Frequently Asked Questions


EA Process

What is the timeline for this project?

Northern Pulp Nova Scotia and Paper Excellence are committed to having a replacement treatment facility in operation by January 31, 2020 in order to comply with the Nova Scotia Boat Harbour Act and continue mill operations. The required Nova Scotia Environmental Assessment (EA) process is now underway, with assistance from Dillon Consulting. Indigenous, public and stakeholder consultation and documentation are an important part of the EA process. This includes documentation of concerns along with how they will be addressed, and presentation of relevant scientific information.

The initial consultation and scientific studies are underway and are expected to be completed by the late spring of 2018, including modeling of the receiving environment and evaluation of existing conditions and habitat.

The registration of the EA is planned for the summer of 2018. Once the project is registered with Nova Scotia Environment (NSE), their EA review process would then begin, which is a minimum 50 day process. Dependent on the Minister of Environment’s decision, additional work under the EA may occur, or the project may be approved, or rejected.

If the project is granted EA approval, applications for additional regulatory approvals will be submitted. The construction would start once the project has received applicable regulatory approvals. The scheduling of construction activities will depend upon detailed design and environmental assessment activities.

Who is reviewing the Environmental Assessment? How will the public have a say?

As part of the completion of the Environmental Assessment (EA) study, there will be many opportunities for public input over the estimated six month study duration prior to registration. The EA Branch of Nova Scotia Environment (NSE) works with proponents (Northern Pulp Nova Scotia) in identifying and addressing environmental concerns during project development stages.

In addition to NSE, other provincial and federal regulatory authorities have been engaged in the EA process including:

  • Fisheries and Oceans Canada (DFO),
  • Environment and Climate Change Canada,
  • Canadian Environmental Assessment Agency,
  • Transport Canada, and,
  • Nova Scotia Department of Natural Resources.

Once the EA study is completed, a formal EA registration document will be submitted to NSE for review. This document includes comments received during the EA study and how they have been addressed or mitigated in the facility design. Consistent with the Environmental Assessment Act, at the time of registration a formal notice will be issued to the public and public access to the EA document will be provided. The formal 30 day review period then begins, where the public can address any comments/concerns regarding the project directly to NSE. All information and comments/concerns received are considered as part of the EA review process. After considering the information compiled, the EA Branch makes recommendations to the Minister regarding the proposed project. The Environment Minister then makes his/her decision.

What is an Environmental Assessment?

An Environmental Assessment (EA) is a decision-making tool used by the province (Nova Scotia Environment - NSE) to evaluate the potential environmental effects of developments before they proceed. This is accomplished through a technical assessment, by involving the public to understand and evaluate their concerns, and by consulting with various government departments and agencies.

The EA Branch of NSE reviews the EA. In addition to NSE, other provincial and federal regulatory authorities have been engaged in the EA process including Fisheries and Oceans Canada (DFO), Environment and Climate Change Canada, Canadian Environmental Assessment Agency, Transport Canada and Nova Scotia Department of Natural Resources.

If there is sufficient concern at the results of the EA study, the Minister of Environment has the ability to shift the project into a process consistent with a ‘Class 2’ EA, including a review panel and public hearing process.

How is this different than the Industrial Approval?

The Industrial Approval regulates current mill operations on an on-going basis, including inputs and discharges. The Environmental Assessment (EA) approval for the proposed Effluent Treatment Facility project is required to address potential environment effects of the replacement facility as a first step prior to the construction. The treatment facility as a component of the mill will be operated in compliance with the overall Industrial Approval for the mill, in addition to other regulatory requirements including EA approval.

I have concerns, but you’ve already completed the design. How can my concerns be heard?

A treatment process has been selected and a preliminary design has been completed. Final design is still ongoing.

Engagement and consultation will occur throughout the study process. Public input is important in determining the final design and outfall location for the facility and is considered in the review process by Nova Scotia Environment’s (NSE) Environmental Assessment (EA) Branch and in the Minister of Environment’s approval decision.

Prior to the project registration, there are opportunities for community discussion through open houses and comments and concerns can be submitted to the project team via mail, phone, email or the project website. This will help the project team understand community concerns and ensure they are considered in the design of the facility and the proposed outfall location. Environmental planning to protect valued environmental components or mitigate risks will be developed from what is heard.

