contract provides financially favourable terms compared to the anticipated costs for such services incorporated within the original budget. Throughout the summer of 2020, the Petitioners successfully consumed significant volumes of water through irrigation of Mill grounds; However, with respect to 2021 planning, the NSE [Nova Scotia Environment and Climate Change] now requires the Petitioners to prepare a new plan for wastewater removal as forebay water (non-toxic water) is no longer allowed to be released into grass adjacent to the Mill. The Petitioners are currently working with NSE to find a practical alternative solution including onsite treatment options. [emphasis added]

Section 44 of the court’s Monitor Report also suggests that Northern Pulp wrangled a very favourable financial deal for itself when it convinced the Municipality to accept its wastewater in the Central Colchester Wastewater Treatment Facility:

Wastewater treatment is significantly under budget due to a) the quality of certain volumes of waste water being less contaminated than forecast which permitted the Petitioners [Northern Pulp and its affiliates] to successfully [sic] for irrigation; b) a dry Nova Scotia summer reducing the volume of rainwater needing to be captured; and c) the Petitioners securing a replacement treatment contract with the Municipality of Colchester on more favourable terms than the Mills [sic] original contractor had provided. 
[emphasis added]

The court Monitor Report does not mention managing possible mercury contamination around the former Canso Chemicals plant beside the mill, or the secure landfill on the site, in which mercury-contaminated materials were buried when the plant was decommissioned in the 1990s. Nor does it mention that at least until December 2018, Northern Pulp owned 50% of the Canso Chemicals plant, while the Olin Corporation of Canada owns the other half.

This is what the Court Monitor does say about Canso Chemicals:

  1. b) Ditching around Canso – Canso Chemicals (“Canso”) is a non-operating chemical chlorine facility located adjacent to the Mill. The core alkali plant at the Canso facility has been closed for a number of years; however, storm water runs between the properties. The Petitioners are engaged in ongoing discussions with Canso and the NSE to determine whether a ditch will need to be dug to ensure Canso run-off does not affect the Northern Pulp property. If a ditch is required, a request for proposal will be prepared and delivered to ditching design and installation bidders.

There is no mention of whether the storm water that runs between the mill and the plant site with its mercury-contaminated landfill is also being collected for hauling to Truro for treatment.

Northern Pulp ups the volumes

In late 2020, Northern Pulp began asking for a renewal of its contract.

The Municipality sent a renewed approval for 2021 in December 2020.

Then, in early January 2021, Northern Pulp wrote to say that with the “recent snow and rain” it was seeing an increase in the volume of wastewater it was collecting, and expected its “requirements to exceed the volumes in the current contract.” The request for approval of higher volumes of wastewater request came in an email with this obsequious line about the “relationship” between Colchester County and the company:

We appreciate our relationship with the County of Colchester and see our relationship as key to the operation of Northern Pulp.

In her reply, Newell noted that Northern Pulp had been delivering the wastewater outside of permitted times. In another email, she said the Municipality needed to review the request for higher volumes of wastewater because its leachate tank held only 180 cubic metres (180,000 litres), which would have to be the daily limit. She also wrote that the Municipality was concerned about “foaming,” as it would be “releasing the product at a faster rate than we usually do.”

Newell told Northern Pulp that she had reviewed the quality data and that from August to December, there were no entries for bismuth, a heavy metal that can have a range of negative health effects, and trichloroethane, an industrial chemical associated with numerous serious health problems, including several types of cancer. Newell informed Northern Pulp these had to be tested for in future.

In addition, she noted that in September and December 2020 the levels of suspended solids in the leachate exceeded the by-law limit of 300 mg/L.

Northern Pulp replied that these were “anomalies,” but the sentence that follows is completely redacted in the documents obtained by the Examiner.

Northern Pulp was permitted to go ahead with higher volumes as a trial run in January, which involved five truckloads per day.

On January 22, the company wrote to thank Newell and the “Colchester team” for allowing it to “reduce the volume of wastewater in our storage.”

On January 28, 2021, Newell sent Northern Pulp a renewed and amended permit for the entire year, which allowed the company to send 115 cubic metres (115,000 litres) of industrial wastewater into the Municipality’s public sewer system, with excess amounts permitted with prior approval. The hours were also extended to give Northern Pulp from 7am until 4pm to make the deliveries.

