Compliance – Manufacturing
Canfor was in substantial compliance with regulatory requirements at its manufacturing facilities with the following exceptions:
A pellet plant twice exceeded permitted particulate limits during dryer stack emissions testing. We implemented a number of mitigative actions, including more frequent mechanical checks for leaks that could cause excess air flow through the stacks, a training program for dryer operators, and improved management of dryer operating temperatures.
One sawmill had a marginal particulate limit exceedance on an energy system stack emissions test. The system was shut down for inspection and cleaning, and passed a retest.
Another mill had a particulate limit exceedance on an energy system stack emissions test. An investigation showed the oxygen sensors were faulty, potentially allowing an excess draw of air into the energy system. The oxygen sensors were replaced, and the mill passed a retest.
Due to an oversight, one sawmill submitted a compliant energy system stack testing report two months after the required submission date. We are establishing compliance work orders through our maintenance system that will serve as a reminder and tracking tool to avoid a recurrence.
At a combined heat and power facility, high moisture content fuel and general fuel quality issues led to several carbon monoxide emission exceedances in February. Reducing biomass fuel from external sources, relying more on over-the-belt fuel generated by the adjacent sawmill, and other operational and fuel quality improvements appear to have resolved this issue.
At one mill, an escape of water occurred from a temporary holding area when a berm gave away. Water and sediment had been moved to the holding area by a contractor who was dredging an onsite fire pond as part of fire protection maintenance. The water escaped offsite to a drainage system, which eventually discharges to a creek. The contractor failed to report the incident to mill staff, and the incident was reported to the BC Ministry of Environment by a member of the public who observed unusual flows in the creek. Canfor was issued a warning letter by Environment Canada for failure to report the incident. We have reinforced with all divisions the requirement to report any out-of-the-ordinary discharges to Regulatory agencies.
At one mill, annual oil water separator samples were not collected in 2015 as required by permit. This was noted on a Ministry of Environment inspection in October 2016, and an advisory was issued. At another mill, duplicate annual oil water separator samples were not analyzed in 2015 as required by the permit. This was also noted on a Ministry of Environment inspection in October. At another mill, oil water separator samples were collected late in the year, and one separator marginally exceeded the permit discharge criteria for hydrocarbons. The systems were shut down for winter shortly afterwards, and will be retested in spring 2017. Implementation of compliance work orders through our maintenance system will prevent recurrences.
There were three reportable spills at sawmills in 2016 – two to the ground from ruptured hydraulic lines on logyard mobile equipment, one caused by a sharp piece of wood rupturing the line, and the other by friction from two lines rubbing together. The third spill was caused when a fork on a forklift pierced the side of a paint tote resulting in a spill of water-based paint to the ground. Appropriate regulatory agencies were notified promptly, the spills were cleaned up and internal follow-up investigations and preventive actions completed.
At one curtailed mill, a Ministry of Environment inspection noted wood residue accumulation issues on the landfill, and an advisory letter was issued. A wood residue management plan had been developed for the site and submitted to the Ministry in 2015. Excellent progress has been made against the plan, and cleanup was completed in late 2016.
One of our US South operations was assessed a $27,000 penalty in 2016 for boiler particulate exceedances. Installation of a continuous dry kiln, which will offload the boiler and new emission control equipment, will achieve compliance.