Once the EA is registered with the EA Branch, the formal 30 day review period begins and comments and concerns regarding the project can be addressed directly to NSE. All information and comments/concerns received are considered as part of the EA Review process by the EA Branch and the Minister of Environment.

Why isn’t this project being undertaken as a Class 2 Environmental Assessment?

Nova Scotia Environment determined this project would follow a Class 1 Environmental Assessment. Northern Pulp’s commitment is to complete the environmental impact assessments with rigor, appropriately assessing potential impacts, identifying mitigation measures and developing a sound environmental plan. NPNS support the government's actions to fulfill the promise made to Pictou Landing First Nation to close the existing ETF. The Boat Harbour Act requires that the use of the Boat Harbour Effluent Treatment Facility cease by January 31, 2020. It is the wish of Pictou Landing First Nation that Boat Harbour is returned to tidal and made a place that the community can once again enjoy.

NPNS is proposing to build a world-class effluent treatment facility.

If there is sufficient concern at the results of the Environmental Assessment study, the Minister of Environment when reviewing the EA Registration document has the ability to send the project into an additional review process that could include a review panel and public hearing process similar to a 'Class 2' EA.

Northern Pulp Nova Scotia Facility

What would be the economic impact of closing the mill?

Closure of Northern Pulp would have a significant adverse effect on the Nova Scotia Forestry Industry. Northern Pulp Nova Scotia (NPNS) exports over $200 million worth of goods annually, a significant portion of the province’s total forestry exports. In addition to directly employing over 330 Nova Scotians and creating over $100 million in labour income through direct and indirect operations, the mill operations also create well over 2000 rural jobs in the province’s forestry industry as Nova Scotia’s largest supplier of sawlogs. Together with its supply chain companies, Northern Pulp produces a total annual value output of $535 million. Northern Pulp is the single largest exporter out of the Port of Halifax, exporting in excess of 1,700 Ocean Freight Containers (20 ft. TEU Equivalents - twenty-foot equivalent unit, a measure used for capacity in container transportation) per month through the Port of Halifax. Northern Pulp exported over $170 million to China in 2016, making wood pulp and Northern Pulp in particular over 1/3 of the province’s exports to China.

What technologies, other than ASB’s, are Canadian Bleached Kraft Mills using to treat effluent?

The following is a list of Canadian kraft mills (not operating Aeration Stabilization Basins - ASBs) and their treatment processes:

Not all Kraft mills discharge into marine environments in Canada, many discharge to lakes and rivers. While many mills have upgraded to Oxygen Delignification to improve their environmental footprint, there are mills operating that have not yet incorporated that technology.

How is this going to change Northern Pulps operational capacity?

The throughput capacity of the Northern Pulp Mill is not expected to be adjusted due to the replacement treatment facility.

Effluent Treatment Facility Design

What is the design for the replacement facility and how was it selected?

KSH Solutions Inc. has completed the preliminary engineering scoping which identified activated sludge treatment (AST) as the best form of treatment for the replacement facility. The replacement facility will be constructed on the existing Northern Pulp mill site. Several alternatives were considered, and the AST was selected based on the following criteria:

  • Optimization - what process will reliably result in quality treatment, given the characteristics needing to be treated?
  • Efficiency - does the technology match the requirement?
  • Economic Viability - can the process allow for the continued viable operation of the mill?
  • Flexibility - can the process function across various operating conditions? (e.g. seasons)
  • Footprint - can the process fit on the mill property, without impacting adjacent natural features and property owners?

The AST process removes solid materials (Total Suspended Solids -TSS), organic loads (Biochemical Oxygen Demand - BOD/Chemical Oxygen Demand - COD), and chlorinated compounds (Adsorbable Organic Halides - AOX). Effluent will be fed into a new primary clarifier for suspended solids removal (primary treatment). Following primary treatment, the clarified effluent enters the two-train biological treatment system (secondary treatment) after being cooled to the appropriate temperature to maximize biological activity. The secondary treatment system removes biodegradable non-settleable organic pollutants using microorganisms. The process is very similar to the treatment provided for municipal effluent treatment systems.