The approval also stated that the Municipality could, “at any time, collect and analyze samples of the wastewater being delivered” to its treatment facility, and could also do the same at the Northern Pulp facility.

There is no correspondence indicating that the Municipality ever collected and tested samples of the wastewater at the mill site, instead of relying on Northern Pulp to do so.

Nor is there any evidence that Nova Scotia Environment and Climate Change exercised its right to monitor the wastewater itself.

Who monitors the collection of samples?

The Examiner contacted Nova Scotia Environment and Climate Change for more information on the arrangement that allows Northern Pulp to dispose of industrial wastewater in a municipal sewage treatment system.

Spokesperson Rachel Boomer replied that according to Ministerial Order 60003 and then one that replaced it, MO 60006, Northern Pulp is still required to, “manage and dispose of landfill leachate and stormwater.”

As for the nature of the landfill leachate, Boomer said:

Landfill leachate is the liquid runoff from the industrial landfill located at the Northern Pulp Mill site. Northern Pulp is required to analyze the wastewater runoff and send the analysis to Environment and Climate Change quarterly, along with reports on ground and surface water. You are welcome to file a FOIPOP request to receive a copy.

Asked whether Nova Scotia Environment and Climate Change has been monitoring the composition of the wastewater, which Northern Pulp collects itself for analysis, Boomer replied:

The company is required to analyze the wastewater before it is sent to the approved facility, and must submit the results to us quarterly.

The Examiner also asked why Northern Pulp isn’t expected to have its own wastewater treatment facility on site. Boomer’s answer:

Wastewater is generated every time it rains. Our goal is to ensure the wastewater is properly treated, and that’s why the ministerial order requires it to be treated at an approved facility. At the moment, Northern Pulp does not have an onsite treatment facility, so they are required to dispose of the wastewater offsite. If they were to develop an onsite treatment facility, they would have to apply for an industrial approval. You would need to speak to the company about whether it is working on an onsite treatment facility and what the timing of that might be.

A pumper truck cleaning up brown wastewater from a break in the Northern Pulp mill effluent pipeline in 2018 during a mill shutdown. Photo: Joan Baxter

The Examiner sent the following questions to Sean Lewis, spokesperson for Northern Pulp:

  1. Can you tell me what the “landfill leachate” is, and what landfill it is coming from? What is in the landfill, where it is on Abercrombie Point, and when it was created?
  2. I understand that Northern Pulp needed to find an approved facility in which to dispose of this wastewater because of a Ministerial Order, following the closure of Boat Harbour. Would a new effluent treatment facility be used for this purpose? Will this disposal in the Colchester facility continue until Northern Pulp receives approval for / builds a new effluent treatment facility? For how much longer does Northern Pulp wish to keep using the Colchester facility?
  3. There are landfills on Abercrombie Point that contain mercury-contaminated materials and also asbestos. Is any of the leachate coming from these?

This is Lewis’ reply:

Northern Pulp has an engineered landfill on the mill property, south of the main mill complex. The landfill opened circa 1980 and is permitted under various Industrial Approvals issued by Nova Scotia Environment.  As per the permits, the landfill contains select residuals from the mill operations including primary sludge, fly ash, bottom ash, lime residues, and slaker residues.  It does not contain any municipal solid waste or material from other companies, including Canso Chemicals.

Water from the landfill, consisting of water from the materials deposited, precipitation, and surface run-off is called leachate.  As part of the permitted operation of the landfill, the leachate must be collected and treated.  In the past, this leachate was treated as part of the mill effluent that was treated at the Boat Harbour Treatment Facility.  Since the closure of the Boat Harbour Treatment Facility, the collected leachate has been treated offsite and will continue until a new advanced treatment facility is approved and operational.

Asbestos was a common building product until the 1970s and was used in some areas during the construction of the mill just as it was in other residential, government, and commercial facilities. As upgrades were done to our facilities, asbestos-containing material was removed and disposed of in a Nova Scotia Environment approved section on the north side of the landfill.  Consistent with Provincial requirements, a copy of the site plan indicating the location of the disposal area was submitted by Northern Pulp to the Registry of Deeds, with a copy of the registration being forwarded to Nova Scotia Environment.  Since the early 2000s, if asbestos-containing material was found in our facilities during upgrades, it was removed and disposed of at other approved disposal sites by licensed third-party contractors. No asbestos-containing material is produced at the mill and no asbestos-containing material has been added to the landfill for close to two decades.

