Levels of manganese coming…

Levels of manganese coming from the facility are modelled at 91% of the Ministry of Environment limit. The modelled levels are very close to the actual limit, warranting a call for actual monitoring to determine how high these levels really are.

The iron oxide levels are modelled at 45% of the limit; it is also worth calling for actual testing of iron oxide.

Finally, the particulate matter (or dust) levels are modelling at only 17% - a highly questionable result given the fact that dust clouds are often observed in and around the site. Particulate pollution and iron oxide can end up falling out on nearby properties (think about dusty patio furniture and homes). Some particulate is small enough that it can create respiratory health issues. The Ministry should require the company to monitor for respiratory particulate – not just ‘total suspended particulate’ which includes all particulate sizes.

I feel the Ministry of Environment should require the company to actually MONITOR (measure) air pollution levels from the facility rather than just estimating using a computer model. Due the impact of Nearby residents they should facilitate actually operating within the allowable air emission limits.

Triple M is also not the only source of manganese within the industrial core. Manganese is also released from steel mills in the industrial core. This raises concerns that the fact that there are multiple sources of manganese in the industrial core and the Ministry of Environment needs to consider the cumulative impact of all of these sources in order to properly protect human health and the environment.

The current air impact from the close proximity of these heavy industrial pollutants continues to have a grave negative effect in the local community. The residents are exposed to a lot of chemicals and particulates. Our outdoor and indoor furniture shows this in daily accumulation of black dust and particulates all over. You can wipe your furniture down daily and yet it still gets covered, that's how much negative impact these companies have on this community.

As part of this amendment application, the company was also required to assess noise impacts from the facility – a process that involves evaluating all individual sources of noise to determine whether additional actions are required to operate the facility within provincial noise guidelines. The assessment report concluded that the company is operating within allowable provincial noise guidelines but that any new equipment added to the operation should not exceed a noise level of 35 decibels (dB). Of particular note is Section 6.3 of this report – which sets out the ‘Noise Abatement Action Plan’. The action plan, which is incredibly brief, focuses on two methods for noise control: maintaining the heights of storage piles and restricting hours of operation for certain activities at the site to between 7am and 11pm

The company should be required to install proper noise control walls/ barriers in locations where such
controls are warranted. Relying on ‘storage piles’ - which we are assuming are made up of scrap metal or related material – for noise abatement does not provide the necessary permanent assurances for surrounding businesses and residents that noise will be properly controlled on an on-going basis. Further, the recommended height for Storage Pile #1 is 8m – well beyond the Ontario Fire Code’s 10 foot height limit for scrap yard piles that may contain combustible materials. In other words, this requirement for storage pile height to mitigate noise impacts could be introducing a fire risk at the site if the storage piles include combustible material. It is also worth noting that the scrap facility next door – American Iron & Steel (AIM) has been required to install properly engineered noise abatement systems (not storage piles) and the same should be required for Triple M.

This facility’s operations should be restricted to the hours between 7am and 11pm in
order to address noise impacts in the area. The noise abatement plan does indicate that certain equipment and activities – including shredder operation, slag metal recovery activities, iron slag dropping, and rail car shunting - will be restricted to these hours.

The Ministry of Environment should add a condition to the company’s air & noise permit that formalizes these operational restrictions.

If you go back into your complaint systems and review ALL the negative impact Triple M has had on the local community going back years you can plainly see they don't operate willingly and according to the guidelines they have in place today. They have to be forced to comply, noting the history of explosions. They are now asking permission to expand and cause more impact. Their environmental track record clearly shows the lack of restraint and they don't seem to care what the impact to the local community or environment is unless forced too. They have not earned any rights or privilege to be allowed to expand. They have shown the MOECC and the Local community they don't care. So no matter what guidelines you put in place, they will openly violate them until they are caught and punished. I would request that MOECC evaluate there environmental policies and with that knowledge reject there expansion plans knowing full well they won't comply with the what ever measures they told to abide by unless forced. And we know the MOECC does not have the manpower to monitor these types of illegal behaviour 24/7.