Why is this facility not designed as a closed loop system with no effluent discharge?

Northern Pulp’s mill is a bleached kraft pulp mill. This is a different pulping process than some other mills around the world that operate closed loop systems. Bleached kraft pulp is a chemical process to form pulp. The bleaching process generates the majority of the effluent and it contains chlorides that would cause equipment corrosion if the effluent was recycled through the system. The chlorides are not harmful to the ocean as they are naturally present there, but they are very harmful to metal equipment. A similar corrosion issue is why you need cathodic protection on boat hulls from the chlorides in seawater.

Over the past 40 years, there has been extensive research and attempts at zero-effluent bleached kraft mills. Eleven (11) bleached kraft pulp mills have attempted zero-effluent systems, but they were not able to meet zero-effluent at all times. Operating issues (build-up of chlorides and minerals that led to scaling, for example calcium) with the closed system occurred regardless of the bleaching process used and of the 10 mills that remain in operation today, all have effluent treatment plants and discharge the treated effluent to receiving waters.

Some examples of mills where closed loop systems are possible include unbleached kraft mills and, bleached chemical thermal mechanical pulp (BCTMP) mills, which are different pulping processes.

Can NPNS make a different product that could be closed loop?

Based on consultation with stakeholders and at the request of fishermen representatives, Brian McClay & Associates Inc. was engaged by Northern Pulp Nova Scotia Corporation to assess the viability from a future marketing/sales perspective of converting the existing Pictou Northern Bleached Softwood Kraft (NBSK) mill to produce either Unbleached Kraft Pulp or Bleach Chemi-Thermo-Mechanical Pulp. The viability study stemmed from consultations with stakeholders, namely fisheries representatives. The study findings indicate that continuing to produce premium reinforcement NBSK is the most competitively viable option by far for Northern Pulp. The full report is available online here.

Will the new facility have the same odour?

Odour control was a key consideration in the preliminary design of the new facility. The replacement treatment facility will not have the same odour as Boat Harbour. Differences between the processes at every stage mean that the proposed AST facility will introduce less odour. Details are outlined on Panel 19 of the open house materials, available here.

Outfall Location

How will the outfall location be determined?

The final, exact location of the outfall will be determined as an outcome of the Environmental Assessment process, final engineering design and related regulatory approvals. To date, a proposed general location has been identified based on considering natural and socio-economic constraints as well as through scientific modeling of flow, dispersal and settling rates, and water chemistry.

Fishing and spawning grounds are some of the important considerations that will go into selecting the final outfall location. Other factors include physical oceanographic features such as bathymetry, water depth, currents, temperature and salinity in addition to engineering considerations.

What is the proposed general location of the outfall at this time?

A receiving water assessment was completed and determined that the outfall should be placed in the Northumberland Strait. Potential locations were evaluated using a conservative (“worst-case”) modelling approach based on the proposed effluent quality. The general outfall location was chosen based on meeting regulatory criteria for key water quality parameters and on providing the smallest potential for long-term cumulative environmental effects.

There are a lot of considerations - including commercial, recreational, and aboriginal fisheries sensitivities, and bird and shoreline sensitives. We've identified a possible solution we believe balances these constraints.

A key consideration, in consultation with Pictou Landing First Nation, was to develop a solution that does not impact Boat Harbour in the future tidal state. Studies have shown that if the outfall was inside Pictou Harbour the slow currents and other environmental factors inside the Harbour could result in accumulation of effluent.

What are the differences between the existing and proposed discharges?

Existing effluent flows over a 6 ft wide dam at the end of the boat harbour basin into the straight. It is fresh water and warmer than the seawater so it enters the strait as a visible plume that sits on top of the salt water and does not mix well. It often travels considerable distance before it mixes with the background waters.

The new proposed outfall will be submerged in 11 metres of water and be dispersed through 6 ports. The ports will be located 1 meter above the sea bottom. Due to the bouyancy of the plume it is not expected to interact to any appreciable extent with the seabed. The plume is designed to reach the surface at 90 meters from the diffusers where it will already be diluted 100:1.

A figure showing the current and proposed discharge locations is included below. The discharges are located approximately 3.5 km apart.

