I'm a community member that…

I'm a community member that lives in close proximity of the Steel industry in Hamilton. Our family is continuously affected by the pollution from the steel mills and the points below reflect the importance that this Amendment should include that will make the community more livable for all citizens of Hamilton.

• 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 (see website below) 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 direction of the industry. 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!
• The review for the MECP Cumulative Effects Study for Benzene and BaP was published in 2018, it was supposed to be reviewed by April 2020. Please post the review as soon as possible for public access. 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. As a result of this Study, I hope that actual actions can be written into the Environmental Compliance Approval that not only addresses new businesses but also the Steel Mills as they are the main sources of these carcinogens. It is time to write stringent level reductions into the Environmental Compliance Approval especially now that the Steel industry is preparing to move into the Technical Standard.
• This ECA amendment should mandate continuous benzene monitoring around the perimeters of the cooke by-product areas. Similar monitoring has been implemented for the petro chemical industry in Sarnia 2 years ago and has become the norm there. Stelco 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. (see link below for petro-chemical industry perimeter monitoring) More on passive monitors (see link below on passive-monitors) Sharing continuously measured data increases transparency and good will towards the community where these industries operate.
• Ministry orders associated with existing Site Specific Standard require Stelco 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 regarding polluting emissions on their websites.
• 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. This should be aligned with the Minister to ask the Federal Government to support the steel industry by providing monetary aid in order to move the industry into a negative/non-recovery oven designs which would be a tremendous help to us all who are affected by pollutants associated with steel making.
• The limits for coke ovens should distinguish between “tall” and “short” coke ovens and have their 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.
• 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. It is of utmost importance that all industries, including the steel industry make continuous progress to meet the Regulation 419. In order for this to happen the Ministry of Environment must set stringent, progressive level reductions that indicate that this is important to all but especially to those that live within close proximity of this industry and breathe the air these industries pollute.