1) The main spirit of the…

1) The main spirit of the Site Specific Standard is working towards significant emission improvements to hopefully one day be in compliance with the Reg. 419 limits. Therefore the ECA amendment should also work towards implementing significant emission improvements going forward.

2) As a benchmark for the limits used for method 303 I suggest to use the Alegany County, PA, USA limits. These limits represent a continuous improvement for Ontario and the fact that they have already been implemented in a comparable jurisdiction should make it easy to implement them here in Ontario

3) The limits for coke ovens should distinguish between “tall” and “short” coke ovens and have the respective limits. This is being done in USA jurisdictions to better reflect the performance capabilities of coke ovens based on their physical shape. Ontario has implemented only the less stringent limits for tall ovens but is using them all across the board. I suggest to make two coke oven categories and impose stricter limits on short ovens, since they can naturally perform better than a tall oven. There is no good reasoning to not implement these improvements for short ovens.

The industry should be required to present a path forward to lay out a plan to move to negative pressure /non recovery coke oven designs. While these are long term plans they should nevertheless be mandated to be drafted up to start scheduling the implementation of better performing coke ovens in the mid and longer future.

5) Monitoring: This ECA amendment should mandate continuous benzene monitoring around the perimeters of the cooke by-product areas. Similar monitoring has been implemented for the metro chemical industry in Sarnia 2 years ago and has become the norm there. AMD should do the same and install passive benzene monitors with a 2 week measurement periods. All results should be made available publicly on an easy to access website with results going on the website within 20 days of receiving the laboratory results. Sharing continuously measured data increases transparency and good will towards the community where these industries operate.

6) Ministry orders associated with existing Site Specific Standard require AMD to establish community liaison committees (CLCs) and to host quarterly public meetings with CLCs to update CLC members and the broader community on progress in reducing the emission levels of contaminants for which the plants have Site Specific Standards. It is not clear based on the posting and supporting documents if the MECP will continue to impose this. I want the ECA to mandate the hosting of CLC meetings quarterly and have a requirement for the company to post quarterly performance data.

7) I suggest to review the MECP Cumulative Effects air study and update and/or impose further action as a result. This study has determined that its mean drivers for the Hamilton air shed are benzene and B(a)P. These known carcinogens are present in high concentrations in Hamilton. The dangers are great and a concern to all that live in the yellow and purple zone that stretches from Hamilton to Burlington to Stoney Creek and Dundas. I would like to see the review of the Cumulative Air study, initially proposed for April 2020 (2 years after preparing it initially) to happen as soon as possible. For instance the levels of allowed benzene emissions for AMD have not been reduced in a very significant way while the levels for Stelco were reduced over 50% after the first 5 year Site Specific Standard. The MECP in my view can not take educated action unless this study is reviewed and possible suggestions being implemented. It is time to take another step to get closer to the 0.45 ug/m3 goal of Reg. 419 limit.

8) Please include community placed monitors on this amendment. The HAMN monitoring network does not show the impacts on the community from the steel mills due to lack of monitoring in the community outside the industrial area. More monitors for PM2.5, benzene, SO2, NO2, etc. that include weather data and wind direction collectors should be placed permanently in the community within 2-3 km of the steel mills in Hamilton and Burlington. Monitors in the HAMN lack compound monitoring stations like benzene, SO2, NO2 etc in key community areas and wind direction collectors, eg. Monitor #STN29168 in St. Christopher Park, Hamilton. These monitors should be paid for by the industry ie. Stelco, AMD, Harsco, Rain Carbon, etc. so we, the citizens, can make informed decisions regarding health risks associated with exposure to these compounds as well as a good will gesture to the community/city for baring the brunt of the pollution we are exposed to on a daily basis. The effects are not only health related but also keep us from enjoying our properties. The smells of chemicals like sulphur and other noxious substances keeps us from being able to open windows on days when the wind comes from the industry direction. I don’t think many people in Ontario or Canada can say that it’s a normal thing to check the weather app to see where the wind is coming from now and for the next few hours before opening a window in their house. This is simply unacceptable!