Effluent Quality

Is the effluent quality the same as currently being discharged to Boat Harbour?

No, the proposed effluent treatment system is different than the Boat Harbour process. In addition, the Boat Harbour system and inputs have changed over time resulting in historic changes in Boat Harbour effluent quality over time. The current Boat Harbour effluent treatment system is an Aeration Stabilization Basin (ASB) system. The proposed system to be located at Abercrombie Point is an Activated Sludge Treatment (AST) system. The AST system is more compact and offers a higher degree of control flexibility. In addition to the AST technology, a future planned in-mill process upgrade oxygen delignification (O2 Delig) is anticipated to improve the overall effluent quality.

Is dilution the solution to pollution for Northern Pulp?

Industry standards and the current Pulp and Paper Effluent Regulation (PPER) limits are mass-based (i.e. kilograms/day) and not based on volume. Therefore adding more fresh water to the effluent does not make PPER limits easier to meet, in fact, PPER prohibits the dilution of effluent in the regulation.

A receiving water study (RWS) was conducted to model the proposed effluent quality at design flow. The RWS is available here. The RWS was conducted in part to model how to design the end of pipe diffusion to be least impactful to the receiving water environment. Achieving good dispersion (i.e. reaching high dilution ratios with background receiving water) as close to the outfall diffuser as possible is the goal of the design.

Also, reducing effluent flow below the 85,000 m3/day design flow results in an improvement in mixing conditions. Therefore, there would be no benefit to adding dilution to the effluent before the outfall.

Will there be metals in the effluent?

Yes, metals naturally occur in the fresh water supply (input to the process) and in wood. Additional information will be gathered as part of the Environmental Assessment (EA).

Air and Water Quality

Will the project have an effect on air quality?

The modernized effluent treatment process has been designed to not adversely impact air quality from the mill or in the surrounding area. Odour control was a key consideration in the preliminary design and is outlined in the consultation materials for December.

Unrelated to the effluent treatment, the mill is separately addressing air quality concerns and working closely with the local government and regulatory authorities to improve air quality.

What are the long term implications of mill operation and the discharge into the Strait?

The Environmental Assessment (EA) will evaluate expected long term implications and potential environmental impacts related to the proposed replacement Effluent Treatment Facility. The replacement treatment facility design will incorporate the components needed to address regulations established with the understanding of the longer term implications.

The EA registration document will be completed by Northern Pulp Nova Scotia (NPNS) and their consultants, including Dillon Consulting. The EA registration document is then reviewed by the EA Branch of Nova Scotia Environment and other applicable government departments and agencies.

Northern Pulp will continue to test effluent quality, as outlined in the Pulp and Paper Effluent Regulations (PPER), as it does today and will follow all federal and provincial regulations for testing and reporting. The development of monitoring programs will be an outcome of the regulatory process for approval of the facility. Under the PPER, an Environmental Effects Monitoring (EEM) Program is required and will be developed. Additional monitoring programs will be designed based on approvals requirements. Oversight will be provided by Nova Scotia Environment and Environment and Climate Change Canada.

Why is it okay to let freshwater into the Northumberland Strait?

Freshwater currently enters the Strait from numerous freshwater sources. Freshwater enters Pictou Harbour from the West River, Middle River, East River and from land-based runoff. Water reduction at Northern Pulp Nova Scotia will result in a higher spill rate over the Middle River dam to Pictou Harbour.

It is anticipated that although dominantly marine in character, there is some natural variation in salinity (amount of salt versus freshwater) in the vicinity of the proposed outfall. Aquatic species present in nearshore areas tend to be somewhat tolerant of lowered salinities. Based on mixing identified in the receiving water study, the “freshwater” effluent plume is completely mixed with the background salinity by 100 m from the diffuser. At 20 m from the diffuser the effluent is predicted to be diluted by 50 times.

Marine Life

What Impacts will there be to lobster larvae?

We have retained the services of a recognized scientist in lobster research to provide expert input. No tests on the effects to lobster larvae have been completed to date.

