Prince George residents affected by asphalt plant emissions  are calling on the Ministry of the Environment to  change the asphalt regulations.  The call  came as part of the meeting between the residents and Ministry staff.  

Extensive monitoring and research work has shown chronic air quality problems in a number of municipal settings in the province. In these situations new emission concentration limits need to be set for asphalt plants.

The 1997 asphalt regulation needs a complete review to address new knowledge in both identification and control of asphalt plant emissions. We request that the ministry address this review from both the perspective of fully identifying and listing dangerous emissions and researching the best technology and management practices available to control those emissions. Engage qualified environmental engineers to develop the highest standard technically achievable in production situations. Sweden, Germany and California operate at 20 mg/m3 particulate levels which are achievable with well maintained fabric filters.

There is a range of technological solutions to protect against air quality and associated health threats that are not being used by the asphalt industry. Particulate and VOC emissions are examples of major concern from a health perspective, but there are others that are not monitored or controlled that may be as offensive. Threats to health can be substantially reduced by the use of pollution control equipment such as thermal oxidizers that burn emission contaminants and bag houses that control particulate dust. Serious consideration should be given to limiting fuel used to heat asphalt to clean sources.By the 2008 paving season implement more stringent emission concentration limits for asphalt plants near residential areas or in problematic airsheds, and expand the list of communities that they apply to include those with airshed problems similar to those in Prince George.

3. Best Management Practices

We understand that a main purpose of the asphalt regulation is to avoid permitting requirements for each asphalt operation. This is a practical change in certain situations such as non urban highway jobs, or in-place asphalt recycling where exposure at any location is for a very limited timeframe. However, the elimination of permitting has eliminated the potential to require best management practices for hot mix plants situated in difficult circumstances such as the Prince George airshed. We also understand that the regulation empowers municipal governments to implement a permitting system. However, municipalities do not have the expertise to determine appropriate special permitting conditions. We request that the Ministry of Environment in the 2007 budgeting process make provision to provide technical support and expertise to municipalities that express an interest in developing local asphalt plant permitting provisions.

4. Effective Management Standards and Controls

Any of the above actions will be futile unless there is a firm commitment to effective monitoring and enforcement of emission limits. Ministry employees have readily admitted that they do not have the controls necessary to bring asphalt operators into compliance. This is clearly a ministry responsibility and the current process needs to be completely revamped to make it effective. Currently, plants can operate for full paving seasons without meeting emission limits and not be subject to any enforceable constraints. As well, asphalt operators do their own testing at a time selected by themselves which leaves the testing process open to abuse.

We request that the testing function be taken out of the hands of the asphalt operators – there was consistent evidence this summer that self-tests are not working. Testing done by operators on days they select by contractors that they hire is not credible. The common industry model is for independent third party testing by qualified persons at the operators cost, under the supervision of a regulatory body such as the Ministry of Environment. We request that for the 2007 paving season;

• The Ministry of Environment commit to implementing an effective monitoring and enforcement program for asphalt plants. The city has a vested interest and should not manage the testing process.
• The Ministry of Environment institute frequent random testing for asphalt operation emissions. Sample problem operators more frequently to minimize risk and optimize the cost of testing. Include provisions in the regulation to make asphalt operators responsible for the cost of ministry administered testing.
• Include time loss and/or other penalties for non compliance in the regulation to ensure provisions are taken seriously.
• Establish firm procedures for implementing contractual penalties such that they cannot be successfully challenged by non-performing operators.