There was no answer to the questions about mercury, or why Northern Pulp doesn’t have its own onsite treatment facility.

Asked by the Examiner whether he thinks industrial wastewater from Northern Pulp’s mill site should be treated in a municipal sewage treatment facility, a wastewater expert who asks to remain anonymous, was categorical.

“No,” he said.

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Joan Baxter

Joan Baxter is an award-winning Nova Scotian journalist and author of seven books, including "The Mill: Fifty Years of Pulp and Protest." Website: www.joanbaxter.ca;...

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13 Comments

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  1. Interesting. Although it is not like this is the only dilute industrial effluent being treated in municipal plants around the province. It would be valuable to report on the effluent from the Colchester treatment plant. If it is adhering to its discharge permit – if it’s working, – what more do you want? Without this information this reads like a witch hunt. All of Burnside Industrial park’s waste goes to the same treatment plant as domestic sewage in Halifax, and it’s almost certain that less treatment happens there than in Truro.

    And as for inputs to Municipal sewers exceeding the various discharge bylaws, well I’m sorry to tell you that because the limits in them are based on residential sewage strengths, it’s rare to find effluent from a restaurant, brewery, bakery, food processing plant, or butcher that complies. The same bylaws often have a clause that allows for an over strength levy. This is what appears to be the case here. Again, pretty normal.

    And with all the unscientific voodoo surrounding how modern Boat Harbour issues are treated in the media, is it any surprise they tried to keep it quiet? I don’t work in government, but I can’t blame them.

    So I have questions.

    1. What would you rather they do, other than legally pay to truck all this to where it can be properly treated? Walk away and let it run into Pictou Harbour untreated?

    2. Do you really think this is something special and uncommon?

    3. Where is the adverse impact that would cause NS Environment to act?

    4. The old practices at Boat Harbour were horrible. They were done by the Province. Not by industry. Why are we now so focussed on standing in the way of the industry trying to do the right thing?

    5. Was there testing done for Mercury? Mercury is scary.

  2. Great reporting as usual, Joan. It never ceases to amaze me what goes on behind closed doors.
    I fear for the future however with the political shift we have just witnessed and a Premier from Northern Pulp’s territory.

  3. There are those that confuse ” diluting ” with ” treating ” or “cleaning up ” . They are not the same . The same amount of emissions are being dumped in ” diluting ” .

  4. I never understood why the Colchester CAO granted approval for the Debert waste removal company to dump radioactive waste water into the County sewer system. Now we read ( thanks to Joan Baxter’s digging and reporting ) that yet another non sewage industrial waste is being pushed thru a plant not engineered for that purpose . Where is N S Environment in this ? Surely they knew about this waste and have turned a blind eye . As they have many times re Northern Pulp when it was operating and exceeding air and water emissions . Where is the sludge from this County plant being landfilled ? That sludge would have concentrated emissions in it including possibly mercury . By diluting and dumping the industrial waste into the Bay of Fundy the Country is breaking Federal law about dumping harmful waste into a Body of Water inhabited by a commercial fishery . What does DOF have to say about that ?

  5. The two senior municipal officials should now be directed by the Municipal Council to hold an accountability session so that members of the public can listen and ask questions. It would be helpful to see who signed off on all of this from the locals to those in the Dept. of Environment.

    Enough of this ‘it is the responsibility of NP to say what is in the effluent material’; it should be tested by provincial government chemists and NP should be billed for that. Local officials should also explain why they okayed this treatment of said material while one, un-named, expert said that such treatment should not be occurring. Some in the Dept. of Environment have clearly made the decision that it is okay to dispose of industrial waste water in the municipal facility as Maurice Rees’ closing in the cited article says the following:

    Department of Environment regulate the volume which can be added to the
    waste water treatment plant on {a} daily basis. April ,2021

  6. Fabulous reporting. Where do we go from here with this damming info that exposes Nova Scotia environment, the complicity if not corruption of the municipality and the tenacity of that pulp manufacturing company. With a conservative govt we have to be very alert and prevent this pulpscam company to start operations again. They should be shut down for ever.

  7. Why have paid civil servents if they work harder at work arounds than they do compliance?
    Thank you all for reporting in great detail on their lack of compliance. The money we spend to have them ignore their jobs!

  8. Great investigative journalism Joan. Thank you. Once we the public know what is happening we can act.