Based on the RWS modelling completed, the water temperature at the point of discharge is expected to meet background water temperature, +/- 1 degree Celsius, within a maximum of 8 metres. This is within CCME Aquatic Life Guidelines and means that the affected area would be within 8 m under worst case (summer) conditions. Background salinity is expected to be met within 100 m from the outfall.

Will there be long term monitoring of marine life and marine water quality?

Northern Pulp will continue to test effluent quality, as outlined in the Pulp and Paper Effluent Regulations (PPER), as it does today and will follow all federal and provincial regulations for testing and reporting. The development of monitoring programs will be an outcome of the regulatory process for approval of the facility. Under the PPER, an Environmental Effects Monitoring (EEM) Program is required and will be developed. Additional monitoring programs will be designed based on approvals requirements. Oversight will be provided by Nova Scotia Environment and Environment and Climate Change Canada.

Environmental Monitoring

What happens if the pipe breaks or the facility has an emergency?

Contingency planning is a component of Northern Pulp Nova Scotia’s (NPNS) approval requirements. Various emergency scenarios will be incorporated in planning for operation of the replacement treatment facility, including potential for discharge pipe failure and repair. A key consideration is that the effluent in the discharge pipe is treated before entering the pipe (this is not the case in the existing Boat Harbour treatment system). Secondly the physical design of the pipe itself is proposed to be high density polyethylene (HDPE). HDPE is strong (has greater than 2” thickness) and has some flexibility to allow for the undulating ocean bottom profile. A component of the contingency planning for the replacement treatment facility is the construction of spill basins. A new spill basin has been proposed with a capacity of 25,000 m3. The spill basin will be a High Density Polyethylene (HDPE) lined basin. A secondary spill containment system is also provided for clarified effluent, with a capacity of 10,000 m3.

How will Northern Pulp be regulated regarding what is discharged?

Both Environment and Climate Change Canada (through the Pulp and Paper Effluent Regulations), and the Nova Scotia Department of Environment (NSE) will set effluent discharge criteria and will have authority to oversee and enforce requirements. NSE can place additional requirements on the facility as part of the terms of the Environmental Assessment Approval or subsequent Industrial Approval. Northern Pulp will need to meet the terms of the approval for continued operation.

There have been environmental issues in the past. What has been done to address these?

Beginning in 1972 the treatment process at Boat Harbour was modified and improved including the addition of settling ponds and an aerated basin.

Several major changes have occurred over the years improving effluent quality entering the Boat Harbour facility. In 1992 the Canso Chemicals chlor-alkali facility that generated sodium hydroxide, using mercury as a catalyst, closed. In 1997 the Mill moved away from elemental chlorine to chlorine dioxide for bleaching to meet new federal Pulp and Paper Effluent Regulations (PPER) for dioxins and furans.

When Paper Excellence purchased the mill, it was known that significant environmental improvements were necessary. Since purchase in 2011, many of these projects and improvements have been completed including closure of the brown stock screen room and the recycling of lime water in the kiln area.

Many projects have good intentions, but fail. How can you guarantee this replacement facility will not cause impacts?

The Environmental Assessment (EA) process is required in order to thoroughly investigate potential environmental impacts, develop appropriate environmental planning, and present suitable mitigation measures for the EA Branch of Nova Scotia Environment to review, along with any other relevant departments and agencies. The Minister of the Environment will not approve the EA if he/she does not believe the proponent (Northern Pulp Nova Scotia) has sufficiently addressed potential environmental impacts with reasonable mitigation measures.

How will Northern Pulp be held accountable for the monitoring program?

Northern Pulp is committed to running an environmentally responsible facility. It is the goal that this project will result in an overall improvement to the environmental wellbeing of the community.

We recognize the public concern surrounding NPNS operations. The ongoing operation of NPNS will be contingent on monitoring programs that are developed during the regulatory process for approval of the facility.

Boat Harbour

What work is being done for the clean-up of Boat Harbour?

The remediation efforts are being conducted under a separate and distinct project from the replacement of the effluent treatment facility. The intention of the remediation project is to return Boat Harbour to its original tidal state. For questions about the Remediation Project, please contact:

Ken Swain, Project Leader, Boat Harbour Project, Nova Scotia Lands

Tel: 902-403-9744

Email: Ken.Swain@novascotia.ca