Aamjiwnaang First Nation …

Aamjiwnaang First Nation (AFN) wishes to note that: (1) the proposal lists "a biological oxidation
unit" as being included in the revised ECA and (2) includes Benzene in the list air of pollutants
emitted by this facility.  It is AFN's understanding that while Benzene is not used in Arlanxeo's
operations, Arlanxeo processes Styrolutions' indistrial wastewater in Arlanxeo's wastewater
treatment facility and that is the reason why Benzene is included in Arlanxeo's ECA proposal.

Aamjiwnaang First Nation (AFN) is very concerned about emissions of Benzene from industrial
facilities located near AFN community and the health/cancer risk that Benzene emissions represent
to the AFN community.  Recent amendments to O.Reg.419/05 established a new annual benzene standard
of 0.45 ug/M3 and established 2 Technical Standard for Petroleum Refineries and Petrochemical
Plants.  These changes recognize the health risk posed to communities exposed to Benzene and the
need for industry to manage vigorously this carcinogen.

Between March 7, 2017 and July 25, 2017, AFN conducted a monitoring program for Benzene and other
pollutants.  EPA Method 325 sampling was done at 15 sites in and around Aamjiwnaang First Nation
(AFN) community.  Method 325 involves using passive diffusion collectors sampling for 11 two-week
periods from 3/7/2017 to 8/7/2017.  The sample tubes were collected and analyzed for a number of
organic compounds by an accredited laboratory. The results of this monitoring program were provided
to Environmental Health Strategies Inc. (EHS) for analysis and interpretation.

In order to identify a level of concern for a two-week monitoring period, EHS followed the
methodology of Section 17 of Ontario Regulation 419/05 - Local Air Quality to develop conversion
factors to convert the annual standard for benzene to a Monitoring Assessment Value (MAV) for a
two-week period. The MAV for Benzene was calculated to be 1.12 ug/M3.

EHS reached the following conclusions after analysing the monitoring results:
1 Every sampling location for every two-week period had detectable benzene, and nearly all of those
measurements were above the Monitoring Assessment Value (MAV).
2 The average concentration for the 22 weeks of sampling, almost half a year, at 12 out of 15 of
the sites was above the two-week MAV. 
3 The most impacted sites were Pipeline 40 and the Band Office, with the highest two-week readings
of 25.30 ug/m3 and 16.10 ug/m3, respectively, which are more than 10-20 times the MAV of 1.12
ug/m3.  These two sites are close to Arlanxeo's wastewater treatment plant.

This analysis of benzene monitoring data shows clearly actionable levels requiring mitigation
pursuant to Ministry regulations and policies. 
We strongly request that the Ministry requires Arlanxeo to take immediate action to either reduce
Benzene emissions from their wastewater treatment plant to below 0.45ug/M3 at the fenceline or to
operate under the Benzene Technical Standard which contains operating requirements for wastewater
treatment plants.  There are several technical options available to Arlanxeo to reduce Benzene
emissions:
1 Cover the Biox unit and route vapors to a control device such as a flare, incinerator or carbon
adsorption;
2 Styrolutions waste can be routed to a new device to remove Benzene prior to sending the waste to
the BIOX unit.
3 If neither of the first 2 options are adequate in reducing Benzene emissions by Arlanxeo, the
Ministry should require Styrolutions to remove Benzene from their waste prior to sending it to
Arlanxeo.