RE: ERO 019-3812; MECP ref…

RE: ERO 019-3812; MECP ref. 3908-BXHSLG
Comments on ECA Application by Environmental 360 Solutions Ltd

In regard to the above-mentioned subject matter, we have conducted a review of the application and the Design & Operations Manual, and we wish to offer the following comments for consideration:

1. Operating Hours – This matter was not clearly defined in both the Design & Operations Manual and the ECA application form. We suggest that the Ministry ensure that the plant’s operations including the shipping and receiving activities at the site shall not be permitted outside the operating hours of 7 am to 7 pm, Monday to Friday. We understand that this condition is a usual requirement of the MECP in order to ensure that noise levels would not be excessive for the community and adjacent property owners/occupants.

2. Used Tire Storage within the confines of the Building - Environmental 360 Solutions Ltd is requesting a total plant storage capacity of 240 metric tonnes, or 24,000 PLT units. However, the ECA application and available supporting information do not provide detailed engineering drawings for the interior of the processing building demonstrating that 24,000 tire units can be safely stored and be readily accessible in in the event of a fire. This data including a floor plan and site drawing should demonstrate there is proper storage planning within the confines of the processing building and ideally will be made available for public review and comment.

3. Fire Suppression Sprinkler System – From the ECA application and the Design & Operations Manual, Environmental 360 Solutions Ltd is not proposing the installation of a Fire Suppression Sprinkler System for the processing building. For safety, we believe that this requirement should be mandatory and the design and installation of such a system should be approved by the local Fire Department. It is our understanding that there have been frequent fire incidents at used tire processing facilities due to the flammable nature of the rubber and textile fibre extracted from processing of used tires. As such, a fire suppression sprinkler system is often demanded by the municipal fire departments in Ontario. Fire extinguishers would not be sufficient as fire incidents often take place at overhead conveyor systems or other elevated locations inaccessible by fire extinguishers.

4. Public Consultation - ECA application Section 3.3 indicated that no public consultation has taken place for this proposal. We believe it is very important to ensure that adjacent landowners and occupants are aware of this application for establishing a used tire recycling facility in the community. Since the facility is defined as a Waste Disposal Site (whether or not the site is a final waste disposal site), notices and consultation with adjacent landowners should have been be carried out, prior to this application being submitted to MECP.

5. Financial Assurance – At this time, the ECA did not propose an amount for Financial Assurance.

6. Engineering Design Drawings and Site Plans - The plant design, processing equipment layout and the fire prevention equipment and sprinkler system should be prepared by a qualified specialized technical consulting firm with expertise in the area and such design drawings should receive approval from local fire department. Section 9.2 of the D & O Manual in our opinion does not adequately address the potentially highly flammable used tire crumbs, and nylon textile fibres which will be created in the processing facility.

7. Section 9.5 of the D & O Manual does not provide any information on potential dust generation during the production process and what control measures which would be put in place to reduce and control potential air emissions.