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December 15, 2018

RE: EBR Registry No 013-4064, Ministry Reference No. 7781-B4YHC6

Dear Madam/Sir,

Please accept this submission as Environment Hamilton’s formal comments regarding Canadian Liquids Processors Limited’s proposal to amend its existing Environmental Compliance Approval (Waste Disposal Site) No. A650041, issued for the use and operation of a waste disposal site with total area of 3.62 hectares at 15 Biggar Avenue in Hamilton.

The EBR registry posting indicates only that ‘(T)his proposal is to revise the site plan and structures of outdoor storage facilities for unprocessed glass’. We had the opportunity to review the MECP file for this proposal and we learned that there is reason to be concerned about the changes the proponent is requesting. As it turns out, the proponent has requested a significant extension to a deadline that has already passed that required them to address unprocessed glass storage requirements. The proponent was originally required to do this by October 31st of 2018. They obviously missed that deadline and have now requested a deadline of June 2020 as the deadline by which to address unprocessed glass storage requirements. The plans in the file show a fabric-roofed building – open to the elements – within which unprocessed glass will be stored. We were told by staff in the MECP Hamilton District Office that the building is more substantial than the bunkers originally proposed. While this is good, we still question the significant extension that the proponent is seeking – especially since the proposed structure does not appear to be that much more substantial than a bunker.

We believe the proposed timeline is far too long – especially since this issue should have already been resolved. Given the nature of the structures, we believe it is unreasonable to require a 20 month extension. This requirement is part of a long list of upgrades the MECP has imposed on this proponent at their Biggar Avenue facility because of extreme odour impacts. The problem reached a crescendo during the summer of 2016 – with odours so strong, anyone near the plant experienced burning eyes, nose and throat. The problem is that there are residential homes directly abutting the site. This makes it that much more urgent that the proponent be required to implement mandated improvements as quickly as possible. June of 2020 does not reflect an ‘as quickly as possible’ mandate; it is simply not appropriate given the adverse effects that this facility has inflicted on the surrounding neighbourhood. It is important to note that the unprocessed glass – and the manner in which it has been stored on site – has been a contributing factor to the odour issues.

We are requesting that the MECP require that the proponent deal with the construction of this required unprocessed glass storage facility so that it is operational before the spring of 2019 – so that progress is made in avoiding any odour problems into the spring/ summer of 2019. As it is, we are already not convinced that an open-ended fabric-roofed building will serve to effectively prevent any odour issues from the unprocessed glass stored on site, but we are also mindful and frustrated about the fact that odour likely will not be considered in this application to amend the waste disposal site ECA, despite the fact that it really needs to be!.

We thank you for the opportunity to comment on this proposal.

Yours truly,

Lynda M. Lukasik, PhD
Executive Director
Environment Hamilton
22 Wilson Street, Suite 4
Hamilton, ON L8R 1C5
TEL: (905) 549-0900