ERO PROPOSAL 019-2526 As a…

ERO PROPOSAL 019-2526

As a former certified emissions auditor of the coke oven batteries at Algoma Steel Inc. (ASI) in 2018, I would encourage the province to reject the proposal (ERO# 019-2526) for an extension to June 30, 2022.

PROVINCIAL ORDERS AND COMPLIANCE BASED APPROACH

The MECP claims through site-specific standards that they use a “compliance-based approach”. ASI can be out of compliance for months with no fines until an order is issued. The simple approach of evaluating performance as gradual “improvements over time” does not negate the excess emissions created in the process. ASI’s Environmental Control Manager confirmed the MECP’s goal to meet US standards, “After a multi-year study and consultation period the final determination was to mirror the emission limits that were established in the USA since they represent the steel sectors biggest competitor and trading partner and because their rules are believed to result in the lowest emission rates from coke batteries”. The various sources of benzene from coke oven batteries that violate emissions standards such as leaks (doors, lids, pipes), pushing and charging operations, are not assessed fines in Ontario giving a competitive advantage compared to US operators. In the US, regulations are stricter, and fines are issued to operators while they make corrective actions to improve over time with changing regulations. In 2016 and 2017, ASI consistently failed to meet the standard for door leaks for over 6 months with no fines before orders were issued and a proposal for a Benzo-a-pyrene (BaP) Site-Specific Standard was delayed. The MECP’s current approach is likely to encourage operators like ASI to operate freely outside the limits for an extended period with no concerns of fines being issued to their facility for non-compliance.

In the past, the MECP was concerned about opacity violations from coke oven battery (COB) stacks as another source of benzene and other contaminants. Opacity violations under Section 46 of Ontario Regulation 419/05 are no longer enforced with fines. The number of violations is important in determining the loading factor of contaminants emitted, and therefore the overall emissions released by the facility from COB stacks. The attitude of the MECP regarding the importance of opacity violations was justified by a misleading statement in an ACLC meeting, “It was explained that the Ministry’s priority was to focus on ground level fugitive emissions from the coke batteries which are regulated by the Site Specific Standards. The stack opacity emissions have much less of an impact on the community and contaminants are less harmful”.

AMBIENT AIR QUALITY MONITORING CONCERNS

The ambient air quality network that characterizes the emissions around ASI, is clearly deficient when compared to other facilities. Data from past MECP air and soil studies have highlighted the need for a reassessment of the current network. Many residents within the Bayview area are within 500m of coke oven batteries and ASI’s By-products plant.

Meteorological stations (“Met stations”) are important in air modelling since they assist in estimating the atmospheric behaviour of an emission and the likelihood of the potential emissions emitted being deposited off-site within a certain distance and area (dispersion pattern). Compared to the St. Marys Cement Plant, ASI’s network currently has only one meteorological station to characterize its emissions. Despite, the complexity of modelling wind speeds and directions for emissions modelling, ASI stated “It is not required. Neither of our met stations are required. We voluntarily operate and maintain our met station to use as a tool to assist our understanding of local conditions.” When the local MECP was requested to address concerns regarding the air monitoring network they stated, “On January 21, 2019 a request to review air monitoring in SSM was made to our MECP Northern Region Tech Support office to review and determine the level of reliability and accuracy of the current monitoring program for SSM. Due to limited resources and priority ranking, a definitive date for completion has not been set.” Emissions are modelled and therefore require an appropriate air ambient monitoring network and real-time sampling to evaluate the potential impacts of actual emissions emitted compared to the modelled emissions.

ALGOMA COMMUNITY LIAISON COMMITTEE (ACLC) - ACCESS AND PUBLIC INPUT

The local MECP was asked how people can share concerns about emissions at ASI and they did not mention the ACLC. I was made aware of the ACLC by the environmental engineer at the City of Sault Ste. Marie when I requested information on ASI emissions. There was no contact information for any members in the meeting minutes, so a request was made to the ACLC Chairperson (ASI’s Environmental Control Manager) for contact information. There was no information provided by ASI but I managed to contact the ACLC public members through the environmental organization where they were members. Unlike ArcelorMittal Dofasco (AMD) and Stelco’s CLCs, ASI argues their terms and conditions does not allow general members of the public to observe these meetings. ASI should allow public access to the committee meetings like other Ontario steelmakers to give a fair opportunity for the public to be involved in issues that concern their health and the environment. Access to these meetings would allow for a better understanding of off-site emissions, the development and importance of site-specific and technical standards, operational upsets concerns, and any enforcement action by the MECP.

Information provided to the ACLC is at the discretion of ASI. The MECP is present at all ACLC meetings and is aware of all violations posted to ASI’s website. ASI pushing violations were under reported when 2017 and 2019 data was compared between their Process Upset Table and ACLC meeting presentations from February to July. The MECP should have noted the discrepancies in the data presented and should consider that not all pushing violations are reported to the MECP by ASI.

COVID 19 AND FINANCIAL IMPACTS

In 2019, the federal government provided ASI $90 million dollars in repayable contributions to help with U.S. tariffs on steel. Also, the Ontario government loaned $60 million dollars to support restructuring processes. Currently ASI has announced that expansion to their operations has been put on hold due to the COVID-19 impacts. Financial security has never been assured during many years of operations at ASI. In the past ASI has been reluctant to make changes for environmental reasons to their facility within the prescribed time frame, arguing finances. The impact of COVID-19 although a factor, is not the only reason the company claims it does not have the finances to complete the required environmental work. There were two significant emissions events at ASI on March 09, 2019 and October 18, 2019 that caused extensive damage to the facility and significant environmental impacts.

On March 09, 2019 there was a plant-wide power failure caused by older style technology. This resulted in significant air emissions for over 1.5 hours and an estimated 4.7 million litres of untreated effluent to be discharged to the St. Mary’s River. On October 18, 2019, a 400lb steam line ruptured causing a loss of power to the by-products plant causing the south raw liquor tank and decanters to overflow and their contaminants to enter storm sewers. This event also resulted in significant air emissions and flaring at the batteries and the by-products plant. According to ACLC meeting minutes, both events received little to no acknowledgment despite the extent of the events, public concerns, and media coverage. Likely for financial reasons to avoid loss of production time, a leak on the gas uptake of No.7 blast furnace in February 2020 was delayed despite the possibility that the structural integrity of the pipe could be compromised resulting in the pipe rupturing, releasing heavy emissions.

FINAL COMMENTS

The funds for these projects should have been previously committed and a portion of the current government funding should be reallocated to these environmental projects since there is an increased benzene exposure above “negligible” to the residents of Sault Ste. Marie. The proposal should not be granted beyond 2021 due to uncertainties with the actual benzene levels versus modelled values. The potential financial impacts to ASI may not be fully realized and may continue considering the pandemic is still ongoing. The proposal states that it is a one-time extension, but it could possibly be extended beyond 2022 for financial reasons, increasing the exposure time. Although the MECP expects ASI to continue to reduce benzene levels, there is no certainty that current levels will not increase before the work is to be completed. There should be a requirement for measured data to verify levels to validate any further delays to environmental initiatives that reduce benzene emissions at the facility.