January 1, 2018
Government of Alberta
Minister of Environment and Parks
Dear Ms. Shannon Phillips,
I am writing to you today to discuss the SWRR gravel operations behind the Wentworth/West Springs neighborhoods in Calgary. Once again, I fully appreciate that your portfolio is challenging as Alberta faces many environmental issues, this gravel operation being only one, but I would like to implore you to consider that you and your government have an opportunity to take a strong stand on this. Albertan’s count on our government to protect our investments and long-term interests. Our current environmental legislation attests to this desire but our regulations are only as good as the enforcement of them.
The particulate matter being generated by this operation far exceeds the limits set out by our government and can be clearly seen by the photos of the ice rink that is situated close to this pit.
Furthermore, Jeff Brookman with YYC Cares has also written to the project manager expressing his concerns about the safety violations and air quality monitoring stations that are inadequate and poorly placed. Below is Mr. Brookman’s exchange with the project manager Rizwan Hussain;
Good evening Rizwan,
Up until recently, I elected not to pursue an official complaint against engineers within Alberta Transportation, however, your nonsensical email below to Ms. Lenore Kay confirms that I was right to adjoin myself to the complaints that have already been filled against you and others because of your failure, amongst other things, to ensure proper air quality monitoring has clearly violated the prime rule of APEGA’s code of conduct:
Professional engineers and geoscientists shall, in their areas of practice, hold paramount the health, safety and welfare of the public, and have regard for the environment
Rizwan, silica dust just like sour gas (H2S) plays no favourites. Both air-born health hazards can kill silently and indiscriminately (one very fast and the other more slowly). The Kelly versus the ERCB (Griizly Resources sour gas wells case), and the issue of “directly affected”, should have changed the way that business is conducted in this Province, see http://blg.com/en/News-And-Publications/Documents/publication_2035.pdf. However, this is clearly not the case. Sour gas requires 360 degree monitoring because the wind can shift in a moments notice. Moreover, sour gas requires training for all that visit a well site or a sour gas plant. The same is true with other air-borne health hazards such as silica dust that can cause death. Given that you must have an approved HAZMAT plan, your email to Ms. Kay and the so-called response from Alberta health frankly disgusts me. As all professionals know, monitoring cannot take place just upwind of the prevailing wind direction (which is the worst of all locations) and unless its a 360 courage, its meaningless.
The accepted levels of particulate matter, including silica dust, are published in the approved South Saskatchewan Regional Plan’s “Regulatory Details” (see below), which are part of the Alberta Land Stewardship Act, a “law”, which is the Act that integrates all of Alberta’s legislation related to air, land, water and biodiversity. This holistic integrating legislation resides above the Water Act, the Public Lands Act and the Government Organization act. Moreover, it sits far above any bizarre interpretation of legislation that may have created the Transportation Utility Corridor (TUC) Policy that is founded upon Schedule 5 (the environmental section) in the Government organization Act and not Schedule 14 (transportation). As you can see in the table below, particulate matter is measured in microns or parts per billion and not the millimeters of dust that has repeatedly shown up on the backyards of the residents in Wentworth/West Springs.
Further the OSHA standard (pretty much a worldwide standard), has a worker limit 50 micrograms/m3 of silica dust per an 8 hour work shift, see http://www.asse.org/assets/1/7/Webinar_Silica_Pete_Rice.pdf (note; this 28 micrograms/m3 in Alberta over a 24 hour period and see the annual limit!). Alberta health has similar standards so this email reply makes absolutely no sense and once again demonstrates that this road is being built without any regard for the health and safety of the public and the environment that adjoins this transportation utility corridor.
Rizwan, as an APEGA member, and the PROJECT MANAGER, you have to hold yourself to a higher standard. This includes standing up when something is not right and telling the politicians and life time bureaucrats who are bulldozing this road through without any regard to HSE and the APEGA code of Conduct, NO!
Kindly appreciate that up until recently I gave you the benefit of the doubt, however, this reply to Ms. Kay (upwind monitoring) makes absolutely no sense and in my opinion you should no longer be part of APEGA. Further, I now believe a stop work order needs to be immediately issued.
Lastly, I will now advocate for PUBLIC INQUIRY on this issue and the other contentious components of the ring road such as the infilling of wetlands, the destruction of river valley and overbuild issue and non-release of an EAB report from a public hearing . The PUBLIC deserves to have their lives protected and so does the environment. Silicosis is a disabling, irreversible, and sometimes fatal lung disease.
Shame on you.
From page 183 of the South Saskatchewan Regional Plan, https://landuse.alberta.ca/LandUse%20Documents/South%20Saskatchewan%20Regional%20Plan%202014-2024%20-%20February%202017.pdf
As you can see and read from these exchanges, serious problems with this operation are not being addressed nor resolved in an appropriate fashion. Again, we can and must do better in protecting our citizens and our environment.
If there is anything I can bring to bear in resolving these issues, please let me know. You have my full support in addressing these concerns and implementing solutions.
Romy S. Tittel